DOD Cost Overruns
Trends in Nunn-McCurdy Breaches and Tools to Manage Weapon Systems Acquisition Costs
Gao ID: GAO-11-499T March 29, 2011
This testimony discusses tools available to minimize Department of Defense (DOD) cost overruns and our recent work on the Nunn-McCurdy process. For nearly 30 years, the statutory provision known as Nunn-McCurdy has been a tool for Congress to use to hold DOD accountable for cost growth on major defense programs. The purpose of the statute was to provide Congress greater visibility into major defense programs' cost growth and to encourage DOD to manage and control cost growth. A Nunn-McCurdy breach occurs when a program's unit cost exceeds certain thresholds. When that happens, DOD must notify Congress of the breach. There are two types of Nunn-McCurdy breaches: significant breaches and critical breaches. A breach of the significant cost growth threshold occurs when the program acquisition unit cost or the procurement unit cost increases by at least 15 percent over the current baseline estimate or at least 30 percent over the original baseline estimate. A breach of the critical cost growth threshold occurs when the program acquisition unit cost or the procurement unit cost increases by at least 25 percent over the current baseline estimate or at least 50 percent over the original baseline estimate. The Nunn-McCurdy process has been amended a number of times over the years. For example, in the Weapon Systems Acquisition Reform Act of 2009, Congress enacted a new provision requiring the Secretary of Defense to terminate a program that experiences a breach of the critical cost growth threshold, unless the Secretary of Defense submits a written certification to Congress. This statement focuses on (1) trends in Nunn-McCurdy breaches, (2) factors that may be responsible for these trends, (3) changes DOD is making or proposing to make to the Nunn-McCurdy process, and (4) other tools DOD can use to minimize cost overruns. This testimony includes information from our March 2011 report on Nunn-McCurdy breaches, which is being released today. The report contains information on the scope of our analysis and the methodology used. In addition, we drew on our published body of work on weapon system acquisitions and best practices to identify tools that can be used to minimize cost overruns.
Since 1997, there have been 74 Nunn-McCurdy breaches involving 47 major defense acquisition programs. There were a larger number of breaches in 2001, 2005, 2006, and 2009, which coincides with new statutory requirements or changes presidential administration. As a result of Congress requiring DOD to measure cost growth against the original baseline estimate, the number of breaches reported increased in 2005 and 2006. The number of breaches was also high in 2001 and 2009-- the first years of new presidential administrations. During both transitions, no annual comprehensive Selected Acquisition Reports (SAR) were submitted, which, along with other factors, may have affected when breaches were reported. Nunn-McCurdy breaches are often the result of multiple, interrelated factors. Our analysis of DOD data and SARs showed that the primary reasons cited for the unit cost growth that led to Nunn-McCurdy breaches were engineering and design issues, schedule issues, and quantity changes. For example, we reported in 2003 that the Space Based Infrared System High program began with immature technologies and was based on faulty and overly optimistic assumptions about software reuse and productivity levels, the benefits of commercial practices, management stability, and the level of understanding of requirements. The program has breached four times. A large number of programs that breached also cited revised estimates, due in part to changing assumptions; requirements changes; and economic changes, such as labor and overhead rates, as factors that contributed to the breaches. DOD has instituted a process to provide earlier warning of potential Nunn-McCurdy breaches and plans to propose changes to the Nunn-McCurdy process to reduce several statutory requirements for breaches caused by quantity changes. Specifically, the Joint Staff has implemented a process to provide an earlier evaluation of the factors that are contributing to cost growth so that programs can take mitigating actions before experiencing a significant Nunn McCurdy breach. This new process has merit, as our analysis shows that nearly 40 percent of Nunn-McCurdy breaches occurred after a production decision had been made--when a program has fewer options for restructuring. DOD plans to propose a legislative amendment to reduce several statutory requirements added in 2009 for Nunn-McCurdy breaches when it determines that a breach was caused primarily by quantity changes that were unrelated to poor performance. According to DOD, not all breaches are indicators of poor performance because quantity reductions or capabilities added to a program after it begins can affect unit cost. The Nunn-McCurdy process can be a useful mechanism for holding programs accountable for cost growth and restructuring them in the wake of cost growth; however, its effect is limited because, in general, programs have already experienced significant problems by the time it is triggered. It is not realistic to expect cost growth to be entirely preventable, but it can be significantly reduced. To put programs in a position to minimize the risk of cost growth, DOD must use the tools available to it to establish programs in which there is a match between requirements and resources--including funding-- from the start and execute those programs using knowledge-based acquisition practices. In our previous work, we have identified proven management practices--many of which have been incorporated into DOD policy, but have yet to be fully implemented in practice--that can serve as tools to prevent DOD cost overruns. Greater adherence to practices at key phases of the acquisition process can help reduce weapon system costs, contain pressures for increased funding, and better address critical warfighter needs.
