Prescription Opioids: Voluntary Medicare Drug Management Programs to Control Misuse

Misuse and abuse of prescription opioids can lead to overdose and death. According to the Centers for Disease Control and Prevention (CDC), 47,600 overdose deaths in the United States in 2017 involved an opioid. GAO and other federal entities have raised concerns about opioid misuse and abuse in Medicare. The Comprehensive Addiction and Recovery Act of 2016 (CARA) authorized CMS and Medicare plan sponsors to establish voluntary DMPs that may limit access to frequently abused prescription drugs, such as opioids, for Medicare beneficiaries who are identified as being at risk for prescription drug abuse. DMPs will become mandatory in Medicare starting in January 2022.

CARA included a provision for GAO to review DMPs under Medicare. This report: 1) describes how Medicare identifies beneficiaries at risk of opioid misuse and abuse and how it attempts to mitigate that risk; and 2) identifies the factors likely to affect the success of Medicare DMPs.

GAO reviewed CDC's Guideline for Prescribing Opioids for Chronic Pain , CMS regulations, and other relevant CMS guidance. GAO also interviewed officials from CMS, the five largest Medicare Part D prescription drug plan sponsors, and officials from six other stakeholder organizations representing Medicare plan sponsors, physicians (including pain specialists), pharmacy benefit managers, state Medicaid programs, and patients.

Medicare's drug management programs (DMP) identify beneficiaries at risk of opioid misuse or abuse, and attempt to mitigate that risk through the use of case management and coverage limitations. DMPs are overseen by the Centers for Medicare & Medicaid Services (CMS) and voluntarily implemented by Medicare Part D prescription drug plan sponsors (private health plans). CMS established a two-step framework for identifying at-risk beneficiaries under DMPs. First, CMS identifies potentially at-risk beneficiaries based on key factors, such as beneficiaries' daily dosage of opioids and the number of prescribers and pharmacies from which they receive opioids, with higher numbers possibly putting the beneficiary at more risk. Second, Medicare Part D prescription drug plan sponsors' clinicians coordinate the provision of care among prescribers and pharmacists (referred to as case management) to determine if those potentially at-risk beneficiaries are actually at risk. If a patient is deemed to be at risk, coverage limitation tools—such as limiting a beneficiary to a selected prescriber or pharmacy, and implementing point-of-sale restrictions on certain drugs or amounts—can be used to limit the at-risk beneficiary's access to opioids. Beneficiaries have an opportunity to appeal an at-risk designation. None of the five plan sponsors GAO interviewed expressed concerns about beneficiaries not receiving clinically appropriate doses of opioids under the Medicare DMPs.

Medicare Part D prescription drug plan sponsors and other stakeholders GAO interviewed reported several factors beyond the case management process that could contribute to the success of DMPs. These factors included communication among sponsors, opioid prescribers, and pharmacies dispensing opioids to reduce potential resistance to participating in DMPs by opioid prescribers or beneficiaries.

According to plan sponsors and stakeholders, plan sponsors could communicate with stakeholders to ensure that DMPs are not viewed as a punitive tool by beneficiaries, but rather as tools for keeping them safe.

Plan sponsors and stakeholders noted that it is important for plan sponsors to have flexibility in varying coverage limitation features to fit regional and other differences in population groups. They noted that CMS should periodically reassess and adjust the elements of the DMP program where appropriate, to incorporate evidence from the outcomes of the DMP—such as how at-risk beneficiaries are identified, or which drugs are selected as frequently abused drugs.

Finally, CMS officials told GAO that they are taking steps to assess the DMPs and gather the information required to make periodic changes to the DMP program. For example, CMS officials plan to analyze data for at-risk beneficiaries that DMPs are required to report to CMS, update their Medicare Part D audit protocol, and obtain feedback from plan sponsors about how the DMPs are working.

The Department of Health and Human Services provided technical comments on a draft of this report, which GAO incorporated as appropriate.

Misuse and abuse of prescription opioids (such as oxycodone), which are  used to treat both acute and chronic pain, has become a serious public  health problem in the United States, including among Medicare  beneficiaries. The Centers for Disease Control and Prevention (CDC)  reported that from 1999 to 2013 the rate of deaths from prescription  opioids nearly quadrupled. In 2017, 47,600 overdose deaths in the United  States involved an opioid, and prescription opioids were involved in many  of these deaths. We and others have reported on inappropriate activities  and risks associated with these prescriptions, such as “doctor shopping,”  where a patient receives multiple opioid prescriptions from different  health-care providers; the diversion of prescription drugs for uses other  than intended; and questionable prescribing practices.

The federal government has taken multiple steps to reduce the misuse  and abuse of opioids. For Medicare, the Comprehensive Addiction and  Recovery Act of 2016 (CARA) established drug management programs  (DMP) to limit access to frequently abused drugs for beneficiaries  considered to be at risk for their abuse, among other things. In April  2018, the Centers for Medicare & Medicaid Services (CMS), which  administers the Medicare program, finalized regulations implementing  DMPs for Part D Medicare’s prescription drug option, through which  private health insurers known as plan sponsors provide prescription drug  coverage to Medicare beneficiaries. The regulations include standards  that Part D plan sponsors, as well as sponsors of Medicare Advantage  plans that also may offer drug coverage (hereafter collectively referred to  as plan sponsors), may use to identify potentially at-risk beneficiaries.  DMPs are currently voluntary for plan sponsors but will become  mandatory starting Jan. 1, 2022, in accordance with the SUPPORT for  Patients and Communities Act.

CARA included a provision for GAO to review the implementation of  Medicare DMPs. In this report, we:  1.  describe how Medicare identifies beneficiaries at risk of opioid misuse  and abuse, and how it attempts to mitigate that risk;  2.  identify factors likely to affect the success of the Medicare drug  management programs.

To describe how Medicare identifies beneficiaries that are at risk of opioid  misuse and abuse, and how it attempts to mitigate that risk, we reviewed  the recommendations contained in CDC’s Guideline for Prescribing  Opioids for Chronic Pain and CMS’s Opioid Misuse Strategy, as well as  CMS regulations, and other relevant CMS guidance. We also  interviewed officials from CMS, Department of Health and Human  Services Office of Inspector General; America’s Health Insurance Plans— a trade association representing health insurers—and from the five  largest Medicare Part D plan sponsors, as measured by enrollment, that  together cover about 70 percent of Medicare beneficiaries with  prescription drug coverage.

To identify the factors likely to affect the success of the Medicare DMPs,  we reviewed the literature on opioid misuse and abuse, and interviewed  officials from CMS and other stakeholders, including the five largest  Medicare Part D plan sponsors, and officials with six organizations  representing Medicare plan sponsors, physicians (including pain  specialists), pharmacy benefit managers, state Medicaid programs, and  patients suffering chronic pain. The views of these Part D plan sponsors  and other stakeholder organizations we interviewed are not generalizable.

