Warfighter Support
Actions Needed to Improve the Joint Improvised Exposive Device Defeat Organization's System of Internal Control
Gao ID: GAO-10-660 July 1, 2010
In 2006, the Department of Defense (DOD) established the Joint Improvised Explosive Device Defeat Organization (JIEDDO) to lead, advocate, and coordinate all DOD actions to defeat improvised explosive devices (IEDs). Since 2007, GAO has reported on several issues related to JIEDDO's management and transparency of operations. In response to the 2008 National Defense Authorization Act conference report, mandating that GAO review JIEDDO's efforts, this report addresses the extent to which JIEDDO has (1) measured the effectiveness of its efforts and investments, (2) adhered to its review and approval process for developing counter-IED initiatives, and (3) taken action to address overall internal control weaknesses previously reported by GAO. To address these objectives, GAO analyzed relevant documents and discussed with relevant officials their guidance, oversight, and internal control processes to carry out JIEDDO operations. GAO also conducted case studies of 56 of 497 initiatives JIEDDO's initiative management system.
While JIEDDO has developed various output performance measures, it has not yet developed a means for reliably measuring the overall effectiveness of its efforts and investments to combat IEDs. Federal internal control standards require that organizations, such as JIEDDO, establish performance measures that compare the results of a program with its intended purpose. GAO recognizes that developing outcome measures that address JIEDDO's overall effect is difficult, but JIEDDO has not developed or followed through with a consistent process or plan to gather appropriate data and evaluate the fundamental effectiveness of the individual initiatives it has fielded. Some other limiting factors, according to JIEDDO officials, are that warfighters operating in theater face competing priorities that interfere with collecting data, and available data may not be consistently recorded and maintained. However, in the absence of a consistent process or plan for evaluating and collecting data from individual initiatives, JIEDDO will not be well-positioned to determine robust performance metrics and procedures to assess whether it is achieving DOD's counter-IED mission. JIEDDO has a review and approval process for developing counter-IED initiatives; however, it has not fully adhered to this process. Of the 56 initiatives GAO reviewed, JIEDDO excluded 26 from this process, and for the 30 that did go through the process, 22 did not show that they followed all of the required steps of the process. According to DOD's directive, all of JIEDDO's counter-IED initiatives are to go through this process, but JIEDDO's instruction designates non-counter-IED initiatives as overhead, and specifies that overhead will not go through this process. However, neither DOD's directive nor JIEDDO's instruction specifically define what constitutes a counter-IED initiative and what should be considered overhead. As a result, GAO found some initiatives designated as overhead which at the time were similar to others then designated as meeting an immediate counter-IED need or later given that designation. With respect to the 22 initiatives that did not follow all required process steps, some of their required documentation needed to confirm approval decisions was incomplete or missing. Without following the requirements of the process, DOD lacks the transparency and accountability of funds spent by JIEDDO. GAO identified several significant internal control system weaknesses that have been present at JIEDDO since GAO's first review in 2007. Beyond those identified in this report, those weaknesses extend to other areas such as financial and human capital management. Although JIEDDO has taken some steps in the past to address these weaknesses, those efforts have not been successful. According to federal standards, internal control is a major part of managing an organization. Some underlying reasons for JIEDDO's lack of progress in addressing these weaknesses include a lack of sustained management attention in following through with corrective actions; challenges with retention and expertise of personnel; and a lack of sufficient acquisition expertise with breadth and depth to understand the programs. GAO recommends JIEDDO take actions to improve (1) its processes for assessing effectiveness of counter-IED initiatives, (2) adherence to its initiative review and approval process, and (3) its overall internal control system. GAO also recommends DOD monitor JIEDDO's progress in improving its internal controls. DOD concurred with these recommendations.
Recommendations
Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director:
William M. Solis
Team:
Government Accountability Office: Defense Capabilities and Management
Phone:
(202) 512-8365
GAO-10-660, Warfighter Support: Actions Needed to Improve the Joint Improvised Exposive Device Defeat Organization's System of Internal Control
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
July 2010:
Warfighter Support:
Actions Needed to Improve the Joint Improvised Explosive Device Defeat
Organization's System of Internal Control:
GAO-10-660:
GAO Highlights:
Highlights of GAO-10-660, a report to congressional committees.
Why GAO Did This Study:
In 2006, the Department of Defense (DOD) established the Joint
Improvised Explosive Device Defeat Organization (JIEDDO) to lead,
advocate, and coordinate all DOD actions to defeat improvised
explosive devices (IEDs). Since 2007, GAO has reported on several
issues related to JIEDDO‘s management and transparency of operations.
In response to the 2008 National Defense Authorization Act conference
report, mandating that GAO review JIEDDO‘s efforts, this report
addresses the extent to which JIEDDO has (1) measured the
effectiveness of its efforts and investments, (2) adhered to its
review and approval process for developing counter-IED initiatives,
and (3) taken action to address overall internal control weaknesses
previously reported by GAO. To address these objectives, GAO analyzed
relevant documents and discussed with relevant officials their
guidance, oversight, and internal control processes to carry out
JIEDDO operations. GAO also conducted case studies of 56 of 497
initiatives JIEDDO‘s initiative management system.
What GAO Found:
While JIEDDO has developed various output performance measures, it has
not yet developed a means for reliably measuring the overall
effectiveness of its efforts and investments to combat IEDs. Federal
internal control standards require that organizations, such as JIEDDO,
establish performance measures that compare the results of a program
with its intended purpose. GAO recognizes that developing outcome
measures that address JIEDDO‘s overall effect is difficult, but JIEDDO
has not developed or followed through with a consistent process or
plan to gather appropriate data and evaluate the fundamental
effectiveness of the individual initiatives it has fielded. Some other
limiting factors, according to JIEDDO officials, are that warfighters
operating in theater face competing priorities that interfere with
collecting data, and available data may not be consistently recorded
and maintained. However, in the absence of a consistent process or
plan for evaluating and collecting data from individual initiatives,
JIEDDO will not be well-positioned to determine robust performance
metrics and procedures to assess whether it is achieving DOD‘s counter-
IED mission.
JIEDDO has a review and approval process for developing counter-IED
initiatives; however, it has not fully adhered to this process. Of the
56 initiatives GAO reviewed, JIEDDO excluded 26 from this process, and
for the 30 that did go through the process, 22 did not show that they
followed all of the required steps of the process. According to DOD‘s
directive, all of JIEDDO‘s counter-IED initiatives are to go through
this process, but JIEDDO‘s instruction designates non-counter-IED
initiatives as overhead, and specifies that overhead will not go
through this process. However, neither DOD‘s directive nor JIEDDO‘s
instruction specifically define what constitutes a counter-IED
initiative and what should be considered overhead. As a result, GAO
found some initiatives designated as overhead which at the time were
similar to others then designated as meeting an immediate counter-IED
need or later given that designation. With respect to the 22
initiatives that did not follow all required process steps, some of
their required documentation needed to confirm approval decisions was
incomplete or missing. Without following the requirements of the
process, DOD lacks the transparency and accountability of funds spent
by JIEDDO.
GAO identified several significant internal control system weaknesses
that have been present at JIEDDO since GAO‘s first review in 2007.
Beyond those identified in this report, those weaknesses extend to
other areas such as financial and human capital management. Although
JIEDDO has taken some steps in the past to address these weaknesses,
those efforts have not been successful. According to federal
standards, internal control is a major part of managing an
organization. Some underlying reasons for JIEDDO‘s lack of progress in
addressing these weaknesses include a lack of sustained management
attention in following through with corrective actions; challenges
with retention and expertise of personnel; and a lack of sufficient
acquisition expertise with breadth and depth to understand the
programs.
What GAO Recommends:
GAO recommends JIEDDO take actions to improve (1) its processes for
assessing effectiveness of counter-IED initiatives, (2) adherence to
its initiative review and approval process, and (3) its overall
internal control system. GAO also recommends DOD monitor JIEDDO‘s
progress in improving its internal controls. DOD concurred with these
recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-10-660] or key
components. For more information, contact William M. Solis, (202)512-
8365 or solisw@gao.gov.
[End of section]
Contents:
Letter:
Background:
JIEDDO Has Not Developed a Means for Reliably Measuring the
Effectiveness of Its Efforts to Combat IEDs:
JIEDDO Has Not Fully Adhered to Its Review and Approval Process for
Managing Counter-IED Efforts:
Lack of Sustained JIEDDO Management Attention and Ineffective DOD
Oversight Hampered Efforts to Improve JIEDDO's Overall Internal
Control System:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Defense:
Appendix III: GAO Contact and Acknowledgments:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 1, 2010:
Congressional Committees:
Improvised explosive devices (IED) continue to be the number one
threat to U.S. troops in Iraq and Afghanistan. To address this threat,
a Department of Defense (DOD) directive[Footnote 1]established the
Joint Improvised Explosive Device Defeat Organization (JIEDDO) in 2006
and directed it to lead, advocate, and coordinate all DOD actions in
support of the Combatant Commanders and their respective Joint Task
Forces' efforts to defeat IEDs as weapons of strategic influence. A
primary role for JIEDDO is to provide funding to the military services
and DOD agencies to rapidly develop and field counter-IED solutions.
Through fiscal year 2010, Congress has appropriated over $17 billion
to JIEDDO to address the IED threat. In addition, other DOD
components, including the military services, have devoted at least
$1.5 billion to counter-IED solutions, not including $22.7 billion for
Mine Resistant Ambush Protected vehicles. Along with the escalation in
Afghanistan, the IED threat is increasingly expanding throughout the
globe with over 300 IED events per month worldwide outside of Iraq and
Afghanistan, according to JIEDDO. There is widespread consensus that
this threat will not go away and that the IED will continue to be a
strategic weapon of influence in future conflicts.