GAO-11-499T, DOD Cost Overruns: Trends in Nunn-McCurdy Breaches and Tools to Manage Weapon Systems Acquisition Costs
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United States Government Accountability Office:
GAO:
Testimony before the Committee on Homeland Security and Governmental
Affairs, Subcommittee on Federal Financial Management, Government
Information, Federal Services and International Security, United
States Senate:
For Release on Delivery:
Expected at 2:30 p.m. EDT:
Tuesday, March 29, 2011:
DOD Cost Overruns:
Trends in Nunn-McCurdy Breaches and Tools to Manage Weapon Systems
Acquisition Costs:
Statement of Michael J. Sullivan, Director:
Acquisition and Sourcing Management:
GAO-11-499T:
Mr. Chairman and Members of the Subcommittee:
I am pleased to be here today to discuss tools available to minimize
Department of Defense (DOD) cost overruns and our recent work on the
Nunn-McCurdy process. For nearly 30 years, the statutory provision
known as Nunn-McCurdy[Footnote 1] has been a tool for Congress to use
to hold DOD accountable for cost growth on major defense programs. The
purpose of the statute was to provide Congress greater visibility into
major defense programs' cost growth and to encourage DOD to manage and
control cost growth. A Nunn-McCurdy breach occurs when a program's
unit cost exceeds certain thresholds. When that happens, DOD must
notify Congress of the breach. There are two types of Nunn-McCurdy
breaches: significant breaches and critical breaches.[Footnote 2] A
breach of the significant cost growth threshold occurs when the
program acquisition unit cost or the procurement unit cost increases
by at least 15 percent over the current baseline estimate or at least
30 percent over the original baseline estimate.[Footnote 3] A breach
of the critical cost growth threshold occurs when the program
acquisition unit cost or the procurement unit cost increases by at
least 25 percent over the current baseline estimate or at least 50
percent over the original baseline estimate. The Nunn-McCurdy process
has been amended a number of times over the years. For example, in the
Weapon Systems Acquisition Reform Act of 2009, Congress enacted a new
provision requiring the Secretary of Defense to terminate a program
that experiences a breach of the critical cost growth threshold,
unless the Secretary of Defense submits a written certification to
Congress.[Footnote 4]
My statement focuses on (1) trends in Nunn-McCurdy breaches, (2)
factors that may be responsible for these trends, (3) changes DOD is
making or proposing to make to the Nunn-McCurdy process, and (4) other
tools DOD can use to minimize cost overruns. My testimony includes
information from our March 2011 report on Nunn-McCurdy breaches, which
is being released today.[Footnote 5] The report contains information
on the scope of our analysis and the methodology used. In addition, we
drew on our published body of work on weapon system acquisitions and
best practices to identify tools that can be used to minimize cost
overruns. The work that supports this statement was performed 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.
Nunn-McCurdy Breaches Increased after Changes in Statute or
Presidential Administration:
Since 1997, there have been 74 Nunn-McCurdy breaches involving 47
major defense acquisition programs.[Footnote 6] (See figure 1.) There
were a larger number of breaches in 2001, 2005, 2006, and 2009, which
coincides with new statutory requirements or changes presidential
administration. As a result of Congress requiring DOD to measure cost
growth against the original baseline estimate, the number of breaches
reported increased in 2005 and 2006. The number of breaches was also
high in 2001 and 2009--the first years of new presidential
administrations. During both transitions, no annual comprehensive
Selected Acquisition Reports (SAR) were submitted, which, along with
other factors, may have affected when breaches were reported.[Footnote
7] For example, according to DOD, during the transition from one
administration to another in 2001, the cost of several programs
breached Nunn-McCurdy thresholds because of a change in management
philosophy, which included fully funding these programs to higher
independent cost estimates.