We conducted this performance audit from June 2018 to May 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

In 2017, nearly one in three Medicare Part D beneficiaries received an  opioid prescription, and Medicare spending for prescription opioids was  almost $3.4 billion. Medicare data for 2017 showed that the beneficiaries  potentially at risk for opioid misuse and abuse were more likely to be  under 65 years of age, female, and dually eligible for Medicare and  Medicaid.

States Experience with Medicaid Lock-in Programs

For years, to limit Medicaid at-risk beneficiaries’ access to controlled  substances, state Medicaid programs have used lock-in programs, which  restrict certain beneficiaries’ access to a single prescriber (such as a  physician or other health-care provider), a single pharmacy, or both.  States have broad discretion in how and whether to implement lock-ins,  including how to identify at-risk beneficiaries. Medicaid lock-in programs  have been associated with advantages including declines in inappropriate  prescribing, decreases in abuse of controlled substances, and increased  treatment options for beneficiaries. Research has identified an  unintended consequence of the Medicaid lock-in programs; some  individuals increased the amount of out-of-pocket payments they made  for controlled substances, thus avoiding lock-in programs as data on  these purchases are not collected by Medicaid.

State Prescription Drug Monitoring Programs (PDMP) are state-run  electronic databases that track the prescribing, dispensing, and  purchasing of controlled substances by individuals, whether purchased  out-of-pocket, through private insurance, or under insurance programs  such as Medicare and Medicaid. Data are available to individuals or  organizations as authorized under state law. For example, health-care  prescribers can check PDMPs for a specific individual prior to prescribing  controlled substances. State PDMPs have documentation of controlled  substances obtained by individuals. As of February 2018, all 50 states,  the District of Columbia, Guam, and Puerto Rico had operational PDMPs  within their borders.

Medicare DMPs Use Case Management to Identify Beneficiaries at Risk of Opioid Misuse and Attempt to Mitigate That Risk

Medicare DMPs perform case management to identify at-risk  beneficiaries and attempt to mitigate risk by increasing communication  and coordination across plan sponsors, health-care prescribers,  pharmacists, and at-risk beneficiaries. CMS established a framework for  plan sponsors that volunteer to establish Medicare DMPs. CMS’s  framework includes two steps for identifying at-risk beneficiaries: 1) CMS  identifies potentially at-risk beneficiaries based on key clinical factors and  2) plan sponsors use case management to identify the subset of  potentially at-risk beneficiaries who are actually at risk.

Step One: Identifying potentially at-risk beneficiaries. CMS identifies  potentially at-risk beneficiaries based on the minimum Overutilization  Monitoring System’s criteria and develops a quarterly list of these  beneficiaries, which it sends to plan sponsors. The Overutilization Monitoring System was originally designed and implemented by CMS in  July 2013 to oversee plan sponsors’ compliance with CMS’s opioid  overutilization policy and is based on beneficiary claims data. It was  enhanced in 2019 to support the implementation of DMPs. The system  encompasses a medication safety approach with the goal of reducing  beneficiary overutilization of opioids while maintaining beneficiary access  to needed medication. The Overutilization Monitoring System creates  and sends a list of beneficiaries meeting minimum criteria quarterly to  plan sponsors with DMPs. These patients are considered potentially at- risk beneficiaries. Additional supplemental criteria can also be used by  plan sponsors to identify other potential at-risk beneficiaries, such as  those who use seven or more pharmacies for opioid prescriptions. Use of  higher numbers of prescribers and pharmacies may put the beneficiary at  more risk. (See table 1.)

Step Two: Using case management to identify actually at-risk  beneficiaries and mitigate risk of misuse or abuse. After identification  of potentially at-risk beneficiaries by CMS, the second step in the  framework is for plan sponsors to coordinate the provision of care,  referred to as case management. Plan sponsors use case management  to determine which potentially at-risk beneficiaries are deemed to be  actually at risk. Plan sponsors’ clinicians must begin case management  for each potentially at-risk beneficiary with the beneficiary’s prescribers of  frequently abused drugs, with the purpose of determining if current  treatment is appropriate, examining specifically if the beneficiary is being  appropriately treated with frequently abused drugs. This step allows for  health-care providers to bring the beneficiary’s clinical information into the  discussion.

Two groups of beneficiaries identified as potentially at risk are excluded  from Medicare DMPs during the case management process: First, CMS  will automatically exempt from Medicare DMP consideration any  beneficiary who (a) has elected to receive hospice, palliative, or end-of- life care; (b) is a resident of a long-term-care facility or of another facility  for which frequently abused drugs are dispensed for residents through a  contract with a single pharmacy; or (c) has active cancer-related pain.  Second, through a discussion of beneficiary-level clinical information as  part of case management, beneficiaries found to be receiving appropriate  treatment, or who have had cases resolved with adjustments to their  treatment will also be excluded from Medicare DMP consideration. CMS  officials told us that the beneficiaries’ health-care providers often adjust  their prescribing after talking with the health plans’ clinicians and learning  information about other health-care providers also treating the  beneficiary.

After eliminating the excluded beneficiaries, the plan sponsor sends an  initial notification letter to the remaining beneficiaries who continue to be  identified as potentially at risk, and thus, may require limiting the  coverage of a prescription drug in some manner (coverage limitation).  The notification letter notifies each beneficiary that he or she has been  identified as potentially at risk; details which coverage limitations the  sponsor intends to implement and for how long; explains how the  beneficiary can submit preferences for the selected frequently abused  drugs prescriber(s) and the selected dispensing pharmacy or pharmacies  for frequently abused drugs in case a lock-in tool is used; provides  information about resources and plan benefits that address prescription  abuse; explains how additional information can be provided to the plan  sponsor; and informs the beneficiary of the right to appeal, among other  things. Medicare plan sponsors have three coverage limitation tools that  can be used either concurrently or sequentially:

Frequently abused drugs prescriber lock-in. The at-risk beneficiary  will receive prescriptions from only one or more selected prescriber.  Prescribers in a group practice will count as a single prescriber.

Frequently abused drugs-dispensing pharmacy lock-in. The at- risk beneficiary will receive all prescriptions from one or more selected  dispensing pharmacy. The pharmacy must be in their plan sponsor’s  network. When a pharmacy has different locations that share real-time  electronic data, such as chain pharmacies, all locations of the  pharmacy will be treated as one pharmacy.

Beneficiary specific point-of-sale claim edit. The at-risk beneficiary  will be restricted to certain frequently abused drugs and amounts  through the point-of-sale claim edit. This means that a plan sponsor  must not cover a prescription for the frequently abused drug for an at- risk beneficiary that is in excess of the limit in the edit. Pharmacists  will receive a message when a beneficiary attempts to fill a  prescription if the prescription exceeds the limit in place for that  beneficiary.