In response to congressional direction,[Footnote 2] GAO has issued a
series of reports examining a broad spectrum of JIEDDO's operations
including its ability to lead, advocate, and coordinate counter-IED
efforts across DOD as well as establish itself as an accountable
organization that can effectively manage billions of dollars in
funding. As DOD looks to the future in deciding the appropriate role,
organizational placement, and degree of Office of Secretary of Defense
(OSD) oversight for JIEDDO, addressing these types of issues will be
critical. For this report, we determined the extent to which JIEDDO
has (1) measured the effectiveness of its efforts and investments, (2)
adhered to its review and approval process for developing counter-IED
initiatives, and (3) taken action to address overall internal control
weaknesses previously reported by GAO.
To assess JIEDDO's efforts to measure the effectiveness of its efforts
and investments, we requested, reviewed, and discussed with JIEDDO
officials current and anticipated efforts to measure and evaluate its
operations and activities. We reviewed these efforts to determine the
progress, breadth, and depth of JIEDDO's measurement development and
their applicability towards JIEDDO's ability to successfully evaluate
its operations initiatives. To assess JIEDDO's adherence to its review
and approval process, we reviewed, analyzed, and discussed JIEDDO
guidance with JIEDDO officials to identify key steps in its process.
We then analyzed data from 56 case studies representing the most
costly initiatives of the 497 initiatives in JIEDDO's initiative
management system for fiscal years 2008 and 2009 to determine whether
JIEDDO's stated process was followed by JIEDDO managers and personnel.
[Footnote 3] These case studies included over $4.67 billion in fiscal
year 2009 projects and initiatives. We also identified required
approval controls over use of funds, reviewed selected transactions
for compliance with these controls, and assessed whether the data
recorded in the accounting and managerial systems accurately reflected
JIEDDO's activities. To assess JIEDDO's actions to address overall
internal control system weaknesses previously reported by GAO, we
interviewed and discussed with JIEDDO officials their efforts to
improve JIEDDO's internal control system in response to prior related
GAO findings. We collected and reviewed internal and external guidance
[Footnote 4] and documentation of JIEDDO's internal control system. We
reviewed and compared JIEDDO's annual statements of assurance
regarding JIEDDO's internal controls system. We then analyzed the
information collected and discussed the significance of conditions
observed with JIEDDO officials. We conducted this performance audit
from May 2008 to May 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. See appendix I for a more complete discussion of GAO's
scope and methodology.
Background:
JIEDDO was created by the Deputy Secretary of Defense in January 2006
and is responsible for leading, advocating, and coordinating all DOD
efforts to defeat IEDs. Prior DOD efforts to defeat IEDs included
various process teams and task forces. For example, DOD established
the Joint IED Defeat Task Force in June 2005 for which the Army
provided primary administrative support. This task force replaced the
Army IED Task Force, the Joint IED Task Force, and the Under Secretary
of Defense, Force Protection Working Group. To focus all of DOD's
efforts and minimize duplication, DOD published new counter-IED policy
in February 2006 through DOD Directive 2000.19E, which changed the
name of the Joint IED Defeat Task Force to JIEDDO and established it
as a joint entity and jointly manned organization within DOD,
reporting to the Deputy Secretary of Defense. The directive states
that JIEDDO shall "focus" (i.e., lead, advocate, and coordinate) all
Department of Defense actions in support of the Combatant Commanders
and their respective Joint Task Forces' efforts to defeat IEDs as
"weapons of strategic influence." The organization is directed to
identify, assess, and fund initiatives that provide specific counter-
IED solutions, and its director has the authority to approve joint IED
defeat initiatives valued up to $25 million and make recommendations
to the Deputy Secretary of Defense for initiatives valued over $25
million. Under the directive, JIEDDO reports directly to the DOD
Deputy Secretary of Defense.
It is JIEDDO's role to provide funding to the military services and
DOD agencies to rapidly develop and field counter-IED solutions.
Congress has provided JIEDDO with its own separate direct
appropriation since 2007. JIEDDO uses its appropriation to provide
funds to the military service that is designated to sponsor counter-
IED initiatives using Military Interdepartmental Purchase Requests.
Departmental guidance also states that the acquiring department, or
military service, is then authorized to create obligations against the
funding without further referral to the requiring department--JIEDDO--
and that the military service has no responsibility to determine the
validity of a requiring-department-approved purchase request.
Therefore, after JIEDDO provides funding authority to the military
service and the designated program manager for a specific initiative,
the service program manager, not JIEDDO, is responsible for managing
the initiatives for which JIEDDO has provided funds.
JIEDDO's efforts to counter the use of IEDs and subsequent funding for
those efforts are organized according to three primary lines of
operation: (1) attack the network that enables the use of IEDs, (2)
defeat the IED itself once emplaced, and (3) train the military forces
in counter-IED techniques. JIEDDO assigns all funds used to one of
these lines of operation--or to a fourth line of operation called
staff and infrastructure[Footnote 5] for miscellaneous expenditures
not directly related to the three lines of operation. When JIEDDO
undertakes any effort requiring funds, it assigns the funds for the
effort to one of the lines of operations. As noted in our prior
report,[Footnote 6] JIEDDO further breaks down its expenditures into
more detailed subsets, which it designates as initiatives, assigning a
name and a unique number called an initiative designation number to
track expenditures related to each initiative. JIEDDO manages and
reports on all funds expended by line of operation and by initiative.
In prior GAO reviews, we reported on several issues related to
JIEDDO's management and operations. In March 2007, we reported
JIEDDO's lack of a strategic plan and the resulting effects on the
development of its financial and human capital management programs. We
made several recommendations based on this finding to the Secretary of
Defense to improve the management of JIEDDO operations, stressing the
development of JIEDDO's detailed strategic plan. Subsequently, we also
reported in March 2008 on JIEDDO's internal controls and made several
recommendations focused at improving JIEDDO's internal control system.
JIEDDO agreed with our recommendations and undertook efforts to
address our findings and recommended actions. In addition, we
testified and issued a report in October 2009 regarding steps that
JIEDDO and DOD have taken to manage counter-IED efforts. Our testimony
also included some of the challenges we discuss in this report.
[Footnote 7]
In November 2007, JIEDDO published and implemented its Joint
Improvised Explosive Device Defeat Capability and Acquisition
Management Process (JCAAMP) instruction,[Footnote 8] and updated the
instruction in November 2009.[Footnote 9] JCAAMP is JIEDDO's process
to respond to urgent warfighter needs; to identify counter-IED
operational capability gaps; to aggressively seek, acquire, and assess
potential materiel and nonmateriel solutions to these gaps through
finding networks that include industry, academic, and service research
labs experts; and to place approved counter-IED initiatives in the
hands of warfighters for operational assessment and deployment. JCAAMP
is intended to enable a smooth transition or transfer of counter-IED
initiatives to one or more services or agencies and provides guidance
on the disposition of those initiatives recommended for termination.
The JCAAMP instruction defines JCAAMP's roles, responsibilities, and
oversight requirements as applicable to all JIEDDO (subordinate
divisions, branches) and other components.
JIEDDO Has Not Developed a Means for Reliably Measuring the
Effectiveness of Its Efforts to Combat IEDs:
While JIEDDO has developed various output-focused performance
measures, it has not yet developed a means for reliably measuring the
effectiveness of its overall efforts and investments to combat IEDs.
Existing metrics focus more on outputs than outcomes. Outputs describe
the level of activity that will be provided over a period of time,
including a description of characteristics such as timeliness or
percentage of products or services delivered.[Footnote 10] Examples of
JIEDDO output measures include metrics to evaluate its response time
in satisfying urgent theater requirements, the quality and relevance
of counter-IED proposals JIEDDO solicits and receives in response to
its solicitations, and the ratio of initiatives for which JIEDDO
completes operational assessments. However, these metrics do not
inform JIEDDO or stakeholders about the effect the agency's efforts
have on combating IEDs as a weapon of strategic influence. JIEDDO has
not developed or followed through with a consistent process or plan to
gather appropriate data and evaluate the fundamental effectiveness of
the individual initiatives it has fielded. JIEDDO officials stated
they have extreme difficulty in reliably gauging the effectiveness of
JIEDDO's efforts and investments on combating IEDs. They attributed
this difficulty to not being able to establish a statistically based
causal relationship between JIEDDO efforts and counter-IED trends.
Nonetheless, federal internal control standards require that
organizations such as JIEDDO establish internal control activities
that help ensure the establishment and review of performance measures
and indicators that compare the results of its program activity with
the plans, goals, and objectives as envisioned by the Government
Performance and Results Act, which suggests that an organization
design its performance measures to compare the results of a program
activity with its intended purpose.[Footnote 11] In our 2007 report on
JIEDDO's lack of a strategic plan,[Footnote 12] we noted that JIEDDO
lacked measurable goals and objectives. JIEDDO's Fiscal Year 2009-2010
strategy stated that finding a set of measures that clearly reveal
JIEDDO's overall contribution to the counter-IED fight remains an
analytical challenge.[Footnote 13]
Evaluating the effectiveness of individual initiatives would help to
inform JIEDDO about its overall effectiveness in countering the IED
threat. However, JIEDDO has not developed or followed through with a
consistent process or plan to establish how it will evaluate the
fundamental effectiveness of its individual initiatives it has fielded
and to collect needed data. In addition to a lack of good outcome-
oriented metrics, other relevant factors contributing to JIEDDO's
difficulty in measuring the effectiveness of individual initiatives
include: (1) data on effectiveness of initiatives are not consistently
collected in theater, (2) initiative management data are not
consistently recorded and maintained at JIEDDO, and (3) performance
data regarding unexpected outcomes such as ineffectiveness of certain
counter-IED efforts are not always evaluated as a means to highlight
potential improvement.
* Data on Effectiveness of Initiatives Are Not Consistently Collected
in Theater: According to JIEDDO officials, because time is critically
limited when counter-IED initiatives are designed for deployment in
theater, the initiatives may not be designed or developed with
adequate data collection procedures to provide information needed for
statistically based assessment of initiatives' effectiveness. JIEDDO
officials told us that data for fielded initiatives can be limited
because collection and documentation of such data do not carry a high
priority for units and soldiers operating in theater. JIEDDO does not
have steps that ensure that potential feedback processes are included
in the design phase as a firm requirement when considering investing
in a counter-IED initiative.