Figure 1: Critical and Significant Breaches by Calendar Year, 1997-
2009:
[Refer to PDF for image: stacked vertical bar graph]
Submission date: 1997;
Significant: 1;
Critical: 0.
Submission date: 1998;
Significant: 3;
Critical: 0.
Submission date: 1999;
Significant: 1;
Critical: 2.
Submission date: 2000;
Significant: 0;
Critical: 0.
No breaches were reported in 2000.
Submission date: 2001;
Significant: 2;
Critical: 9.
Submission date: 2002;
Significant: 1;
Critical: 2.
Submission date: 2003;
Significant: 0;
Critical: 2.
Submission date: 2004;
Significant: 4;
Critical: 3.
Submission date: 2005;
Significant: 14;
Critical: 3.
Submission date: 2006;
Significant: 2;
Critical: 8.
Submission date: 2007;
Significant: 4;
Critical: 1.
Submission date: 2008;
Significant: 1;
Critical: 3.
Submission date: 2009;
Significant: 2;
Critical: 6.
Source: GAO analysis of DOD data.
Note: This figure uses the terms significant and critical to
categorize reported program cost growth. We note, however, that prior
to 2006, the statute did not use those terms to describe the cost
growth thresholds.
[End of figure]
The Air Force had a higher proportion of total breaches compared to
its proportion of total programs, whereas the Navy had a smaller
proportion of breaches compared to its proportion of programs.
Aircraft, satellite, and helicopter programs have experienced the
largest number of breaches. Of the 47 programs that breached, 18
programs breached more than one time. Only one of the programs with
multiple breaches--the Armed Reconnaissance Helicopter--was not
recertified after a breach of the critical cost growth threshold and
was terminated. The Navy Area Theater Ballistic Missile Defense was
also not recertified and was terminated because of poor performance
and projected future cost and schedule problems. Some programs that
have experienced a critical breach--including the Advanced Seal
Delivery System, Army Tactical Missile System-BAT, Comanche
Reconnaissance Attack Helicopter, Land Warrior, and VH-71 Presidential
Helicopter Replacement--have also been terminated.
Engineering and Design Issues Are Most Cited by DOD as being
Responsible for Nunn-McCurdy Breaches:
Nunn-McCurdy breaches are often the result of multiple, interrelated
factors. Our analysis of DOD data and SARs showed that the primary
reasons cited for the unit cost growth that led to Nunn-McCurdy
breaches were engineering and design issues, schedule issues, and
quantity changes. For example, we reported in 2003 that the Space
Based Infrared System High program began with immature technologies
and was based on faulty and overly optimistic assumptions about
software reuse and productivity levels, the benefits of commercial
practices, management stability, and the level of understanding of
requirements.[Footnote 8] The program has breached four times. A large
number of programs that breached also cited revised estimates, due in
part to changing assumptions; requirements changes; and economic
changes, such as labor and overhead rates, as factors that contributed
to the breaches. (See figure 2.) For example, we previously reported
that initial development cost estimates for the Army's Warfighter
Information Network-Tactical communications system were understated by
at least $1.3 billion, or nearly 160 percent, as of July 2008, in part
because the estimates assumed that commercial-off-the-shelf radio
technology would be available.[Footnote 9] This assumption proved to
be wrong, and the program breached in 2006.
Figure 2: Factors Cited in SARs as being Responsible for Nunn-McCurdy
Breaches:
[Refer to PDF for image: vertical bar graph]
Factor responsible for breach: Engineering/design issues;
Number of breaches citing this factor: 50.
Factor responsible for breach: Schedule issues;
Number of breaches citing this factor: 44.