After a 30-day period from the date of the initial notification letter, there  are two possible outcomes: either the plan sponsor will determine that the  beneficiary is at risk for misuse or abuse of frequently abused drugs and  will proceed with the coverage limitation under its DMP, or the sponsor  will determine that the beneficiary is not at risk. If the potentially at-risk  beneficiary is found to be at risk, a second notification letter is sent to the  beneficiary as soon as possible after the 30-day period but no later than  60 days from the date of the initial notification letter. The second letter  includes the beneficiary’s identification as at risk for misuse or abuse of  frequently abused drugs, the right to appeal the decision, coverage  limitations to be employed, and the expiration date of the coverage  limitations, among other things. The second notification letter also  explains how the beneficiary can submit preferences for the selected  frequently abused drugs prescriber(s) and the selected dispensing  pharmacy or pharmacies for frequently abused drugs in case a lock-in  tool is used. The selected frequently abused drugs prescriber(s) must  agree to serve as the beneficiary’s only frequently abused drugs  prescriber(s) and must be determined by the plan sponsor as not  contributing to the beneficiary’s opioid misuse. The at-risk beneficiary  generally has 60 days from the date of the second notification letter to  request an appeal of an at-risk determination. A new at-risk determination  is made by the plan sponsor as a result of continued case management  (that is, continued coordination of care and clinical discussions) within a  standard time frame of 7 days for redetermination, or an expedited time  frame of 72 hours for redetermination.

Alternatively, if it is determined that the potentially at-risk beneficiary is  being treated appropriately for their medical condition and is therefore not  at risk, an alternate second notification letter is sent to the beneficiary  stating that the beneficiary was deemed not to be at risk and that access  to frequently abused drugs will not be limited under a DMP. This alternate  second notification letter must be sent no later than 60 days after the date  on the initial notification letter.

If a beneficiary switches to a different plan sponsor after being identified  as potentially at risk or actually at risk, the determination does not  automatically transfer to the new plan sponsor. The new plan sponsor will  be able to see the previous plan sponsor’s determination, but the new  plan sponsor may have to make its own determination through case  management unless the prior plan’s case management information is up  to date.

According to CMS’s framework, the termination date of an at-risk  determination is the earlier of two possible dates: 12 months from the  effective date of the coverage limitation, unless the limitation is extended,  or when the beneficiary demonstrates that he or she is no longer likely to  be at risk before the end of the 12 months. At the end of the 12-month  period, a clinical assessment of the at-risk beneficiary will determine if the  DMP should continue for another year or be ended. The maximum  coverage limitation period in a DMP is 24 months. After 24 months, the  coverage limitation is halted, but according to the framework, CMS  continues to monitor the beneficiary quarterly through the Overutilization  Monitoring System and can re-identify the beneficiary as potentially at risk  again if he or she meets the minimum Overutilization Monitoring System  criteria.

Reporting requirements for Medicare DMPs. Although the Medicare  DMPs are currently voluntary, the framework places reporting  requirements on plan sponsors that choose to establish DMPs. Medicare  DMPs are integrated with the Opioid Drug Utilization Review Policy and  Overutilization Monitoring System to improve medication safety. Plan  sponsors must report to CMS, through the Overutilization Monitoring  System, the results of case management for each potential at-risk  beneficiary identified. For each beneficiary deemed to be at risk, the  coverage limitation tools – frequently abused drugs prescriber lock-in,  frequently abused drugs-dispensing pharmacy lock-in, and beneficiary  specific point-of-sale claims edit – that will be used to limit the  beneficiary’s access to frequently abused drugs must also be reported.  Other required information to be reported to CMS includes dates of the  initial and second notification letters, and the date that the plan sponsor  decides to terminate a potential at-risk or at-risk status. This data allows  CMS to track beneficiary-level data for those beneficiaries placed in  DMPs.

Input about Medicare DMP framework from plan sponsors and  experts. Although the at-risk determination is the responsibility of the  plan sponsor, four of the five plan sponsors we interviewed stated they  would rely on results from case management, including the beneficiary’s  primary health-care provider’s input, to make the determination. One plan  sponsor told us it has a panel of physicians and pharmacists that makes  the at-risk determination for beneficiaries. The panel takes into  consideration the input of the beneficiary’s prescribers of frequently  abused drugs, but the panel makes the final decision.

None of the five plan sponsors we interviewed expressed concerns about  beneficiaries not receiving clinically appropriate doses of opioids under  the Medicare DMPs, given that the case management process includes  clinician input, including the beneficiary’s primary health-care provider  and plan sponsors’ clinicians. According to one medical expert, case  management is beneficial because it allows for input from the  beneficiary’s prescriber rather than relying solely on the Overutilization  Monitoring System metric criteria to determine who is at risk.

Three of the five plan sponsors we interviewed expressed prior positive  experiences with lock-ins. All plan sponsors had experience with the lock- in tools from their experience participating in Medicaid programs or  offering private insurance plans. Three of the five plan sponsors reported  better coordinated oversight and management of patients and their  conditions in those experiences. One sponsor stated that lock-in  programs are perceived as an additional safety mechanism for at-risk  beneficiaries by helping with the coordination of the beneficiaries’ care  because the plan sponsor’s clinicians, prescribers, and pharmacies are  aware of the lock-in programs.

Plan Sponsors and Stakeholders Believe Coordination, Communication, and Flexibility to Incorporate Best Practices Are Keys to Success of Drug Management Programs

Officials with five plan sponsors and six stakeholder organizations  representing physicians, pharmacy benefit managers, and patients we  interviewed told us that several factors beyond the clinical input  incorporated in the case management process could contribute to the  success of DMPs. These factors include communication, collaboration,  and flexibility for plan sponsors to manage and incorporate best practices.

Communication among plan sponsors, opioid prescribers, and  pharmacies dispensing opioids could reduce any potential resistance to  DMPs by stakeholders, and contribute to DMP success, officials told us.  Specifically, several officials with plan sponsors and stakeholders noted  that sponsors should communicate with, and educate stakeholders to  ensure that DMPs, especially their coverage limitation tools, are not  viewed as punitive tools by beneficiaries, but rather as tools for keeping  them safe. Some of these officials stated that through education and  other means, plan sponsors should also encourage health-care providers  and their enrollees to view opioid addiction by at-risk beneficiaries as a  disease rather than a choice.

Effective collaboration among prescribers and patients in making  individualized treatment decisions for pain management is another key to  successful DMPs, according to some stakeholders we interviewed.  Specifically, some plan sponsors and a stakeholder noted that during and  after case management plan sponsors should support collaboration  between prescribers and patients to ensure access to the clinically  appropriate level of opioids for each beneficiary.

Flexibility to incorporate best practices from DMPs and flexibility in  varying coverage limitation features to fit regional differences are other  keys to success, some plan sponsors and a stakeholder told us, due to  regional and other differences in population groups. Data from CDC show  that there is some variation in death rates from opioids in the overall  population by state, and a CDC study also shows that opioid prescribing  patterns also vary by location—the average per capita prescribed  amounts varied widely by county, and demographic and other factors are  sometimes associated with higher prescribing patterns. In addition, some  officials with plan sponsors and stakeholders stated that the criteria for  DMPs such as how at-risk beneficiaries are identified, and other  parameters of the DMP (such as which drugs are designated as  frequently abused drugs) should be periodically reassessed by CMS with  feedback by plan sponsors and adjusted, where appropriate, to  incorporate evidence from the outcomes of the DMP.