* Initiative Management Data Are Not Consistently Recorded and
Maintained at JIEDDO Because of Availability Limitations: Data that
officials stated should be available at JIEDDO to be used for
measuring effectiveness sometimes are not available because
documentation of information has not been routinely and reliably
recorded at JIEDDO. For example, we found that the date, source, and
initial concept for one counter-IED initiative--required by JIEDDO and
needed to establish performance baselines--were not available,
according to officials, either because they had not been recorded or
because they had not been retained. While JIEDDO has established
standards for document storage and retention and implemented a system
for storing and managing documents, these efforts require a degree of
compliance not yet achieved. Officials attributed the condition of
poor data quality to JIEDDO staff perception that routine
documentation of information is of limited value and that other higher
value pursuits such as rapid acquisition of initiatives should take
priority amongst their limited available time. JIEDDO officials are
aware that improving discipline at identifying and routinely
documenting JIEDDO-generated information is needed to conduct counter-
IED initiative evaluations. For example, JIEDDO recently formed and
staffed a team of individuals that is expected to review all new
funding requests to determine whether the associated counter-IED
effort will involve an increase in staff or require development or
expansion of JIEDDO infrastructure. The team reportedly has developed
a routine process for reviewing, discussing, questioning, commenting,
and most importantly, recording these actions and decisions in a
traceable record that has begun to provide JIEDDO managers and staff
with a reliable source of historic events and decision points for
subsequent data analysis. According to the Internal Review Director,
JIEDDO plans to expand this documentation process to other key teams
managing other dimensions of counter-IED initiatives. However, it is
too early for us to evaluate the consistent use and effectiveness of
this new process or JIEDDO's plans to implement it across the rest of
the organization.
* Performance Data on Unexpected Outcomes Are Not Always Evaluated for
Impact: JIEDDO may not be adequately evaluating the ineffectiveness of
its counter IED initiatives, and therefore not adequately pursuing and
presenting data that show where improvement may be necessary. For
example, in response to a general officer request in Iraq, the
Institute for Defense Analysis collected and analyzed IED incident
data before and after a certain initiative to determine its effect on
the rate of IED incidents. JIEDDO officials intended the initiative in
question to reduce the number of IED attacks. However, the data
collected contradicted the intended result because the number of IED
incidents increased in areas where the initiative was implemented.
These data could provide lessons learned to fix the initiative or to
suggest another approach towards JIEDDO's strategic goal of reducing
IED incidents. However, JIEDDO officials stated that JIEDDO did not
analyze these data because they would not demonstrate effectiveness
and consequently, JIEDDO may be overlooking data useful for
identifying areas for improvement.
More broadly, JIEDDO's strategic plan development efforts have not
produced a satisfactory set of performance measures to gauge JIEDDO's
effect on achieving DOD's counter-IED mission, nor an effective data
collection and evaluation plan. In the absence of a commitment to this
effort with a consistent process or plan for collecting and evaluating
data from individual initiatives, JIEDDO will not be well-positioned
to determine whether it is achieving DOD's counter-IED mission as
contemplated by the Government Performance and Results Act.[Footnote
14]
JIEDDO Has Not Fully Adhered to Its Review and Approval Process for
Managing Counter-IED Efforts:
JIEDDO has a review and approval process for developing counter-IED
initiatives--JCAAMP--however, JIEDDO has not fully adhered to this
process. Specifically, we reviewed 56 of JIEDDO's most costly
initiatives in its financial records for fiscal years 2008 and 2009
and determined that 26 of the initiatives were excluded from the
process outright because JIEDDO designated them as overhead not
subject to JCAAMP. According to JIEDDO officials, "overhead" is a
broad and diverse category including staff and infrastructure
requirements, operations and plans support, developmental efforts,
counter-IED training support efforts, and general support requirements
for JIIEDDO. However, because JIEDDO guidance is so broad it is not
clear which initiatives should be considered counter-IED initiatives,
and consequently some counter-IED initiatives were excluded from
JIEDDO's JCAAMP process.[Footnote 15] Furthermore, for those 30
counter-IED initiatives that did go through the process, JIEDDO did
not consistently follow required steps of the process for 22 of these
initiatives.
JIEDDO Has Excluded Some Counter-IED Initiatives from Its Review and
Approval Process:
We found that of the 56 initiatives we reviewed, JIEDDO excluded 26 of
them from JCAAMP. Based on DOD Directive 2000.19E,[Footnote 16] all of
JIEDDO's counter-IED initiatives are to go through JIEDDO's review and
approval process (JCAAMP) which includes obtaining the Deputy
Secretary of Defense's approval for all JIEDDO initiatives valued
greater than $25 million. Additionally, JIEDDO Instruction 5000.01
designates non-counter-IED initiatives as overhead, and specifies that
overhead will not go through this process.[Footnote 17] JIEDDO has
characterized the governance mechanisms of its review and approval
process--including the Deputy Secretary of Defense's approval for
initiatives exceeding $25 million--as perhaps the most important part
of its process before committing funding to any initiative. DOD
defines an initiative as a materiel or nonmaterial solution that
addresses capability gaps in defeating IEDs.[Footnote 18] However,
neither DOD Directive 2000.19E nor JIEDDO Instruction 5000.01
specifically defines what constitutes a counter-IED initiative and
what is considered overhead. To illustrate,
* JIEDDO excluded one of two very similar training initiatives from
its review process, both of which fund role players at the national
training center to create a realistic war scenario. JIEDDO processed
one initiative through JCAAMP with role players with speaking roles
and not the other because it only involved role players as nonspeaking
extras. According to JIEDDO officials, they classified the initiative
with role players as extras as an overhead requirement thereby
excluding it from JCAAMP. However, both initiatives are similar in
purpose and objective, which is to enhance the counter-IED training
experience by creating a realistic war scenario at the national
training center. The excluded initiative appears to be a solution that
addresses capability gaps in defeating IED, not overhead, and
therefore should not have been excluded from JIEDDO's review and
approval process.
* In the March 2009 data we collected to conduct our case studies,
JIEDDO designated a radar system initiative--the Vehicle Dismount
Exploitation Radar--as an overhead requirement because according to
JIEDDO officials it was not ready to satisfy all existing operational
needs for which it was being developed. Therefore, it was excluded
from the JCAAMP process. However, even though designated as overhead,
JIEDDO officials slated the device to satisfy an immediate counter-IED
urgent need from theater in April 2009 and said that they expected to
field the device within fiscal year 2010. Although JIEDDO officials
classified the initiative as overhead, because it was not ready to
satisfy all existing operational needs and therefore not ready to be
fielded, both the directive and instruction are unclear about whether
maturity or counter-IED application should be the deciding factor in
determining whether an effort should be designated as overhead or an
initiative. Classification of the radar system as an overhead
requirement meant that JIEDDO did not submit this initiative for
Deputy Secretary of Defense approval, even though JIEDDO has expended
approximately $67.4 million on the initiative--exceeding the $25
million total life-cycle approval criteria more than twofold. This
initiative appears to be a solution that addresses capability gaps in
defeating IED, not overhead, and therefore should not have been
excluded from JIEDDO's process.
Overall, we determined that the 26 initiatives excluded from JCAAMP
had total funding requirements of $1.5 billion as of March 31, 2009,
and represented about one third of the total $4.67 billion
requirements for all 56 of our case studies. In addition, when we
requested data to be able to conduct this review, we found that JIEDDO
does not maintain and track information identifying which initiatives
it designates as overhead requirements and excludes from this process
in a comprehensive, readily accessible format. When initiatives are
excluded from JCAAMP, internal and external stakeholders do not have
the opportunity to review, comment on, and potentially change the
course of the initiative in coordination with competing or
complementary efforts.
JIEDDO Did Not Fully Apply Its Management Process to Counter-IED
Initiatives:
Among 30 initiatives from our 56 case studies that JIEDDO said went
through the JCAAMP process, we found 22 examples involving
inconsistent and inadequate compliance with steps required by
applicable DOD guidance. JIEDDO's charter,[Footnote 19]JIEDDO's
process instruction,[Footnote 20] and JIEDDO's standard operating
procedures[Footnote 21] together identify a set of various decision
points and actions, collectively intended to control JIEDDO's use of
resources to identify, acquire, assess, and place counter-IED
initiatives. In reviewing documentation and application of these
criteria to counter-IED initiatives, we determined JIEDDO did not
consistently comply with its requirements. For summary reporting
purposes, we tallied the incidences of inconsistency and noncompliance
and grouped them into the following three categories:
* Incomplete or Missing Initiative Decision Memos: JIEDDO's standard
operating procedure requires that JIEDDO (1) document each of its
decisions to release funds for counter-IED initiatives in separate,
detailed, written formal initiative decision memoranda approved and
signed by the director or his deputy director; (2) complete the
initiative decision memorandum before obligating funds for the subject
counter-IED initiative; and (3) retain and file a copy of the
initiative decision memorandum with each resulting funding document
created by JIEDDO's budget and accounting directorate. However, we
found that 19 of 30 initiative case studies had not complied with one
or more of these requirements consistently. For example, the
initiative decision memorandum supporting JIEDDO's release of $13.9
million in funds on April 17, 2008, for one initiative was
procedurally not compliant because (1) it was signed 2 days after the
funding was issued to and accepted by the service sponsor--i.e., the
military service JIEDDO designated to sponsor this initiative--and (2)
it was signed by a division official, not by the director or deputy
director as required.