Factor responsible for breach: Quantity changes;
Number of breaches citing this factor: 41.
Factor responsible for breach: Revised estimates;
Number of breaches citing this factor: 38.
Factor responsible for breach: Economic changes;
Number of breaches citing this factor: 35.
Factor responsible for breach: Requirement changes;
Number of breaches citing this factor: 34.
Factor responsible for breach: Support costs;
Number of breaches citing this factor: 23.
Factor responsible for breach: Funding issues;
Number of breaches citing this factor: 21.
Factor responsible for breach: Production issues;
Number of breaches citing this factor: 16.
Source: GAO analysis of DOD data.
[End of figure]
DOD Has Introduced New Practices to Mitigate Risk of Breaches and
Plans to Propose Changes to Nunn-McCurdy Process:
DOD has instituted a process to provide earlier warning of potential
Nunn-McCurdy breaches and plans to propose changes to the Nunn-McCurdy
process to reduce several statutory requirements for breaches caused
by quantity changes.
Specifically, the Joint Staff has implemented a process to provide an
earlier evaluation of the factors that are contributing to cost growth
so that programs can take mitigating actions before experiencing a
significant Nunn McCurdy breach. This new process has merit, as our
analysis shows that nearly 40 percent of Nunn-McCurdy breaches
occurred after a production decision had been made--when a program has
fewer options for restructuring. DOD plans to propose a legislative
amendment to reduce several statutory requirements added in 2009 for
Nunn-McCurdy breaches when it determines that a breach was caused
primarily by quantity changes that were unrelated to poor performance.
According to DOD, not all breaches are indicators of poor performance
because quantity reductions or capabilities added to a program after
it begins can affect unit cost. DOD officials point to Excalibur as an
example of a program that would qualify for this relief. The Excalibur
program experienced a Nunn-McCurdy breach of the critical cost growth
threshold after the Army reduced quantities from 30,000 to 6,264. The
quantity reductions were the result of Army assessments that concluded
it did not need as many of these munitions as planned, rather than in
response to program-specific cost concerns. While in the case of
Excalibur the Army reduced quantities based on capability needs, we
have previously reported that quantities are often reduced in response
to cost overruns on programs.[Footnote 10] Tracking changes in
research and development costs, which are not sensitive to quantity
changes, would be one way DOD could evaluate program performance in
this context.
Using Knowledge-Based Acquisition Practices Can Help Minimize the Risk
of Cost Overruns:
The Nunn-McCurdy process can be a useful mechanism for holding
programs accountable for cost growth and restructuring them in the
wake of cost growth; however, its effect is limited because, in
general, programs have already experienced significant problems by the
time it is triggered. It is not realistic to expect cost growth to be
entirely preventable, but it can be significantly reduced. To put
programs in a position to minimize the risk of cost growth, DOD must
use the tools available to it to establish programs in which there is
a match between requirements and resources--including funding--from
the start and execute those programs using knowledge-based acquisition
practices. In our previous work, we have identified proven management
practices--many of which have been incorporated into DOD policy, but
have yet to be fully implemented in practice--that can serve as tools
to prevent DOD cost overruns.[Footnote 11] Greater adherence to the
following practices at key phases of the acquisition process can help
reduce weapon system costs, contain pressures for increased funding,
and better address critical warfighter needs.
* Early and continued systems engineering analysis: Early systems
engineering, ideally beginning before a program is initiated and a
business case is set, is critical to designing a system that meets
requirements within available resources, such as technologies, time,
money, and people.[Footnote 12] Specifically, a robust analysis of
alternatives and preliminary design review (PDR)--which analyze the
achievability of required capabilities before committing to a program--
can help ensure that new programs have a sound, executable business
case that represents a cost-effective solution to meeting warfighters'
needs. Such engineering knowledge can identify key trade-offs in
requirements and technology that are essential to managing cost.
Systems engineering continues to be an important tool through a
program's critical design review (CDR) and system demonstration.