Officials with plan sponsors and stakeholders we interviewed also  discussed several factors that could limit the success of the DMPs:

An official with a plan sponsor and a stakeholder told us that  purchases of opioids made by beneficiaries using cash are not  captured in the available prescription drug claims data maintained by  plan sponsors. These officials suggested therefore that sponsors  should encourage the selected prescribers to review this information  by using state PDMPs, which track controlled substance prescriptions  in a state and include cash sales of opioids.

One plan sponsor commented that coverage limitations could have a  negative effect on beneficiary health satisfaction survey scores and  therefore could affect how a physician prescribes opioids.  Beneficiaries who are placed in a DMP or subject to one of the DMP  tools may report decreased satisfaction in the “Consumer Assessment  of Healthcare Providers and Systems” surveys. Under Medicare  Advantage, patient experience about the ease of receiving care is one  measure of quality and is a factor in plan sponsor reimbursement.  Finally, some officials with plan sponsors and stakeholders told us  that in localities where prescribers feel a stigma associated with  dispensing opioids, the coverage limitation feature could have the  unintended consequence of creating a disincentive for prescribers to  take care of patients who require opioid treatment. According to an  official, to combat the opioid crisis, some states send letters to the top  opioid prescribers in their state as a way to create awareness about  trends in opioid prescribing. Officials with a plan sponsor and a  stakeholder said that providers who want to avoid being on the list of  top prescribers refer patients to pain specialists for management of  pain. Officials told us that the demand for these pain specialists is  increasing and there are long waiting lists to access care by these  pain specialists.

CMS is taking several steps to assess the DMPs and gather information  to make periodic changes to the program. For example, CMS officials told  us they plan to monitor and analyze beneficiary complaints, appeals,  prescription drug event data, and other data submitted by plan sponsors  related to DMPs. According to CMS officials, the agency also will obtain  feedback from plan sponsors about how the DMPs are working, and this  feedback will be the basis for making periodic changes to the DMPs.  CMS is also updating its Medicare Part C and D audit protocol so it can  audit DMP related beneficiary notices. Finally, CMS tracks the utilization  of opioids by Medicare Part D enrollees using Part D data and the  Overutilization Monitoring System. For example in the 2020 Medicare  Advantage and Part D draft call letter, CMS reported that between 2012  and 2017, there was a 33 percent decrease in the number of Part D  enrollees meeting or exceeding 90 MME for at least one day, with the  largest decrease (14 percent) in 2017.

We provided a draft of this report to HHS for review. HHS provided  technical comments, which we incorporated as appropriate.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of Health and Human Services, the  Administrator of CMS, and other interested parties. In addition, the report  will be available at no charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-7114 or at CosgroveJ@gao.gov. Contact points for our  Office of Congressional Relations and Office of Public Affairs can be  found on the last page of this report. Other major contributors to this  report are listed in appendix I.

Appendix I: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Martin T. Gahart (Assistant  Director), N. Rotimi Adebonojo (Analyst in Charge), Jennie Apter,  Deborah J. Miller, Emily Wilson, Rick Lipinski, Todd Anderson, and Vikki  Porter made key contributions to this report.

Medicare's drug management programs identify beneficiaries at risk of abusing opioids and take steps to reduce their risk. These programs look at factors that can contribute to opioid abuse and misuse, such as being prescribed a high daily dosage or receiving opioids from multiple prescribers.

Health care providers then review each case. If they decide a patient is at risk, this may trigger more limits on opioid availability, such as limiting a beneficiary to one prescriber. Those designated at risk may appeal. Patients who are receiving end-of-life care are among those exempted from these reviews.


Defense Acquisitions: Action Is Needed to Provide Clarity and Mitigate Risks of the Air Force's Planned Advanced Battle Management System

The Air Force's ABMS is a family of systems intended to replace the command and control capabilities of aging legacy programs and develop a network of intelligence, surveillance, and reconnaissance sensors. Air Force officials stated ABMS has received $172 million in funding through fiscal year 2020 for efforts related to ABMS. The Air Force is not designating ABMS as a major defense acquisition program or a middle tier acquisition program.

Congress included a provision in statute for GAO to review the status of ABMS. This report examines the extent to which the Air Force has (1) established a plan for ABMS development and (2) defined management and decision-making authorities for ABMS efforts. To conduct this assessment, GAO reviewed ABMS program documentation and interviewed Air Force officials.

The Air Force's Advanced Battle Management System (ABMS) is intended to establish a network to connect sensors on aircraft, drones, ships, and other weapon systems to provide a real-time operational picture on threats across all domains, as depicted below.

According to Air Force officials, the department will take a nontraditional approach to develop ABMS through short-term efforts that will enable it to rapidly field capabilities. As a result of this approach, ABMS requirements will change over time as development progresses. The Air Force started ABMS development without key elements of a business case, including:

firm requirements to inform the technological, software, engineering, and production capabilities needed;

a plan to attain mature technologies when needed to track development and ensure that technologies work as intended;

a cost estimate to inform budget requests and determine whether development efforts are cost effective; and

an affordability analysis to ensure sufficient funding is available.

GAO's previous work has shown that weapon systems without a sound business case are at greater risk for schedule delays, cost growth, and integration issues. Congress has kept a close eye on the effort and required quarterly briefings on its status, as well as a list of certain ABMS requirements by June 2020. However, given the lack of specificity that remains regarding the Air Force's ABMS plans, Congress would benefit from future briefings that address the missing business case elements.

While the Air Force has taken some steps to establish an ABMS management structure, the authorities of Air Force offices to plan and execute ABMS efforts are not fully defined. Unless addressed, the unclear decision-making authorities will hinder the Air Force's ability to effectively execute and assess ABMS development across multiple organizations.

GAO is making four recommendations, including that the Air Force should develop and brief the Congress quarterly on a plan to mature technologies, a cost estimate, and an affordability analysis. In addition, the Air Force should formalize the ABMS management structure and decision-making authorities. The Air Force concurred with the four recommendations. GAO will continue to monitor the Air Force's actions to address these recommendations.

The Air Force’s Advanced Battle Management System (ABMS) is  intended to eventually enable cross-service defense operations in an  operationally contested environment. According to Air Force officials,  ABMS will be composed of a network of intelligence, surveillance, and  reconnaissance sensors and will utilize cloud-based data sharing to  provide warfighters with battlespace awareness for the air, land, sea,  space, and cyber domains. The Air Force envisions ABMS as a family of  multiple systems, and the Air Force is in the early stages of planning and  is still determining which weapon systems—those that may already exist  or need to be developed—will support it. To date, the Air Force reported it  has received $172 million to fund ABMS efforts. The fiscal year 2021  President’s Budget requests $302 million for ABMS efforts.