* Lack of Required Initiative Approval: JIEDDO's guidance requires
that counter-IED initiatives that exceed $25 million in total
acquisition cost for JIEDDO's tenure of ownership (or are reasonably
expected to exceed $25 million) in funding requirements be (1)
submitted to an external panel of 15 senior managers from various
functional areas within DOD for advice, review, and recommendations
whether to proceed with the initiative; and (2) subsequently approved
by the Deputy Secretary of Defense--based on his judgment and
consideration of the DOD senior managers' recommendations and
comments--before JIEDDO creates an initiative funding memorandum or
provides funds for the initiative.[Footnote 22] However, we found 13
of the 30 initiatives did not comply with these requirements before
issuing funds to the service sponsors for the initiatives. For
example, JIEDDO created and signed an initiative decision memorandum
on March 19, 2008, to begin one initiative project expected to cost
$348 million, before submitting the initiative for review to the
senior managers' external panel and obtaining Deputy Secretary of
Defense approval. JIEDDO did not receive external approval from the
deputy secretary of defense until April 18--about 1 month after
funding was issued for the initiative--resulting in premature
commitment and obligation of $28.7 million for the initiative on March
24, 2008, without required authorization.
* Lack of Consistent Initiative Documentation of Decisions and Events:
JIEDDO officials told us that process decisions and events of counter-
IED initiatives receiving funds should be physically documented and
filed within the appropriate folders and digitally captured via its
data management tool. The purpose of this documentation is to provide
proof of JIEDDO actions and an audit trail for JIEDDO personnel and
others to determine the history and progress of an initiative. JIEDDO
is expected to secure and store the physical files at its headquarters
for a period of 6 years with only authorized budget personnel allowed
to remove the files using a tracking system for physical control.
After 6 years, the documents are expected to be digitally archived and
the physical files destroyed. However, 22 of the 30 initiatives we
studied were not implemented consistent with the processes described
by JIEDDO officials, even though JIEDDO financial records indicate
that JIEDDO had issued funds to service sponsors for the initiatives
studied. For example, in 5 cases, file folders for initiatives we
reviewed were not available for review when requested, and JIEDDO
officials could not determine where the files were located or who
possessed the files at the time of our request. Available folders for
other initiatives did not contain all required documentation for
various specific JIEDDO decisions and actions. Some file folders did
not have accurately dated and signed copies of purchase requests; some
had documents that contradicted one another, and others had documents
missing entirely.
According to JIEDDO officials, systematic compliance with its process
and documentation thereof has been a weakness that JIEDDO has
attempted to correct and continues to pursue improvements in this
regard. In response to findings discussed in this report, officials
from JIEDDO's accounting and budgeting division, acquisition oversight
division, and internal review division said that the discipline and
compliance with JIEDDO's process for managing counter-IED initiatives
have improved significantly beginning in the last quarter of fiscal
year 2009. They point out that this period occurred after the bulk of
our study and analysis of selected JIEDDO initiatives, and that it is
too early to determine the full effect of these improvements.
Nonetheless, while JIEDDO may have taken steps to address some of our
concerns, this review's findings and the findings of prior GAO reports
underscore that JIEDDO has not had a systematic process in place to
adequately manage or fully document its activities and operations for
the majority of its operating life, nor, as discussed more fully
below, an effective internal control process to ensure consistent
compliance with process and documentation requirements. Because, as
JIEDDO officials state, it is too early to assess the effects of
JIEDDO's subsequent action, it is not clear if this condition has
improved. When JIEDDO does not adhere to its established acquisition
process, including maintaining required documentation, transparency is
limited and accountability of funds is in jeopardy.
Lack of Sustained JIEDDO Management Attention and Ineffective DOD
Oversight Hampered Efforts to Improve JIEDDO's Overall Internal
Control System:
Our prior and current audit work has identified a long-standing
problem of inadequate attention to internal control weaknesses by
JIEDDO management such as those related to strategic planning, program
management, and financial and human capital management. At the same
time, OSD officials, including the office of the Deputy Secretary of
Defense, to whom JIEDDO officially reports, have provided limited
oversight of JIEDDO's overall internal control system. According to
federal standards, internal control is a major part of managing an
organization. It comprises the plans, methods, and procedures used to
meet missions, goals, and objectives; and, in doing so, supports
performance-based management.[Footnote 23] Furthermore, DOD relies on
JIEDDO's system of internal controls for assurance that JIEDDO is
achieving its objectives.
JIEDDO Has Not Taken Sufficient Action to Address Persistent Internal
Control Weaknesses:
JIEDDO has significant weaknesses in its system of internal control
that have persisted since it was established in January 2006.
According to federal internal control standards, monitoring of
internal controls should be conducted to assess the quality of
performance over time and to ensure that the findings of audits and
other reviews are promptly resolved.[Footnote 24] However, JIEDDO has
not taken sufficient action to monitor the quality of its system of
internal control and correct identified control deficiencies. In our
prior reports, we concluded that JIEDDO needed more transparency over
its resources and needed to address specific internal control
weaknesses.[Footnote 25] For example, in March 2008, we reported that
JIEDDO lacked adequate controls to ensure counter-IED initiatives are
properly approved before they are funded. As evidenced earlier in this
current report, at the time of our review JIEDDO still lacked
effective controls over the approval of initiatives and it is too soon
to determine if any subsequent actions by JIEDDO have significantly
improved this condition. We also reported in March 2008 that JIEDDO
lacked an effective system of internal control over its financial
processes. More recently, based on the Internal Review Director's
assessment of our prior work regarding ongoing weaknesses in JIEDDO's
internal control system, JIEDDO management acknowledged and reported
to DOD in July 2009 that its internal control system was materially
weak.[Footnote 26] JIEDDO management attributed its failure, in part,
to not having an individual on staff with sufficient competence to
both understand internal control system requirements and ability to
educate and persuade management of the serious need for JIEDDO to
formally develop, implement, test, evaluate, and adjust as needed its
internal control program.
JIEDDO's lack of progress in resolving its internal control problems
is, in part, due to a lack of sustained management attention in
following through with corrective actions. Responding to our prior
work and concerns from within DOD and JIEDDO's congressional oversight
committees, JIEDDO initiated several actions to improve internal
control processes. For example, JIEDDO established an Internal Review
office charged with developing, administering, and overseeing an
internal control system in September 2007. It also developed and
expanded an internal oversight division--called the Acquisition
Oversight Division--charged with oversight of counter-IED initiatives
funded by JIEDDO in March 2008. However, JIEDDO has not followed
through in fully implementing these actions to improve its internal
control system. For example, although JIEDDO intended to hire several
internal review personnel to staff its newly established internal
review office, it hired only one person to staff the office in
November 2007 and that person left in February 2009 without having
succeeded in establishing a formal internal control system.
Furthermore, this office remained unstaffed until April 2009, when
JIEDDO officials hired a new Internal Control Director to reestablish
and manage its internal review office.
Additionally, after JIEDDO established the Acquisition Oversight
Division in May 2008, JIEDDO senior management later questioned the
appropriateness of this division's attempt to closely review JIEDDO's
testing activity that assesses the compatibility and effectiveness of
its individual counter-IED initiatives before being placed in actual
use. The acquisition oversight division was established to address
Office of Secretary of Defense concerns regarding the need to separate
day-to-day JIEDDO internal oversight of counter-IED initiatives from
JIEDDO's operating division responsible for developing and
implementing the initiatives.[Footnote 27] JIEDDO management officials
said the testing activity had a self-monitoring component and
therefore considered the acquisition oversight division's review
redundant. The acquisition oversight division countered that its
review verified that the self-monitoring component of the testing
activity was not functioning as intended. Nonetheless, in May 2009,
JIEDDO management removed oversight responsibility for testing
activities from the acquisition oversight division's purview. Later,
JIEDDO's internal review office conducted an audit which proved that
self-monitoring by the testing activity was not sufficient and
corroborated the need for the acquisition oversight division's audits.
During ongoing operations reorganization, begun in November 2009,
JIEDDO officials developed plans to eliminate the acquisition
oversight division and disperse its manpower to other JIEDDO positions
within its operating division, thus resulting in no longer making
oversight their function in the organization. This action would
effectively eliminate a process for identifying and reporting
weaknesses with counter-IED initiatives. JIEDDO officials stated that
its plan to eliminate the acquisition oversight division did not
preclude JIEDDO from developing alternative oversight mechanisms.
[Footnote 28]
During the course of this review, the JIEDDO Internal Review Director
said JIEDDO had taken three new actions to remedy internal control
weaknesses present at JIEDDO. Those actions are (1) hiring the
internal review office's first subordinate staff member--an auditor--
in August 2009 to assist the Internal Review Director in evaluating
the effectiveness of JIEDDO's internal controls, (2) engaging a
consulting firm to assist in its internal control implementation
efforts in November 2009, and (3) instituting formal internal control
education activities in February 2010. Although it is too early to
know whether these new efforts to improve JIEDDO's system of internal
controls will be successful, we continue to be concerned whether they
will address internal control shortcomings given JIEDDO's past
failures in implementing corrective actions and sustaining them over
time. However, as of January 2010, JIEDDO was assigned a new director,
and its management team has recently expressed its intention to
address program internal control weaknesses. This new leadership has
recognized the challenge JIEDDO faces in maintaining prompt delivery
of counter-IED solutions while ensuring appropriate controls are in
place to maintain accountability.
In addition to concerns regarding JIEDDO management's past commitment
to address weaknesses in its overall system of internal controls,
improvements to JIEDDO's internal control system may also be hampered
by challenges with the retention and expertise of personnel, ranging
from scientists, system engineers, and operations research analysts,
to intelligence analysts, budget analysts, accountants, and auditors.
For example, JIEDDO is faced with challenges in retaining a
sufficiently stable labor pool that is adequately sized to support a
system of internal controls on an ongoing basis because employees are
uncertain regarding the permanence of JIEDDO. In July 2009, JIEDDO
reported to DOD that staffing supervision challenges and retaining
trained program administrators at JIEDDO are underlying causes for its
inadequate internal control program development and implementation.
[Footnote 29] For example, JIEDDO's July 2009 assurance statement
report states that its practice of satisfying large portions of its
labor requirements through service contracts has resulted in a high
ratio of contractors to government employees, and therefore it has too
few government managers to oversee inherently governmental functions.