* Leveraging mature technologies and processes: Programs often have
insufficient knowledge about the maturity of technology. More
prototyping early in programs could help DOD ensure that a system's
proposed design can meet performance requirements. Further, having
predictable manufacturing processes before decisions are made to move
into production can reduce unknowns.[Footnote 13]
* Establishing realistic cost and schedule estimates that are matched
to available resources: Cost and schedule estimates are often based on
overly optimistic assumptions. Our previous work shows that without
the ability to generate reliable cost estimates, programs are at risk
of experiencing cost overruns, missed deadlines, and performance
shortfalls.[Footnote 14] Inaccurate estimates do not provide the
necessary foundation for sufficient funding commitments. Engineering
knowledge is required to achieve more accurate, reliable cost
estimates at the outset of a program.
* Clear, well-defined requirements: Our work has shown that DOD's
culture and environment often allow programs to start with too many
unknowns, for example, entering the acquisition process without a full
understanding of requirements.[Footnote 15] Additionally, minimizing
requirements changes could decrease the amount of cost growth
experienced by acquisition programs.
* Incremental approach to acquiring capabilities: Programs can put
themselves in a better position to succeed by implementing incremental
acquisition strategies that limit the time in development.[Footnote 16]
Our prior work on best product development practices found that
successful programs use these tools as they progress through the
acquisition process to gather knowledge that confirms that their
requirements are achievable, their technologies are mature, their
designs are stable, and their production processes are in control.
Successful product developers ensure a high level of knowledge is
achieved by key junctures in development. We characterize these
junctures as knowledge points. The following figure depicts how these
tools can come into play as a program moves through its development
process and into production. It summarizes the activities necessary
for successful outcomes at each key knowledge point.
Figure 3: DOD Acquisition Process and GAO Knowledge-Based Acquisition
Practices:
[Refer to PDF for image: illustration]
DOD acquisition process:
Materiel development decision:
Materiel solution analysis:
Milestone A:
Technology development:
PDR:
Milestone B: Development start.
Engineering and manufacturing development: Integrated system design:
Knowledge Point 1: Technologies, time, funding and other resources
match customer needs. Decision to invest in product development.
Key steps:
* Preliminary design review completed;
* Technologies demonstrated to high levels;
* Incremental acquisition strategy in place;
* Knowledge-based cost estimate.
CDR;
Engineering and manufacturing development: Capability and
manufacturing demo:
Knowledge Point 2: Design is stable and performs as expected. Decision
to start building and testing production representative prototypes.
Key steps:
* System-level CDR and subsystem design reviews completed;
* Ninety percent of engineering drawings released;
* Integrated system prototype demonstrated;
* Critical manufacturing processes identified.
Knowledge Point 3: Production meets cost, schedule, and quality
targets. Decision to produce first units for customer.
Key steps:
* Production-representative prototype demonstrated in intended
environment;
* Manufacturing processes in control;
* Product reliability demonstrated via production-representative
prototype testing.
Milestone C: Production start.
Production.
Source: GAO.
[End of figure]
Mr. Chairman, this completes my prepared statement. I would be happy
to respond to any questions you or other members of the subcommittee
may have at this time.
Contacts and Acknowledgments:
For further information about this statement, please contact Michael
J. Sullivan at (202) 512-4841 or sullivanm@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this statement. Individuals who made key
contributions to this statement include Ron Schwenn, Assistant
Director; Morgan Delaney Ramaker; Kristine Hassinger; Leigh Ann Nally;
Kenneth Patton; and Roxanna Sun.
[End of section]
Footnotes:
[1] 10 U.S.C. § 2433. The statutory provision is known as Nunn-McCurdy
because it was first introduced by Senator Nunn and passed as a 1-year
provision as part of the Department of Defense Authorization Act,
1982, 127 Cong. Rec. 9760-63 (1981), Pub. L. No. 97-86, § 917. The
following year, Representative McCurdy introduced a permanent
provision based on Senator Nunn's provision, which was enacted as part
of the Department of Defense Authorization Act, 1983, 128 Cong. Rec.
18345-48 (1982), Pub. L. No. 97-252, § 1107. There are a number of
statutory provisions that help implement cost growth reporting under
Nunn-McCurdy. For the purposes of this testimony, we refer to these
statutory provisions as the Nunn-McCurdy process.