The National Defense Authorization Act for Fiscal Year 2019 included a  provision for us to review the status of ABMS, including an assessment of  the system’s overall acquisition strategy. To date, the Air Force has not  established an overall acquisition strategy for ABMS. Therefore, this  report examines the extent to which the Air Force has (1) established a  plan for ABMS development, and (2) defined management and decision- making authorities for ABMS efforts.

To assess the extent to which the Air Force has established a plan for  ABMS development, we reviewed available planning documents to  determine how or whether the Air Force has identified the system’s  intended capabilities, cost, and schedule. We assessed those plans using  GAO’s acquisition leading practices to determine how Air Force plans  address key aspects of a business case to support that it has adequately  assessed the risks and costs of the ABMS effort. These include  documenting firm requirements, a plan to attain mature technologies, a  cost estimate, and an affordability analysis. In addition, we interviewed  officials to discuss aspects of the ABMS planning process that have been completed and what additional planning will be done. These offices  include the Office of Cost Assessment and Program Evaluation, Air Force  Acquisition, Air Force Headquarters Plans and Requirements, Office of  the Chief Architect of the Air Force, Chief Architect Integration Office, Air  Combat Command, and Air Force Program Executive Officer (PEO) for  Digital, and Air Force PEO for Command, Control, Communications,  Intelligence, and Networks.

To assess the extent to which the Air Force has defined management and  decision-making authorities for ABMS efforts, we reviewed Air Force  documents to determine how the Air Force established the management  structure for ABMS. In addition, we interviewed officials at various Air  Force offices supporting the management and execution of ABMS efforts  to discuss their roles and responsibilities. These offices include Air Force  Acquisition, Air Force Warfighting Integration Capability (AFWIC), Office  of the Chief Architect of the Air Force, Chief Architect Integration Office,  and Air Force PEOs. We assessed the ABMS management structure  against principles GAO has identified to achieve management objectives,  which internal controls refer to as the control environment. This  component was significant to this objective, along with the related  principle that management should establish an organizational structure,  assign responsibility, and delegate authority to achieve the entity’s  objectives.

We conducted this performance audit from August 2019 to April 2020 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.

The Air Force has identified ABMS as its solution to support broad  Department of Defense (DOD) efforts to develop Joint All-Domain  Command and Control (JADC2) capabilities. These capabilities will  eventually allow U.S. forces from all of the military services, as well as  allies, to conduct military operations across all warfighting domains.  Command and control is the collection and sharing of information to  enable military commanders to make timely, strategic decisions; take  tactical actions to meet mission goals; and counter threats to U.S. assets.  Figure 1 shows the concept of DOD operations within a joint all-domain  environment.

When the Air Force began planning for ABMS in 2017, officials stated the  intent was to replace and modernize the capabilities of the Airborne  Warning and Control System (AWACS), which provides the warfighter  with the capability to detect, identify, and track airborne threats, among  other capabilities. According to officials, the Air Force currently plans to  operate AWACS aircraft through 2035. In July 2018, the DOD Joint  Requirements Oversight Council approved an ABMS Initial Capabilities  Document that describes which capabilities would need to be developed  and which associated gaps in current capabilities the Air Force would  need to address.

According to Air Force officials, after the Initial Capabilities Document was  approved, the Air Force determined that its planned approach to ABMS  was no longer compatible with the most recent National Defense  Strategy, released in January 2018. The 2018 National Defense Strategy  outlines DOD’s strategy for maintaining the defense of the United States  based on new and reemerging threats from competitors, such as Russia  and China. It also defines expectations for how DOD and its military  departments should be prepared to engage those threats during future  conflicts:  forces would be expected to strike a diverse range of targets inside  adversarial air and missile defense networks;  forces would need capabilities to enhance close combat lethality; and

DOD would prioritize investments that enabled ground, air, sea, and  space forces to deploy, operate, and survive in all domains while  under attack.

Air Force officials stated that these expectations led the department to  reassess requirements for ABMS and assess new options for developing  more robust and survivable systems that could operate within contested  environments. For example, the Air Force officially canceled a  recapitalization program for the Joint Surveillance Target Attack Radar  System (JSTARS)—an aircraft that provides surveillance and information  on moving ground targets—in December 2018. The cancellation was  linked to the 2018 National Defense Strategy, which calls for a more  survivable and networked solution, among other things. A June 2018 Air  Force report to Congress identified concerns regarding the survivability of  the JSTARS aircraft in a contested environment and stated that the Air  Force was instead planning for ABMS to eventually provide JSTARS’s  capabilities. The Air Force determined that it could continue using some  of its JSTARS aircraft into the 2030s.

Officials stated the Air Force subsequently changed the scope and intent  of ABMS to align with the 2018 National Defense Strategy and broader  requirements for JADC2. According to senior Air Force officials, they  concluded that, to align with the new defense strategy, ABMS needed to  do far more than replace AWACS and JSTARS. They also concluded that  no single platform, such as an aircraft, would be the right solution to  providing command and control capabilities across multiple domains. In  an April 2019 congressional testimony, the Air Force announced a new  vision for ABMS as a multidomain command and control family of  systems enabling operations in air, land, sea, space, and cyber domains.  In that testimony, Air Force leadership explained the need to move away  from a platform-centric approach (such as JSTARS) to a network-centric  approach, one that connects every sensor to every shooter. The Air  Force, however, did not formally document its decision to change the  scope of ABMS. In November 2019, according to Air Force officials,  ABMS was determined to be the Air Force solution for JADC2 in  response to a July 2019 Joint Requirements Oversight Council memo  outlining DOD requirements for command and control systems  requirements across all domains.

In May 2019, we reported that Air Force leadership determined that it  would not designate ABMS as a major defense acquisition program  because it would be a family of systems. The Air Force also determined  that ABMS would be directed by a Chief Architect working across PEOs,  rather than a traditional acquisition program manager. According to Air  Force officials, the Chief Architect role will be instrumental in integrating  the various programs and technologies into an overall system and is the  first of its kind within the Air Force.

Additionally, Air Force officials stated that they intend to use a flexible  acquisition approach to develop ABMS, one that is outside of traditional  pathways such as a major defense acquisition program or middle tier  acquisition. According to the Chief Architect, this approach will allow  ABMS to develop and rapidly field capabilities. Specifically, the Air Force  intends to break up technology development into many short-term efforts,  generally lasting 4 to 6 months each. The Chief Architect stated that the  goal of breaking up development into smaller increments is to increase  innovation by requiring multiple contractors—including those that may not  usually engage with DOD—to compete for contracts more frequently.  These short-term efforts will include prototyping and demonstrations to  prove that the capabilities work. Those that are proven will be delivered to  the warfighter. By using this approach, the Air Force intends to field  capabilities sequentially and more quickly than if all were developed and  delivered at one time as is typically done for traditional acquisitions.  Additionally, Air Force officials indicated that this approach will not lock  the Air Force into long-term development efforts with just one contractor  and will allow the Air Force to more easily move on from unsuccessful  development efforts.