[Footnote 30] This condition could also result in compressing the
amount of time to carry out internal controls. JIEDDO officials have
requested approval for adding 141 additional government employee
positions and converting 192 positions currently for contractors to
government employee positions to remedy the condition and received
approval in February 2010 to begin hiring personnel to fill the new
and converted positions. However, according to JIEDDO officials,
successfully filling those positions with a stable, retainable
workforce remains a challenge because the positions require a specific
and significant set of skills that have been in short supply,[Footnote
31] and JIEDDO anticipates difficulty filling these positions. Also,
JIEDDO, as an organization, exists based on its relevance to combating
the IED threat, according to JIEDDO management. Therefore, according
to JIEDDO officials, potential employees may be concerned about
professional advancement and job security.
Furthermore, JIEDDO officials state that JIEDDO is challenged by a
lack of sufficient acquisition expertise with breadth and depth of
understanding and experience in program acquisition. Specifically,
JIEDDO's operating divisions are devoid of positions that are either
classified as acquisition positions, or specifically require
acquisition expertise. Such expertise is needed to ensure that its
acquisitions are conducted skillfully. An important part of JIEDDO's
mission is to rapidly acquire counter-IED solutions in support of the
warfighter, and federal control standards state that management should
ensure that its workforce has the skills necessary to help an
organization achieve its goals. However, in February 2010, a team of
four independent acquisition experts conducted a brief review of
JIEDDO's acquisition process at the request of the new director and
observed that JIEDDO has no positions for persons with acquisition and
program management experience.[Footnote 32] The team recommended
creating acquisition professional positions within JIEDDO's formal
organization and filling these positions with persons who have this
acquisition experience. However, JIEDDO faces a challenge in filling
these positions with qualified acquisition professionals because such
professionals are in high demand as a result of DOD efforts to
increase its acquisition workforce across the department. Nonetheless,
such expertise would help JIEDDO minimize risks in acquiring equipment
or systems because it could address issues early in the acquisition
process and, as a result, might avoid costly fixes in later stages in
the acquisition process. For example, according to one expert from the
acquisition review team, this expertise would help JIEDDO know how to
ensure that JIEDDO's rights, such as how to repair or engineer changes
to an acquired system, are included in the contract, because if
neglected, can result in costly or restrictive actions later in the
system's life.
DOD Has Not Adequately Monitored JIEDDO's Internal Control System:
DOD has not adequately monitored JIEDDO's internal control system,
relying too heavily on certifications from JEIDDO regarding its
operations, which has not permitted it to identify and act to correct
ongoing internal control weaknesses. DOD Comptroller officials said
that oversight over JIEDDO's internal control system is maintained
through the DOD Managers' Internal Control Program, which DOD uses to
manage the requirements of the Federal Managers' Financial Integrity
Act and the Office of Management and Budget Circular No. A-123.
However, these officials stated that under this program, the
Comptroller's office relies solely on JIEDDO to develop and implement
an effective internal control system that addresses key program
performance risks, monitors effectiveness and compliance, and reports
deficiencies or material weaknesses in its internal control system
through a report called the annual statement of assurance.[Footnote
33] This statement is provided to the OSD Office of the Director of
Administration and Management.[Footnote 34] DOD uses additional
techniques in its general oversight of JIEDDO, such as the Deputy
Secretary of Defense's review of certain high-dollar counter-IED
initiatives. However, JIEDDO's internal control system and annual
assurance statement are the key mechanisms DOD relies upon to
comprehensively and uniformly summarize and monitor internal control
system status within its organizations, including JIEDDO, and more
importantly to report and elevate unremedied deficiencies to higher
levels within and outside of DOD for awareness and action.
DOD's oversight system, however, failed to detect, report, and take
action to address the control weaknesses discussed previously in this
report, which have been present at JIEDDO since its first year of
operation. (Further, JIEDDO did not disclose these control weaknesses
in either of its first two annual statements of assurance,[Footnote
35] or fully detail all of its weaknesses in its third and most recent
statement of assurance completed in July 2009). For example, JIEDDO
excludes initiatives from some of the governance mechanisms of its
review and approval process, which JIEDDO characterized as the most
important part of its process before committing funding to any
initiative. Moreover, JIEDDO did not disclose in its 2009 report the
exclusion of initiatives from these important control processes.
Given that DOD's internal control program did not result in the
identification and reporting of these weaknesses and conditions at
JIEDDO, the DOD Comptroller's department-level control intended to
assure the quality of JIEDDO's annual assurance statement was not
effective. In discussing this finding, DOD Comptroller officials
stated that DOD reacts to findings and weaknesses reported by external
organizations, such as GAO or the DOD IG, rather than proactively and
systematically testing the subordinate organizations itself. However,
without adequate oversight of its programs, DOD has inadequate
assurance that JIEDDO operations are providing reliable data for
evaluating progress towards mission objectives or otherwise adequately
recognizing and disclosing existing weaknesses needing corrective
action.
Conclusions:
As IEDs continue to pose a significant threat to U.S. forces in Iraq
and Afghanistan, defeating the threat continues to be a high defense
priority, which will likely require a continued significant investment
in resources provided through JIEDDO. Collectively, this review's
findings along with the findings of prior GAO reports underscore that
JIEDDO has not had a systematic process in place to evaluate its
results, ensure adherence to its acquisition process, and adequately
develop and maintain an adequate internal control system. Although
JIEDDO has taken some steps to improve its management and oversight in
support of its mission to defeat IEDs, it is too early to know the
results of these changes. For example, during this review, we learned
that one JIEDDO office, the Acquisition Oversight Division, previously
established in May 2008, was planned for elimination, therefore
creating uncertainty regarding whether JIEDDO will maintain a process
for identifying and reporting weaknesses with counter-IED initiatives.
A key issue involves the need for sustained high-level management
commitment and leadership to ensure needed changes have been
implemented fully and correctly. Without this assurance, the
possibility of continued exclusion of initiatives from JCAAMP
requirements, coupled with a lack of adherence with all steps of the
process required by applicable guidance, may significantly limit the
transparency and accountability of JIEDDO's actions within JIEDDO, as
well as to the Deputy Secretary of Defense, the services, and other
DOD components.
Furthermore, the magnitude of resources required, coupled with the
scale and span of JIEDDO's mission to focus all DOD counter-IED
efforts, underscores the importance to achieve efficient use of
funding made available to JIEDDO. Because of the continued absence of
adequate internal controls, JIEDDO cannot ensure that its financial
resources are being adequately managed or that decision makers get the
most transparent information to make decisions if JIEDDO does not (1)
develop a means for reliably measuring the effectiveness of its
efforts and investments on combating IEDs; (2) fully adhere to
processes that JIEDDO has designed to identify, assess, and acquire
its counter-IED initiative investments; and (3) address material
weaknesses in its internal control system. Furthermore, these
improvements are needed to be able to assure OSD that the program is
achieving its objectives, particularly in light of the fact that OSD
has taken insufficient action to monitor and work closely with JIEDDO
to improve JIEDDO's internal controls and the quality of its financial
and personnel data necessary to assure Congress and the public that
JIEDDO is effectively focusing all of its resources to address the
threat of IEDs to U.S. forces.
Recommendations for Executive Action:
We are recommending that the Secretary of Defense through the Deputy
Secretary of Defense direct the Director of JIEDDO to take the
following seven actions:
To improve its processes for assessing effectiveness of counter-IED
initiatives:
* Include in the design for each counter-IED initiative a plan that
includes appropriate outcome-oriented metrics and improved data
collection and evaluation plans incorporating use of theater-level
data as well as data capturing unexpected outcomes to gauge the
effectiveness of initiatives, individually and collectively.
* Ensure implementation of JIEDDO's plan to expand, across the
organization, its process for documenting counter-IED initiative
management actions and decisions.
To improve adherence to JCAAMP:
* Revise the JCAAMP instruction to more clearly define which
initiatives are subject to JCAAMP. The revised instruction should:
- define what constitutes a counter-IED initiative and what is
considered overhead, and:
- define and document JIEDDO's process for determining, identifying,
and separately tracking other JIEDDO programs and activities that
JIEDDO considers overhead and excludes from its JCAAMP process.
* Ensure all steps of JCAAMP are followed and fully documented, as
required.
To develop an effective overall internal control system:
* Ensure changes JIEDDO makes to its system of internal controls
include steps to follow through on corrective actions and
recommendations.
* Take necessary measures to deploy sufficient staff with the needed
skill and experience to assess, identify, address, and report to DOD
on efforts taken to address its shortcomings.
* Create positions or otherwise identify ways to access acquisition
expertise to minimize risk in acquiring equipment or systems.
To address JIEDDO's continued challenges in providing transparency and
reasonable assurance concerning the effectiveness of its internal
control system, we also are recommending that the Secretary of Defense
through the Deputy Secretary of Defense take the following two actions:
* Designate an organization in DOD, such as the DOD Comptroller, to
monitor JIEDDO's progress in implementing its changes to address
material weaknesses in its internal control system.
* Develop and implement additional internal controls at the OSD level
needed to ensure that JIEDDO is providing reliable data for evaluating
its progress towards mission objectives or otherwise adequately
recognizing and disclosing in management control reports any other
existing control weaknesses needing corrective action.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, DOD fully concurred
with all nine of our recommendations and delineated several actions
DOD and JIEDDO are implementing or plan to implement to address our
report findings. We believe that if fully implemented DOD's actions
would address our recommendations. The department's written comments
are reprinted in appendix II.
Regarding our two recommendations related to improving processes for
assessing effectiveness of counter-IED initiatives, DOD identified
several actions it plans or has begun to implement. For example,
JIEDDO stated that it has created a new planning board to verify that
initiative assessment methodology development is concurrent with
initiative development. JIEDDO also said it is implementing a new
assessment methodology for all initiatives designed to provide a
consistent evaluative framework to assess their level of readiness and
risk when making specific decisions to continue, transition, or
terminate initiatives. Additionally, DOD stated that additional
controls have now been implemented to improve the documentation of all
initiative management actions and decisions, such as publishing formal
minutes for JCAAMP approval bodies. Lastly, JIEDDO expressed its
expectation that its continued efforts to strengthen and validate
control effectiveness will help to ensure that initiative management
actions and decisions are formally documented, and that documentation
is retained in a central location. We agree that these actions, if
fully implemented, would satisfy our recommendations and improve the
management of counter-IED initiatives by providing more insight into
the effectiveness and historic expectations of each initiative.