[2] The Nunn-McCurdy statute did not use the terms "significant" or
"critical" to describe the cost growth thresholds until 2006, when the
statute was amended by section 802 of the National Defense
Authorization Act for Fiscal Year 2006, Pub. L. No. 109-163.
[3] Program acquisition unit cost is the total cost of development,
procurement, acquisition operations and maintenance, and military
construction divided by the number of units procured. Procurement unit
cost is the total procurement cost divided by the number of units to
be procured.
[4] Weapon Systems Acquisition Reform Act of 2009, Pub. L. No. 111-23,
§ 206 (codified at 10 U.S.C. § 2433a(b)).
[5] GAO, Trends in Nunn-McCurdy Cost Breaches for Major Defense
Acquisition Programs, [hyperlink,
http://www.gao.gov/products/GAO-11-295R] (Washington D.C.: Mar. 9,
2011).
[6] See [hyperlink, http://www.gao.gov/products/GAO-11-295R] for more
information about the methodology we used to count breaches and remove
duplicate entries from data provided by DOD.
[7] DOD is required to submit SARs to Congress at the end of each
fiscal year quarter on current major defense acquisition programs,
although certain exceptions apply. SARs for the first quarter of a
fiscal year are known as comprehensive annual SARs. Each comprehensive
annual SAR is required to be submitted within 60 days after the date
on which the President transmits the budget to Congress for the
following fiscal year. 10 U.S.C. § 2432(b)(1), (c)(4), (f). While DOD
is required to report breaches in quarterly SAR submissions, most
breaches are typically reported in comprehensive annual SARs.
[8] GAO, Defense Acquisitions: Despite Restructuring, SBIRS High
Program Remains at Risk of Cost and Schedule Overruns, [hyperlink,
http://www.gao.gov/products/GAO-04-48] (Washington, D.C.: Oct. 31,
2003).
[9] GAO, Defense Acquisitions: A Knowledge-Based Funding Approach
Could Improve Major Weapon System Program Outcomes, [hyperlink,
http://www.gao.gov/products/GAO-08-619] (Washington, D.C.: July 2,
2008).
[10] [hyperlink, http://www.gao.gov/products/GAO-08-619].
[11] GAO, Best Practices: Better Management of Technology Development
Can Improve Weapon System Outcomes, [hyperlink,
http://www.gao.gov/products/GAO/NSIAD-99-162] (Washington, D.C.: July
30, 1999); Best Practices: Better Matching of Needs and Resources Will
Lead to Better Weapon System Outcomes, [hyperlink,
http://www.gao.gov/products/GAO-01-288] (Washington, D.C.: Mar. 8,
2001); Best Practices: Capturing Design and Manufacturing Knowledge
Early Improves Acquisition Outcomes, [hyperlink,
http://www.gao.gov/products/GAO-02-701] (Washington, D.C.: July 15,
2002); [hyperlink, http://www.gao.gov/products/GAO-08-619]; Best
Practices: DOD Can Achieve Better Outcomes by Standardizing the Way
Manufacturing Risks Are Managed, [hyperlink,
http://www.gao.gov/products/GAO-10-439] (Washington, D.C.: Apr. 22,
2010); and Opportunities to Reduce Potential Duplication in Government
Programs, Save Tax Dollars, and Enhance Revenue, [hyperlink,
http://www.gao.gov/products/GAO-11-318SP] (Washington, D.C.: Mar. 1,
2011).
[12] [hyperlink, http://www.gao.gov/products/GAO-01-288].
[13] [hyperlink, http://www.gao.gov/products/GAO-02-701].
[14] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for
Developing and Managing Capital Program Costs, [hyperlink,
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009).
[15] GAO, Defense Acquisitions: Strong Leadership Is Key to Planning
and Executing Stable Weapon Programs, [hyperlink,
http://www.gao.gov/products/GAO-10-522] (Washington, D.C.: May 6,
2010).
[16] [hyperlink, http://www.gao.gov/products/GAO-08-619].
[End of section]
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