The Air Force Has Not Established a Business Case for ABMS, Increasing Development Risks

The Air Force has not established a plan or business case for ABMS that  identifies its requirements, a plan to attain mature technologies when  needed, a cost estimate, and an affordability analysis. As a result of  recent ABMS management and scope changes, the Air Force remains  early in the planning process and has not yet determined how to meet the  capabilities or identify systems that will comprise ABMS. In December  2019, Air Force officials stated an overall plan for ABMS did not exist and  would be difficult for the Air Force to develop in the near term due to the  unclear scope of ABMS requirements. To date, the Air Force has not  identified a development schedule for ABMS, and it has not formally  documented requirements.

As previously stated, ABMS will be managed as a family of systems and  not as a traditional acquisition program typically governed by DOD  Instruction 5000.02, nor as a middle tier acquisition. As a result, Air Force  officials initially told us that they did not intend to develop most of the  typical acquisition documentation, such as a cost estimate, that is  generally required of major defense acquisition programs before entering  the development phase. In March 2020, after we sent a copy of this report  to DOD for comment, the Air Force provided us a draft tailored acquisition  plan for ABMS in lieu of an acquisition strategy. Based on our initial  review, this document includes some elements of a traditional acquisition  strategy, such as contract and test strategies. However, this tailored  acquisition plan does not include key information such as the overall  planned capabilities and estimated cost and schedule for ABMS. We will  continue to monitor the Air Force’s planning efforts as the program  progresses. The Air Force also began preparing an analysis of  alternatives in January 2019 to assess options for delivering capabilities  such as surveilling moving targets and battle management command and  control. The Air Force expects to complete the analysis in 2020, but Air  Force officials expect it will inform only some aspects of ABMS planning.  The Air Force has not defined what additional planning documentation it  will develop to help it establish a business case for ABMS. For example,  major defense acquisition programs are generally required to develop  acquisition planning documents, such as a cost estimate.

We have previously reported on the importance of establishing a solid,  executable business case before committing resources to a new  development effort. A business case demonstrates that (1) the  warfighter’s needs are valid and that they can best be met with the  chosen concept and (2) the chosen concept can be developed and  produced within existing resources. In addition to an acquisition strategy,  other basic elements of a sound acquisition business case include firm  requirements, a plan for attaining mature technologies, and a reliable cost  estimate and affordability analysis, further described below.  1.  Firm requirements are the requisite technological, software,  engineering, and production capabilities needed by the user.  Acquisition leading practices state that requirements should be clearly  defined, affordable, and informed. Deciding how best to address  requirements involves a process of assessing trade-offs before  making decisions. Unstable or ill-defined requirements can lead to  cost, schedule, and performance shortfalls.  2.  A plan to attain mature technologies when needed is critical in  establishing that technologies can work as intended before integration  into a weapon system. The principle is not to avoid technical risk but  rather address risk early and resolve it ahead of the start of product  development. Identifying technologies and defining a plan to ensure  mature technologies can be attained when needed help guide  development activities and enable organizations to track development  and inform decisions on next steps.  3.  A reliable cost estimate and affordability analysis are critical to the  successful acquisition of weapon systems. GAO’s Cost Estimating  and Assessment Guide states that a reliable cost estimate is  comprehensive, well-documented, accurate, and credible. Leading  practices have shown that realistic cost estimates allow program  management to obtain the knowledge needed to make investment  decisions and match requirements with resources. A cost estimate is  the basis of an affordability analysis, which validates whether a  program’s budget is adequate for the planned acquisition strategy.

The process of developing and documenting a business case builds  knowledge needed to match customer needs with available resources,  including technologies, timing, and funding. The fact that the Air Force  does not plan to establish such a business case for ABMS increases the  risk of cost and schedule overruns and may impact Congress’s ability to  exercise its oversight responsibilities. The status of key elements for the  ABMS business case follows:  Status of requirements. The Air Force has not established well-defined,  firm requirements for ABMS, but Congress required that the Air Force  start defining requirements for the networked data architecture necessary  for ABMS to provide multidomain command and control and battle  management capabilities by June 2020. The Air Force has not defined  the changes in ABMS’s requirements, such as the need to provide  multidomain command and control capabilities in support of joint operations. As a result, the only existing documentation of ABMS’s  requirements resides in the ABMS Initial Capabilities Document from  2018, which generally focuses on the capabilities needed to replace  AWACS. That document does not address the expanded JADC2  requirements and capabilities ABMS is expected to eventually fulfill. Air  Force officials stated that ABMS requirements and the family of systems,  or programs, that compose ABMS will be defined over time as they gain  more knowledge.

Given the lack of specificity regarding ABMS, Congress has kept a close  eye on the effort and has implemented several reporting requirements.  Since 2018, the Air Force has been required to provide quarterly updates  to the defense committees on the status of ABMS development and  associated technologies. In addition, the National Defense Authorization  Act for Fiscal Year 2020 required the Air Force to provide ABMS-related  documentation that describes certain requirements, a development  schedule, and the current programs that will support ABMS, among other  things, by June 2020.

While the Air Force has not established firm requirements for ABMS to  date, it has informally identified some broad requirements. For example,  the Air Force anticipates that ABMS will provide interoperability between  systems, present real-time information to military decision makers, and  fully utilize the range of sensor data and capabilities across DOD to  create a common battlespace operational picture. In addition, Air Force  officials stated that ABMS would be developed as a government-owned  open architecture family of systems, which would allow any system to be  integrated into ABMS.

The Air Force has identified seven different development categories that it  plans to simultaneously address to meet its broad ABMS requirements.  According to the Air Force, the categories are not intended to be  comprehensive and may change as development progresses. These  development categories include:

Apps  Although the Air Force has not defined these seven development  categories, it has identified 28 development areas that fit within the  categories. For example, one of these development areas, which falls  under the “secure processing” category, is called cloudONE. It is intended  to store and process data using a cloud infrastructure for multiple levels of  classified and unclassified data. These development areas will eventually  compose the architecture and technologies that make up ABMS. In  January 2020, the Air Force provided us with a draft version of high-level  descriptions of the 28 development areas; however, the document did not  fully define the requirements or capabilities for the development areas nor  identify which organizations would lead each effort. For example, the  cloudONE description does not indicate specific technical requirements  that must be met, such as amount of storage, the number of users, or  data transmission rate.

Although ABMS requirements are not fully defined, the Air Force awarded  several short-term development contracts for ABMS. According to Air  Force officials, these efforts are intended to show that its nontraditional  development approach is feasible rather than to develop specific  capabilities that will be integrated into ABMS. For example, the Air Force  awarded several development contracts totaling approximately $8 million  for gatewayONE, one of the 28 development areas that is intended to  enable communication between platforms. As part of this effort, the Air  Force conducted a demonstration in a joint military exercise in December  2019. While the exercise demonstrated some data transfer capability, it  did not directly address the intent of gatewayONE to enable  communication between multiple platforms using government-owned  systems. According to Air Force officials, ongoing and future efforts will  allow the Air Force to better define ABMS requirements and determine  what existing and emerging technologies can fulfill those capabilities. The  Air Force has not determined what development efforts will follow these  early demonstration efforts, in part because it has not fully defined its  requirements.

