Defense Infrastructure: Army Should Assess Progress in Standardizing Designs for Facility Construction

In 2006, the U.S. Army Corps of Engineers began its Centers of Standardization program to develop design standards for facility types that the Army constructs on a regular basis. The Centers support broader Army efforts under the AFSP to standardize facility types with objectives such as improving design quality, reducing design and construction costs and time, and reducing change orders.

Senate Report 115-262 accompanying the John S. McCain National Defense Authorization Act for Fiscal Year 2019 included a provision for GAO to evaluate the Centers' effectiveness. This report assesses, among other things, the extent to which (1) the Centers have identified activities that support their objectives, and (2) the Army tracks the Centers' progress toward their objectives. GAO reviewed and analyzed applicable regulations and program and project documentation; compared Center activities to program objectives; and interviewed cognizant agency officials to gain an understanding of the Centers' operations and potential financial liabilities.

The nine Centers of Standardization (Centers) within the U.S. Army Corps of Engineers undertake a number of activities designed to support each of their program objectives. Their charter includes three objectives: (1) developing and refining Centers' policies and processes; (2) assuring consistent application of the Centers' standards; and (3) monitoring execution to meet the overarching objectives and priorities of the Army Facilities Standardization Program (AFSP) and standardization process. We found that the Centers' various activitiessuch as conducting value engineering and life-cycle cost studies to identify possible cost savings and analyze long-term costs of new facilitiesare consistent with key principles and concepts in Office of Management and Budget guidance for a disciplined capital planning process. Additionally, the post-occupancy evaluations led by the Centers are designed to evaluate whether the Army functional requirements have been met, Army standard design has been implemented, and there are any areas where the design could be improved. These evaluations support all three of the Centers' objectives by evaluating whether a design needs improvement, a facility was constructed in accordance with the approved project design, and customer needs were met.

The Army has limited performance measures to track the Centers' progress in achieving program objectives. Semi-annual meetings of the Army's Centers of Standardization Management Board (Board) enable the Army to track the Centers' progress toward their goal of developing and updating Center policies and processes (first objective of the Centers). However, GAO found that the Army lacks performance measures to assess the Centers' progress in ensuring the consistent application of Army standard designs (second objective of the Centers) and in monitoring how well the Centers meet the objectives and priorities of the AFSP and standardization process (third objective of the Centers). Specifically, the Board does not maintain, consolidate, or analyze information about how frequently the Centers participate in construction projects, or how this activity affects the program and supports AFSP objectives, such as reducing project costs, times, and change orders. Taking steps to develop and implement appropriate performance measures would enhance the Army's efforts to ensure that the Centers are meeting their program objectives.

GAO is recommending that the Army establish performance measures to assess the Centers' progress to (1) ensure the consistent use of standard designs and (2) reduce construction costs and time and reduce the occurrence of change orders. The Army concurred with our recommendations.

In 2006 the U.S. Army Corps of Engineers (USACE) began its Centers of  Standardization (Centers) program. Under this program, USACE  established nine Centers to develop design standards for types of  facilities that the Department of the Army (Army) constructs on a regular  basis, such as barracks, battalion headquarters, dining facilities, and  fitness centers. The objectives for Army facilities’ standardization and use  of the Centers’ standard designs include improving the design quality of  Army facilities, reducing the design and construction costs and time, and  reducing the contract changes during construction. We have previously  reported that federal construction projects typically involve some degree  of change as the projects progress. Contract changes (change orders)  are made through modifications to a contract and can occur for a variety  of reasons, including design errors and changes in user requirements.  For instance, a contractor could file a claim against the government if the  contractor felt there was a flaw in the Army’s standard design or that  using the standard design resulted in unanticipated costs during the  design or construction phase.

In March 2018 we reported that Department of Defense (DOD)  construction projects consistently faced cost overruns and schedule  delays. Additionally, we reported that guidance for construction projects  did not fully incorporate the necessary steps for developing reliable cost  estimates. We recommended that DOD fully incorporate all 12 steps  needed for developing high-quality reliable cost estimates. As of August  2019, DOD officials told us that the department was planning to update its  cost-estimating guidance to include all 12 steps.