Regarding our two recommendations related to JCAAMP, DOD identified
actions aimed at improving adherence to JCAAMP. Specifically, the
department stated that JIEDDO will revise the JCAAMP to provide better
definition of how JCAAMP applies to C-IED initiatives, developmental
efforts, and staff and infrastructure support for initiatives. DOD
also stated that JIEDDO will develop procedures to define and track
programs that are funded outside of the JCAAMP and will refine its
process of accounting for staff and infrastructure for core
requirements and programs that support these requirements. The
department also stated that JIEDDO conducted a detailed review of
JCAAMP and concluded that the process is sound but that the root cause
of our finding stemmed from inadequate documentation of JCAAMP
actions. Consequently, DOD stated that JIEDDO plans to implement
processes to track all JCAAMP actions to evidence that controls were
properly executed and that justifications for any exceptions are
appropriately documented. We agree that implementation of these
actions are appropriate and should satisfy our findings.
Regarding our three recommendations related to developing an effective
overall internal control system, DOD concurred and offered several
actions to addressing the findings. DOD stated that JIEDDO is
implementing its manager's internal control program in accordance with
DOD Instruction 5010.40 including JIEDDO's (1) engaging an independent
audit and consulting firm in fiscal year 2010 to document high-risk
processes, identify corrective actions, and implement process
improvements, and (2) requiring its Internal Review office to monitor
the implementation of corrective actions and report progress to JIEDDO
leadership and all relevant oversight bodies as required. To improve
sufficiency of JIEDDO's staff, DOD approved additional manpower
increases at JIEDDO that will increase the ratio of government service
employees to contractors and expand the skill sets required of its
government service employees to include the needed skills and
experience to address our findings including providing effective
government oversight of JIEDDO programs, such as recruiting
acquisition professionals against new authorizations approved in
fiscal year 2010. We agree that these actions, if fully implemented,
would satisfy our recommendations for improving JIEDDO's internal
control system.
Regarding our two recommendations focused on providing transparency
and reasonable assurance concerning the effectiveness of its internal
control system, DOD stated that it has actions underway to address our
findings. Specifically, DOD said the Office of the Under Secretary of
Defense, Comptroller is assigning its Financial Improvement and Audit
Readiness Directorate the responsibility to monitor and report upon
JIEDDO's progress in the development and implementation of internal
controls. Additionally, according to DOD, the Under Secretary of
Defense, Comptroller, Financial Improvement and Audit Readiness
Directorate is taking action to emphasize the requirement and
proactive implementation of the department's Managers' Internal
Control Program including (1) in June 2010 the DOD Comptroller,
Managers' Internal Control Manager, is meeting with senior managers
from the Department of Defense, Inspector General to make arrangements
to develop regular communications between the two to institutionalize
the sharing of audit-related insights and potential recommendations
that focus upon operational, administrative, and program controls, and
(2) in fiscal year 2011, the Under Secretary of Defense, Comptroller,
Financial Improvement and Audit Readiness Branch will begin to conduct
onsite validation meetings with each of the DOD Components responsible
for submission of a Statement of Assurance to the Office of the
Secretary of Defense and rate each component's internal control
program with a score providing improved oversight through the
validation of the DOD Component's adherence with DOD Instruction
5010.40. We agree that these actions will not only address our
findings, but also provide positive evidence that DOD is demonstrating
the principles underlying the monitoring standards for an internal
control system throughout the department.
We are sending copies of this report to interested congressional
committees and the Secretary of Defense. This report will be available
at no charge on GAO's Web site [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-8365 or by e-mail at SolisW@GAO.GOV. Contact
information for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff who
have made major contributions to this report are listed in appendix
III.
Signed by:
William M. Solis, Director:
Defense Capabilities and Management:
List of Committees:
The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate:
The Honorable Daniel Inouye:
Chairman:
The Honorable Thad Cochran:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
United States Senate:
The Honorable Ike Skelton:
Chairman:
The Honorable Howard McKeon:
Ranking Member:
Committee on Armed Services:
House of Representatives:
The Honorable Norman D. Dicks:
Chairman:
The Honorable C.W. Bill Young:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To assess the Joint Improvised Explosive Device Defeat Organization's
(JIEDDO) efforts to measure the effectiveness of its efforts and
investments, we requested, reviewed, and discussed with JIEDDO
officials current and anticipated efforts to measure and evaluate its
operations and activities. We reviewed these efforts to determine the
progress, breadth, and depth of JIEDDO's measurement development and
their applicability towards JIEDDO's ability to successfully evaluate
its operations initiatives. We reviewed assessments JIEDDO cited as
examples of measuring its activities and measures and determined that
collectively, JIEDDO's measurement development efforts were not
followed through to completion and had not evolved beyond the planning
stages. We reviewed the instances where JIEDDO attempted to conduct
individual measurement exercises for counter-IED initiatives,
including those that JIEDDO characterized as completed--successful--
and those that were not completed--unsuccessful. In discussion with
JIEDDO officials and in review of the underlying information, we
developed examples of limitations experienced during the individual
efforts. We then categorized and summarized the limitations,
challenges, and underlying root causes, for the exercises we reviewed,
for JIEDDO's limited progress in its measurement efforts, and for
potential actions to improve chances for success.
To assess JIEDDO's adherence to its review and approval process, we
reviewed, analyzed, and discussed JIEDDO guidance with JIEDDO
officials to identify key steps in its process, and then collected
corroborating data from 56 case studies of JIEDDO's most costly
counter-IED initiatives for fiscal years 2008 and 2009 to determine
whether JIEDDO's stated process was followed by JIEDDO managers and
personnel. These studies included over $4.67 billion in fiscal year
2009 projects and initiatives funded with fiscal years 2008 and 2009
appropriations. We also identified required approval controls over use
of funds, reviewed selected transactions for compliance with these
controls, and assessed whether the data recorded in the accounting and
managerial systems accurately reflected JIEDDO's activities. We drew
high-dollar initiatives to more efficiently assess the largest portion
of JIEDDO's funds. We included representative initiatives from
JIEDDO's three mission-related lines of operations. [Footnote 36] We
also reviewed large-dollar initiatives approved by the Deputy
Secretary of Defense for fiscal years 2008 and 2009. Because we
identified weaknesses in the completeness and accuracy of JIEDDO's
documentation and controls, we did not review the full range of
initiatives we had originally planned because it would have added no
further value for purposes of addressing the objectives of this
review. Our analysis drew from a universe of the 497 initiatives
listed in JIEDDO's initiative management system--CCARs--as of March
30, 2009, against which JIEDDO had earmarked, committed, obligated,
and/or expended its fiscal years 2008 and 2009 appropriations. We took
steps to ensure that the universe data JIEDDO provided for funded-to-
date initiates were complete by comparing the sum of the total dollar
amounts to the total appropriations/funds made available to JIEDDO for
fiscal years 2008 and 2009. Using embedded JIEDDO codes, we separated
the data into subsets based on categories that JIEDDO uses to
characterize and manage its operations: (1) attack the network that
enables the use of IEDs, (2) defeat the IED itself once emplaced, and
(3) train the military forces in counter-IED techniques. For each
category, we ranked all of the associated initiatives to identify the
20 that carried the highest requirement for fiscal year 2008 and
fiscal year 2009 combined for a total of 60 initiatives from the
JIEDDO's lines of operations. We excluded 4 initiatives after we
learned that the Department of Defense (DOD) Inspector General was
closely scrutinizing them for mandated audits already underway,
reducing the number of case studies conducted and completed by GAO to
56 in total, which reflected a total of $4.67 billion in combined
fiscal years 2008 and 2009 funding that JIEDDO had approved at the
time we collected our data. For each initiative, we collected the
individual documentation packages JIEDDO is supposed to file and
maintain as proof of JIEDDO actions and to provide an audit trail for
JIEDDO personnel and others to determine the history and progress of
an initiative. We then compared the progress of each initiative as
reflected in JIEDDO's accounting system with details in the individual
documentation packages, to determine whether historic documentation
matched the financial record and whether various decision points were
documented and approved as required by the JIEDDO directive,
instruction, and standard operating procedures. In cases where JEDDO's
documentation appeared to be incomplete or incongruent, we discussed
the gaps on a case-by-case basis with initiative program managers and
JIEDDO managers from accounting and finance, acquisition oversight,
internal review, and the office of the chief of staff. Through the
progress of the audit, we shared tentative observations and concerns
with JIEDDO management officials prior to reaching conclusions on each
of the initiatives. Once we had concluded data gathering and analysis
on individual initiatives, we reviewed and arrayed the data to
identify patterns of adherence issues related to JIEDDO's directive,
instruction, and standard operating procedures, as well as to federal
internal control standards. We presented and discussed our findings to
JIEDDO management, made corrections where warranted to individual
initiatives, and have summarized these as findings in the body of this
report. We visited and met with officials from JIEDDO's Joint Center
of Excellence (JIEDDO's organization managing counter-IED
initiatives), the National Training Center (site for some of JIEDDO's
counter-IED training initiatives), JIEDDO's Technology and
Requirements Integration Division, JIEDDO's Acquisition Oversight
Division, JIEDDO's command group, JIEDDO's Operations Research Systems
Analysis Division, and JIEDDO's and Resource Management Division
(JIEDDO's organization performing budget, accounting, and finance
functions) to gather information corroborating and explaining the
financial activity and documentation related to JIEDDO initiatives we
tested.