Status of plan to attain mature technologies when needed. The Air  Force has started development activities without first identifying what  technologies are needed for the 28 development areas for ABMS.  According to Air Force officials, they do not plan to identify all  technologies needed while pursuing development activities. Therefore,  the Air Force cannot assess whether technologies required for ABMS are  mature or determine the necessary steps to ensure those technologies  are mature when needed. Air Force officials stated that as ABMS  development progresses, they plan to select commercially available or  other mature technologies for integration. However, without first  identifying the technologies it needs, the Air Force cannot develop a plan,  or technology roadmap, with detailed actions to ensure those  technologies will be mature when needed. For example, the Air Force  plans for ABMS to assume the capabilities of AWACS and JSTARS  aircraft, which are set to retire in the 2030s. However, the Air Force has  not defined the technologies ABMS will need or established a roadmap to  ensure those technologies are mature before the retirement of legacy  aircraft. This increases the risk that the requisite technologies will not be  mature before the Air Force must integrate them into ABMS, which  increases the likelihood that those capabilities will not be developed when  needed.

The Chief Architect and other Air Force senior leaders stated that the  ABMS development effort is an ambitious undertaking for the Air Force.  Our prior work has found that some DOD programs related to ABMS  development have posed challenges in the past, in part because  technologies were not sufficiently mature when needed, as shown in table  1.

Additionally, the Office of Cost Assessment and Program Evaluation  assessed previous DOD programs that were similar to ABMS  development and noted that the scope of ABMS will be larger than any of  those individual programs. Officials from that office concluded that ABMS  is a high-risk effort and the Air Force has not provided sufficient  programmatic detail. As a result, they could not conclude that the Air  Force would be able to overcome the cost, schedule, and performance  challenges of these past programs. Air Force officials stated that the Air  Force’s approach to ABMS development will avoid these past challenges  because only mature technologies will be integrated into ABMS and the  Air Force is expected to frequently evaluate development progress.  However, since the Air Force has not identified what the technology  needs for ABMS are, it cannot yet determine if those technologies are  mature or will be mature when needed. We have previously found that  starting development without first identifying and assessing the maturity of  technologies increases the likelihood that those technologies are not  mature when needed, which often results in cost overruns and schedule  delays.

Status of cost estimate and affordability. The Air Force has not  developed a cost estimate for ABMS or an affordability analysis.  According to the GAO Cost Estimating and Assessment Guide, even in  cases where limited information is available, cost estimates should still be  developed to inform budget requests. To date, the Air Force has  requested nearly $500 million for ABMS efforts through fiscal year 2021.  The Air Force, however, currently has no plans to develop a life-cycle  cost estimate, which would provide a comprehensive account of ABMS  costs, or an independent cost estimate, which would confirm the  credibility of estimated costs.

Officials stated that the Air Force has not developed a cost estimate  because the capabilities, technologies, and systems that will compose  ABMS are still to be determined and will change over time. Officials  stated they intend to develop cost estimates for each of the 28  development areas in the future but did not identify a timeline. The GAO  Cost Estimating and Assessment Guide acknowledges that cost  estimating is more difficult when requirements—and the technologies and  capabilities to meet them—are changing and the final product design is  not known while the system is being built. In these cases, leading  practices call for developing cost estimates that should be updated more  frequently to reflect changes in requirements. Without a realistic and  current cost estimate for ABMS efforts, the Air Force will be unable to  effectively allocate resources and conduct informed long-range  investment planning.

The Air Force has also not determined if it can afford ABMS. Affordability  is the degree to which the funding requirements for an acquisition effort fit  within the service’s overall portfolio plan. Whether an acquisition effort is  affordable depends a great deal on the quality of its cost estimate and  other planned outlays. To conduct an affordability analysis, the budget  requirements for the entire portfolio are identified for future years. This  can help determine whether the funding needs are relatively stable or if  the portfolio will require a funding increase in the future. The GAO Cost  Estimating and Assessment Guide states that, as part of the cost  estimating process, management should review and approve an  affordability analysis to identify any funding shortfalls. Air Force officials  stated that the Air Force does not plan to conduct a comprehensive  affordability analysis for ABMS because it is managing it as a family of  systems. They stated that any costs to the Air Force will be determined in  the future by the various organizations that manage the systems that will  eventually support ABMS. However, without an affordability analysis, the  Air Force will be unable to determine whether it can commit sufficient  resources for ABMS in future years.

Air Force Has Established an ABMS Management Structure, but Decision-Making Authorities Are Unclear

While the Air Force has taken some steps to establish an ABMS  management structure, the authorities of Air Force offices to plan and  execute ABMS efforts are unclear. Internal controls, which provide  standards on effective management of programs, state that management  should establish the organizational structure and authority necessary to  enable the entity to plan, execute, control, and assess the organization in  achieving its objectives. The Air Force, however, has not fully defined or  communicated ABMS decision-making authorities to Air Force offices,  and documentation to date regarding ABMS management has been  limited. Several Air Force offices are involved in ABMS management, as  shown in figure 2.

Air Force Acquisition. This office is headed by the Assistant Secretary  of the Air Force for Acquisition, Technology and Logistics, who is  generally responsible for all acquisition functions within the Air Force. In  an October 2018 memorandum, Air Force Acquisition established the  position of the Chief Architect and stated that any unresolved ABMS  issues between the Chief Architect and PEOs are to be brought to Air  Force Acquisition for resolution.

Chief Architect. The Air Force established this position in October 2018  to execute the overarching vision and strategy for ABMS. According to  the Air Force, the Chief Architect will determine the overall design of ABMS,  coordinate with the service-level commands and the acquisition  programs involved to ensure their efforts are aligned with the overall  design and development of ABMS, and  identify the enabling technologies that will compose the ABMS family  of systems.

An October 2018 memorandum stated that individual PEOs and program  managers that oversee programs supporting ABMS will retain all authority  and responsibility for executing their respective programs.

In November 2019, Air Force Acquisition issued additional ABMS  management guidance that stated that the Chief Architect would select  and fund ABMS development projects for PEOs to execute. However, the  guidance did not address whether the Chief Architect has authority to  direct the execution of efforts initiated and originally funded by the PEOs,  which may support ABMS. Specifically, there is no documentation to  clarify whether the Chief Architect would have the authority to realign  PEO priorities or funding for ABMS projects. For example, the PEO for  Space is currently executing a data integration project, which aligns with  the cloudONE development area. Although some ABMS funds have been  obligated for this project, there is no documentation to support that the  Chief Architect will be able to direct the PEO to change the project  objectives or timeline to align with ABMS requirements once they are  defined.

Air Force Warfighting Integration Capability (AFWIC). In October  2017, the Air Force established AFWIC. According to Air Force officials,  AFWIC will ensure forces are operationally ready to perform JADC2  missions using ABMS technologies. According to an AFWIC senior  official, in April 2019 AFWIC began leading multidomain command and  control efforts for the Air Force. An October 2018 memorandum directed  the Chief Architect to coordinate with AFWIC regarding the development  of ABMS. Other documentation on ABMS execution indicates that AFWIC  will also coordinate with major commands on Air Force doctrine and  operations in support of ABMS. However, the documentation did not  further define this coordination or indicate whether AFWIC would have  any authority in directing ABMS activities.

Chief Architect Integration Office. In December 2019, the Air Force  established the Chief Architect Integration Office at Wright-Patterson Air  Force Base to coordinate and integrate ABMS development efforts across  PEOs and other organizations. Air Force officials stated that this office is  in the process of being staffed and the roles and responsibilities still need  to be formalized. However, as currently envisioned, this office would lead  technology development risk reduction efforts by working with the PEOs  and other organizations, such as federally funded research and  development centers, to conduct ABMS demonstrations and prototypes.  Air Force officials told us the Chief Architect Integration Office is expected  to resolve issues across Air Force organizations, such as sharing of  resources and personnel. An Air Force Life Cycle Management Center- led task force is currently developing an overall strategy for the office, to  include resource and organizational requirements. Air Force officials  stated that a proposed strategy will be completed in March 2020. Until the  Chief Architect Integration Office has been fully established, it is unclear  whether the office will have the required authorities to execute the  mission of integrating ABMS development efforts across the Air Force.

Air Force officials stated that the decision-making authorities across these  offices will be developed over time. According to officials, details on these  authorities have not been developed or communicated to the offices  supporting ABMS and the Air Force has not established a timeline for  doing so. The Air Force expects that multiple organizations within the Air  Force will be responsible for executing ABMS development efforts.  Internal controls, which provides standards for effective management of  programs, states that organizational structure and authority is necessary  to plan, execute, and assess progress. The absence of fully defined and  documented decision-making authorities, which are communicated to all  those involved, increases the risk to the Air Force’s ability to successfully  plan, execute, and assess ABMS development efforts.

The Air Force started ABMS development activities without a business  case that defines ABMS requirements, a plan to ensure technologies are  mature when needed, a cost estimate, and an affordability analysis.  Developing these key elements of a business case helps to build a solid  foundation for any successful technology and product development effort,  even one using a nontraditional acquisition approach. Congress has  already required the Air Force to define and report on certain ABMS  requirements, among other aspects of ABMS planning, by June 2020.  However, the Air Force does not intend to develop the other elements of  a business case, even though it is requesting over $300 million for ABMS  development activities in fiscal year 2021. Given the criticality of the battle  management command and control mission and the planned retirement  of legacy programs, the lack of an ABMS business case introduces  uncertainty regarding whether the needed capabilities will be developed  within required time frames. For example, without a plan to mature  technologies needed to field ABMS capabilities, the Air Force cannot be  certain those technologies will be ready when needed.

While it may be difficult for the Air Force to formulate a complete ABMS  business case at this time, due to the recent changes in ABMS’s scope,  the Air Force is not precluded from beginning the process of defining and  formalizing a business case. As ABMS continues to evolve, so too can  the Air Force’s business case. For example, the Air Force does not yet  know the total life cycle costs of ABMS, but it could provide Congress with  a cost estimate based on its knowledge today and update the cost  estimate over time. This would allow the Air Force to assess whether  ABMS is affordable. Furthermore, the Air Force is already required to  provide quarterly briefs to congressional defense committees on the  status of ABMS, which affords the Air Force the opportunity to present  Congress with information on its ABMS business case and explain any  changes over time. Specifically, including updates on the scope of the Air  Force’s plans to ensure ABMS will have mature technologies when  needed, an overall cost estimate, and an affordability assessment would  provide important information to Congress.

Finally, the Air Force has started to execute ABMS development efforts  without clearly defined decision-making authorities that have been  communicated to the offices supporting those efforts. The absence of  these defined authorities may hinder management’s ability to execute and  assess ABMS development across multiple organizations within the Air  Force.

We are making the following four recommendations to the Secretary of  the Air Force to direct the Assistant Secretary of the Air Force for  Acquisition, Technology and Logistics:  The Assistant Secretary of the Air Force for Acquisition, Technology and  Logistics should direct the Chief Architect to develop a plan to attain  mature technologies when needed for each ABMS development area,  which includes an initial list of technologies and an assessment of their  maturity that is updated to reflect changes, and update Congress  quarterly. (Recommendation 1)

The Assistant Secretary of the Air Force for Acquisition, Technology and  Logistics should direct the Chief Architect to prepare a cost estimate that  is developed in accordance with cost estimating leading practices, to  include regularly updating the estimate to reflect ABMS changes and  actual costs, and update Congress quarterly. (Recommendation 2)

The Assistant Secretary of the Air Force for Acquisition, Technology and  Logistics should direct the Chief Architect to prepare an affordability  analysis that should be regularly updated, and update Congress  quarterly. (Recommendation 3)

The Assistant Secretary of the Air Force for Acquisition, Technology and  Logistics should formalize and document acquisition authority and  decision-making responsibilities of the Air Force offices involved in the  planning and execution of ABMS, to include the Chief Architect. This  document should be included as part of the submission to Congress in  June 2020 and communicated to the Air Force offices that support ABMS.  (Recommendation 4)

We provided a draft of this product to the Department of Defense for  comment. In its comments, reproduced in appendix I, the Department of  Defense concurred with our recommendations. We will continue to  monitor the Air Force’s actions to respond to these recommendations.

We are sending copies of this report to the appropriate congressional  committees. We are also sending a copy to the Secretary of Defense, the  Secretary of the Air Force, and other interested parties. In addition, this  report is available at no charge on GAO’s website at http://www.gao.gov.

Should you or your staff have questions, please contact me at (202) 512- 4841 or MakM@gao.gov. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this report.  GAO staff who made key contributions to this report are listed in appendix  II.

Appendix I: Department of Defense Comments

Appendix II: GAO Contact and Staff Acknowledgments

In addition to the contact above, the following staff members made key  contributions to this report: Justin Jaynes, Assistant Director; Jessica  Karnis, Analyst-in-Charge; and Lauren Wright. Other contributions were  made by Brian Bothwell, Rose Brister, Brian Fersch, Miranda Riemer,  Megan Setser, Hai Tran, and Robin Wilson.

The Air Force is developing the Advanced Battle Management System—a network to connect U.S. forces during military operations across land, sea, space, and cyberspace. Through cloud-based data sharing, sensors on drones, aircraft, ships, and other weapon systems would gather and aggregate real-time intelligence, surveillance, and reconnaissance information.

We found the Air Force hasn’t developed a complete plan for the system—like identifying which technologies would be included and the cost—putting it at risk for schedule delays, cost growth, and other issues if they don’t work together as intended.

We made 4 recommendations to address this.