To assess JIEDDO's actions to address overall internal control system
weaknesses previously reported by GAO, we interviewed and discussed
with JIEDDO officials their efforts to improve JIEDDO's internal
control system in response to prior related GAO findings. We collected
and reviewed internal and external guidance and documentation of
JIEDDO's internal control system. We reviewed and compared JIEDDO's
annual statements of assurance regarding JIEDDO's internal controls
system. We then analyzed the information collected and discussed the
significance of conditions observed with JIEDDO officials.
We also examined documentation including DOD Directive 2000.19E, which
established JIEDDO, other documentation and briefings relating to
JIEDDO's evolution, and JIEDDO Instruction 5000.01, which established
JIEDDO's rapid acquisition process, as well as other documents and
briefings from JIEDDO, the services, and other DOD entities. We
discussed JIEDDO's management of its internal processes, its strategic
planning, initiative development, and internal controls. We assessed
the reliability of JIEDDO's financial data we reviewed by (1)
corroborating the data with supporting information and documentation
from physical file records at JIEDDO headquarters and from initiative
program offices, (2) reviewing existing information about the data and
the system that produced them, and (3) interviewing agency officials
knowledgeable about the data. Based on this work, we determined that
the data were sufficiently reliable for the purposes of the review of
initiatives.
We conducted this performance audit from May 2008 to May 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.
[End of section]
Appendix II: Comments from the Department of Defense:
Joint IED Defeat Organization:
5000 Army Pentagon:
Washington, DC 20310-5000:
June 21, 2010:
Mr. William Solis:
Director, Defense Capabilities and Management:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Solis:
This is the Department of Defense (DoD) response to the GAO draft
report, GAO-10-660, 'Warfighter Support: Actions Needed to Improve
Joint Improvised Explosive Device Defeat Organization's System of
Internal Control' dated May 12. 2010 (GAO Code 351230).
The Joint Improvised Explosive Device Defeat Organization (JIEDDO)
executes its mission in support of COCOM requirements by rapidly
responding to urgent warfighter needs. The single most relevant factor
in JIEDDO's decision making and coordination efforts is to ensure
these capabilities are available to a COCOM engaged in combat during a
decisive time of need A "good enough" solution delivered rapidly in a
dynamic war environment is more valuable than an ideal solution
delivered much later. JIEDDO provides C-IED capabilities and both
material and non-material solutions in a rapid manner based upon
requirement urgency and solution maturity. JIEDDO's organizational
value is based on this ability and flexibility to respond to COCOM
needs as quickly as possible while accepting a higher level of program
risk.
JIEDDO recognizes that in accepting a higher risk profile in executing
the mission that effective stewardship of its resources is a vital
concern. This report highlights areas for improvement in defining
acceptable levels of risk while maintaining effective oversight
and internal control of our processes. To this end JIEDDO is
conducting a complete review of functions and processes and
implementing a manager's internal control program that will provide
assurance of effective use of JIEDDO resources. Ourendstate is to
establish a system of internal controls that is assessable,
accountable, and transparent for JIEDDO's decision making processes
and program management in support of the warfighter.
The enclosed attachment contains a detailed response to each
recommendation. Comments on technical or factual corrections to the
report were provided in a separate document to the GAO audit team. The
point of contact for this response is Mr. William Rigby, JIEDDO
internal Review, william.rigby@jieddo.dod.mil, 703-602-4807.
Sincerely,
Signed by:
Michael L. Oates:
Lieutenant General, U.S. Army:
Director:
Enclosure: As stated:
[End of letter]
GAO Draft Report ” Dated May 12, 2010:
GAO Code 351230/GAO-10-660:
"Warfighter Support: Actions Needed to Improve Joint Improvised
Explosive Device Defeat Organization's System of Internal Control"
Department Of Defense Comments To The Recommendations:
Recommendation 1: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense direct the Director of the
Joint Improvised Explosive Device Defeat Organization (JIEDDO) to
include in the design for each counter-improvised explosive device
(IED) initiative a plan that includes appropriate outcome oriented
metrics, improved data collection and evaluation plans incorporating
the use of theater level data as well as data capturing unexpected
outcomes to gauge the effectiveness of initiatives, individually and
collectively.
DOD RESPONSE: Concur. During the conduct of this audit JIEDDO has
taken several steps to improve initiative assessments and continues to
refine our processes and reviews to ensure assessments are conducted
for each initiative. JIEDDO implemented a planning board for
initiatives that incorporates developing an assessment methodology
concurrent with initiative development. JIEDDO is implementing an
assessment methodology for all initiatives to provide a consistent
evaluative framework to assess their level of readiness and risk to
inform decision making specific to each Transition Point. This
framework will provide transparency for incremental changes over time
to furnish senior leaders with comprehensive information to inform
decision making.
Recommendation 2: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense direct the Director of the
Joint Improvised Explosive Device Defeat Organization (JIEDDO) to
ensure implementation of JIEDDO's plan to expand, across the
organization, its process for documenting counter-improvised explosive
device (IED) initiative management actions and decisions.
DOD Response: Concur. JIEDDO has implemented additional controls to
improve the documentation of all initiative management actions and
decisions, such as publishing formal minutes for Joint Improvised
Explosive Device Defeat Capability and Acquisition Management Process
(JCAAMP) approval bodies. In accordance with the finding, JIEDDO will
continue to strengthen and validate control effectiveness, to ensure
that all initiative management actions and decisions are formally
documented, and that documentation is retained in a central location.
Recommendation 3: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense direct the Director of the
Joint Improvised Explosive Device Defeat Organization (JIEDDO) to
revise the Joint Improvised Explosive Device Defeat Capability and
Acquisition Management Process (JCAAMP) instruction to more clearly
define which initiatives are subject to JCAAMP. The revised
instruction should:
* Define what constitutes a counter-improvised explosive device (IED)
initiative and what is considered overhead.
* Define and document JIEDDO's process for determining, identifying,
and separately tracking other JIEDDO programs and activities that
JIEDDO considers overhead and excludes from its JCAAMP process.
DOD Response: Concur. JIEDDO will revise the JCAAMP to provide better
definition of how JCAAMP applies to Counter-Improvised Explosive
Device (CIED) initiatives, developmental efforts and staff and
infrastructure support for initiatives. JIEDDO will develop procedures
to define and track programs that are funded outside of the JCAAMP.
JIEDDO will refine its process of accounting for staff and
infrastructure for core requirements and programs that support these
requirements.
Recommendation 4: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense direct the Director of the
Joint Improvised Explosive Device Defeat Organization (JIEDDO) to
ensure all steps of the Joint Improvised Explosive Device Defeat
Capability and Acquisition Management Process (JCAAMP) are followed
and fully documented, as required.
DOD Response: Concur. JIEDDO conducted a detailed review to determine
the root causes of the GAO's findings, and identify opportunities to
strengthen controls to mitigate issues cited in this report. This
review determined that the JCAAMP process is sound but that the root
cause stemmed from inadequate documentation of JCAAMP actions. In
response to the GAO's concerns, JIEDDO will implement processes to
track all JCAAMP actions to evidence that controls were properly
executed and that justifications for any exceptions are appropriately
documented.
Recommendation 5: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense direct the Director of the
Joint Improvised Explosive Device Defeat Organization (JIEDDO) to
ensure changes JIEDDO makes to its system of internal controls include
steps to follow-through on corrective actions and recommendations.
DOD Response: Concur. JIEDDO is implementing a manager's internal
control program in accordance with DoD Instruction 5010.40. JIEDDO
retained an independent audit and consulting firm in FY10 to document
high risk processes, identify corrective
actions, and implement process improvements. The JIEDDO Internal
Review office will monitor the implementation of corrective actions
and report progress to JIEDDO leadership and all relevant oversight
bodies as required.
Recommendation 6: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense direct the Director of the
Joint Improvised Explosive Device Defeat Organization (JIEDDO) to take
necessary measures to deploy sufficient staff with the needed skill
and experience to assess, identify, address, and report to DoD on
efforts taken to address its shortcomings.
DOD Response: Concur. In February and April 2010 the Department of the
Army as the Executive Agent for JIEDDO manpower authorizations
approved increases in JIEDDO authorizations that allow JIEDDO to in
source government professional positions. JIEDDO is developing
appropriate position descriptions and recruiting government service
(GS) hires with the needed skills and experience to address the issues
identified by the GAO and to provide effective government oversight of
JIEDDO programs.
Recommendation 7: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense direct the Director of the
Joint Improvised Explosive Device Defeat Organization (JIEDDO) to
create positions or otherwise identify ways to access acquisition
expertise to minimize risk in acquiring equipment or systems.
DOD Response: Concur. JIEDDO recognizes the need to augment and
supplement our existing acquisition workforce with additional staff
trained and qualified to conduct and oversee acquisition in the DOD.
JIEDDO is recruiting acquisition professionals against new
authorizations approved in FY10. JIEDDO is converting several existing
positions to align with the DoD Acquisition Corps. JIEDDO is exploring
opportunities to have acquisition personnel from other agencies
support JIEDDO on a rotational basis to provide short time support and
additional training and mentorship to the existing JIEDDO acquisition
workforce. JIEDDO is partnering with the Defense Acquisition
University (DAU) to provide training to the JIEDDO workforce. The
recent addition of a second highly experience government contracts
attorney to the Office of General Counsel will further strengthen
JIEDDO's acquisition expertise and help keep risk at acceptable levels.
Recommendation 8: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense designate an organization in
DoD, such as the DoD Comptroller to monitor the Joint Improvised
Explosive Device Defeat Organization's (JIEDDO) progress in
implementing its changes to address material weaknesses in its
internal control system.
DOD Response: Concur. The Office of the Under Secretary of Defense,
Comptroller will assign the Financial Improvement and Audit Readiness
Directorate the responsibility to monitor and report upon the Joint
Improvised Explosive Device Defeat Organization's progress in the
development and implementation of internal controls.
Recommendation 9: The GAO recommends that the Secretary of Defense
through the Deputy Secretary of Defense develop and implement
additional internal controls at the OSD level needed to ensure that
the Joint Improvised Explosive Device Defeat Organization (JIEDDO) is
providing reliable data for evaluating its progress towards mission
objectives or otherwise adequately recognizing and disclosing in
management control reports any other existing control weaknesses
needing corrective action.
DOD Response: Concur. This fiscal year, the Under Secretary of
Defense, Comptroller, Financial Improvement and Audit Readiness
Directorate has met individually with the majority of the Department
of Defense Components that are required to submit annually a Statement
of Assurance to the Office of the Secretary of Defense. The purpose of
these meetings to: 1) emphasize the requirement and proactive
implementation of the Department's Managers' Internal Control Program
through adherence with the DoD Instruction 5010.40 to include ongoing
support and active participation by Senior Management (e.g., "tone-at-
the”top"), a risk-based approach and the use of self-reporting so that
material internal control weaknesses can be identified and remediated
prior to their potential negative impact upon the organization's
mission.
During June 2010, the DoD Comptroller, Managers' Internal Control
Manager met with Senior Managers from the Department of Defense,
Inspector General. The purpose of the meeting was review of the DoD
Comptroller's actions initiated this fiscal year to ensure that each
DoD Component understands and pro-actively addresses the requirements
of DoD Instruction 5010.40. It was agreed that the two organizations
would initiate regular communications for the purpose to share audit
related insights and potential recommendations that focus upon
operational, administrative and program controls.
Beginning in fiscal year 2011, the Under Secretary of Defense,
Comptroller, Financial Improvement and Audit Readiness Branch plans to
conduct onsite validation meetings with each of the DoD Components
responsible for submission of a Statement of Assurance to the Office
of the Secretary of Defense. The purpose of these onsite visits will
be to provide oversight through the validation of the DoD Component's
adherence with DoD Instruction 5010.40. Scoring criteria has been
distributed to each of the DoD Components and is also posted on the
DoD Managers' Internal Control Program web site. Each DoD Component's
Managers' Internal Control Program will be evaluated and the Component
will receive a score that represents their adherence with DoD
Instruction 5010.40.
[End of section]
Appendix III: GAO Contact and Acknowledgments:
GAO Contact:
For further information please contact William Solis, (202) 512-8365
or solisw@gao.gov.
Acknowledgments:
In addition to the contact named above, Cary B. Russell (Assistant
Director), Grace Coleman, Ron La Due Lake, Lonnie McAllister, Tristan
T. To, Jason Pogacnik, Jim Lloyd, and Yong Song, and John Strong made
key contributions to this report.
[End of section]
Footnotes:
[1] Department of Defense Directive 2000.19E, Joint Improvised
Explosive Device Defeat Organization (JIEDDO) (Feb. 14, 2006).
[2] H.R. Rep. No. 110-477 (conference report accompanying the National
Defense Authorization Act for Fiscal Year 2008).
[3] Joint IED Defeat Organization Instruction 5000.01, Joint
Improvised Explosive Device Defeat (JIEDD) Capability Approval and
Acquisition Management Process (JCAAMP) (Nov. 9, 2007).
[4] External guidance includes federal standards as well as DOD
regulations, directives, and guides governing internal control
requirements and their application within DOD and JIEDDO.
[5] Staff and infrastructure includes Non-Counter-IED Requirements
which JIEDDO defines as typically CONUS-only costs, and JIEDDO
Operations and Plans for typically Iraq and Afghanistan costs. JIEDDOI
5000.01, para. E5.4.2. (Nov. 9, 2007).
[6] GAO, Defense Management: More Transparency Needed over the
Financial and Human Capital Operations of the Joint Improvised
Explosive Device Defeat Organization, [hyperlink,
http://www.gao.gov/products/GAO-08-342] (Washington, D.C.: Mar. 6,
2008).
[7] GAO, Warfighter Support: Challenges Confronting DOD's Ability to
Coordinate and Oversee Its Counter-Improvised Explosive Devices
Efforts, [hyperlink, http://www.gao.gov/products/GAO-10-186T]
(Washington, D.C.: Oct. 29, 2009) and GAO, Warfighter Support: Actions
Needed to Improve Visibility and Coordination of DOD's Counter
Improvised Explosive Device Efforts, [hyperlink,
http://www.gao.gov/products/GAO-10-95] (Washington, D.C.: October
2009).
[8] JIEDDO Instruction 5000.01 (Nov. 9, 2007).
[9] The JIEDDO instruction revision occurred after the completion of
our fieldwork and changes therein have not been fully implemented due
to change of leadership and pending reorganization of JIEDDO.
[10] OMB Circular No. A-11, Sec 200.3, Preparation and Submission of
Strategic Plans, Annual Performance Plans, and Annual Program
Performance Reports (2009).
[11] Government Performance and Results Act, (codified at 31 U.S.C. §§
1115-1119) (2010); Pub. L. No. 103-62 (1993); [hyperlink,
http://www.gao.gov/products/GAO/AIMD-00-21.3.1], Standards for
Internal Control in the Federal Government (November 1999).
[12] GAO, Defense Management: A Strategic Plan is Needed to Guide the
Joint Improvised Explosive Device Defeat Organization's Efforts to
Effectively Accomplish its Mission, [hyperlink,
http://www.gao.gov/products/GAO-07-377C] (Washington D.C.: Mar. 28,
2007).
[13] JIEDDO, JIEDDO's Fiscal Year 2009-2010 Strategy (February 2009).
[14] Government Performance and Results Act, Pub. L. No. 103-62 (1993).
[15] DOD Directive 2000.19E (Feb. 14, 2006). JIEDDOI 5000.01 (Nov. 9,
2007).
[16] DOD Directive 2000.19E (Feb. 14, 2006).
[17] JIEDDOI 5000.01, ¶ E5.4.2.
[18] DOD Directive 2000.19E, para. 3.1. (Feb. 14, 2006). "Materiel
solution" is defined in CJCSI 3170.01G as correction of a deficiency,
a solution to a capability gap, or incorporation of new technology
that involves development or acquisition of a new item or piece of
equipment and "non-material solution" is defined as a solution to a
capability gap that involves changes in doctrine, organization,
training, materiel, leadership and education, personnel, facilities,
or policy, the materiel portion of which is restricted to commercial
or nondevelopmental items, which may be purchased commercially, or by
purchasing more systems from an existing materiel program.
[19] DOD Directive 2000.19E (Feb. 14, 2006).
[20] JIEDDOI 5000.01 (Nov. 9, 2007).
[21] JIEDDO organizational elements each establish standard operating
procedures for conducting the business of that given organizational
element within applicable JIEDDO and DOD guidance. For example,
Resource Management has established and documented its required
standard operating procedures in a 276-page document.
[22] DOD Directive 2000.19E (Feb. 14, 2006), and JIEDDOI 5000.01 (Nov.
9, 2007).
[23] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1],
Standards for Internal Control in the Federal Government (November
1999).
[24] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(November 1999).
[25] GAO, Defense Management: A Strategic Plan is Needed to Guide the
Joint Improvised Explosive Device Defeat Organization's Efforts to
Effectively Accomplish its Mission, [hyperlink,
http://www.gao.gov/products/GAO-07-377C] (Washington D.C.: Mar. 28,
2007), [hyperlink, http://www.gao.gov/products/GAO-08-342], and
[hyperlink, http://www.gao.gov/products/GAO-10-95].
[26] JIEDDO Memorandum for Director of Administration and Management
(July 9, 2009). Annual Statement Required under the Federal Managers'
Financial Integrity Act of 1982 (FMFIA).
[27] JIEDDO's Acquisition Oversight Division, which is responsible for
oversight of JIEDDO's counter I-ED inititiatives acquisition
management, is separate from the internal review office, which is
responsible for the JIEDDO-wide internal control program.
[28] After the completion of our audit work, we provided JIEDDO
management with a statement of facts that included the forgoing
actions documented during our work at JIEDDO. In discussing the audit
finding, JIEDDO management informed GAO that the new JIEDDO Director
has since decided to retain JIEDDO's Acquisition Oversight Division as
an organizational element at JIEDDO. However, during the same
discussion, JIEDDO officials also acknowledged that the oversight
division will not be maintained in its present form and that the size,
functions, and responsibilities of the oversight division have yet to
be determined.
[29] JIEDDO Memorandum for Director of Administration and Management
(July 9, 2009). Annual Statement Required under the Federal Managers'
Financial Integrity Act of 1982 (FMFIA).
[30] Inherently governmental functions are those that are intimately
related to the public interest as to mandate performance only by
federal employees
[31] These included, for example, intelligence analysis specialists
with weapons and cultural expertise, experienced scientists--including
chemists and physicists--with military explosives expertise, and
program/system integrators with expertise in the differences between
JIEDDO's system development process and standard DOD system
development processes.
[32] The JIEDDO director requested an assistance visit from the
Defense Acquisition University and the Defense Contract Management
Agency, which each provided two experienced persons to the team for a
1-week review conducted in February 2010. The director made the
request as part of his effort to develop an understanding of JIEDDO's
processes and the request included assessing JIEDDO's rapid
acquisition process.
[33] DOD regulation defines material weaknesses as reportable
conditions which, in management's judgment, are significant enough to
report to the next higher level.
[34] "The Director of Administration and Management consolidates the
JIEDDO statement into the OSD statement which is reported to the
Secretary of Defense. The OSD Comptroller prepares the DOD statement
for the Secretary of Defense, using the Component Heads annual
assurance statements as the basis for the Department's level of
assurance."
[35] Statement of assurance first issued in 2007, and second statement
of assurance followed in 2008.
[36] These include JIEDDO's operations to (1) attack the network that
enables the use of IEDs, (2) defeat the IED itself once emplaced, and
(3) train the military forces in counter-IED techniques. We excluded
JIEDDO's fourth line of operations because it includes staff and
infrastructure activities not directly related to the other three
lines of operations, which are directly involved in the development of
JIEDDO's counter-IED initiatives.
[End of section]
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