In addition, in July 2019 we reported that USACE does not regularly  monitor how long it takes to finalize construction contract changes, thus  limiting management’s ability to identify and respond to problems. We  recommended that the Secretary of the Army direct the Chief of  Engineers and Commanding General of the U.S. Army Corps of  Engineers to develop a strategy to expand on existing data and systems  to routinely collect information on and monitor the time frames for  finalizing construction contract changes at the headquarters level. DOD  agreed with this recommendation, and officials told us that DOD has  developed a corrective action plan to address the recommendation. They  estimate that this effort will be completed in August 2020.

Senate Report 115-262, accompanying a bill for the John S. McCain  National Defense Authorization Act for Fiscal Year 2019, included a  provision for us to evaluate the effectiveness of the Centers, including  whether they are achieving their objectives. This report assesses the  extent to which (1) the Centers have identified activities that support their  key objectives; (2) the Army tracks the Centers’ progress in meeting their  key objectives; and (3) increased liability may be introduced to the  Centers during construction when standard designs are used.

For objective one, we assessed the Centers’ roles and responsibilities— as stipulated in Army and USACE regulations—to identify activities that  the Centers undertake on construction projects. We identified eight Army  projects that were authorized in fiscal years 2014 and 2015 for our  analysis. We selected projects from those years because military  construction projects typically take multiple years to complete. Therefore,  selecting projects from this time frame increased the likelihood that the  contractor had completed construction of the projects and that the  Centers had conducted post- occupancy evaluations, which are used to  assess users’ satisfaction with completed projects. We then compared  these activities to the objectives expressed in the Centers’ 2006 charter to  determine whether the activities supported the objectives. We reviewed  supporting documentation for eight Army projects that the service  identified as being built using standard designs to determine whether  evidence existed to demonstrate that the Centers had engaged in these  activities. While our observations on these projects are not generalizable  to all Army projects, they illustrate the kinds of activities the Centers  engage in on Army projects that use standard designs. We further  evaluated whether the Centers’ activities are consistent with key  principles and concepts in Office of Management and Budget (OMB)  guidance to agencies for a disciplined capital programming process (for  example, federal buildings). We also interviewed cognizant officials  concerning the Centers’ objectives and activities they engage in to  support those objectives.

For objective two, we reviewed information on processes related to the  Centers’ project documentation and performance metrics. We also  reviewed DOD annual performance reports to identify any goals and  performance measures that are related to the objectives of the Centers.  We assessed whether the project documentation, the Centers’  performance measures, and any performance measures in DOD’s annual  performance reports would assist the Centers in assessing progress  toward their three program objectives to (1) develop and refine Centers of  Standardization policies and processes; (2) assure consistent application  of standards of the Centers program; and (3) monitor the Centers’  execution to meet the overarching objectives and priorities of the Army  Facilities Standardization Program (AFSP) and standardization process.  Finally, we interviewed Centers headquarters and Army officials, including  members of the Centers of Standardization Management Board,  concerning any performance measures currently being utilized.

For objective three, we reviewed DOD and Army guidance and  regulations that address legal responsibilities related to military  construction to identify the extent to which the Centers’ role in developing  standard designs used in construction potentially exposes the Centers to  liability related to problems that arise during construction. We reviewed  documents that relate to the Centers’ standard contracting practices and  interviewed USACE legal counsel concerning any previous or potential  liability related to standard design.

We conducted this performance audit from January 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 overall objective of the Army Facilities Standardization Program is to  achieve savings and benefits in the programing, design, and construction  of Army facilities of excellence. To meet AFSP’s objectives in a timely,  efficient, and cost-effective manner, the Army established the nine  Centers in 2006 to support the AFSP, as shown in figure 1.

The AFSP operates under the direction of the Army Facilities  Standardization Committee (Committee). As shown in figure 2 below, the  Committee is chaired by the Assistant Chief of Staff for Installation  Management (ACSIM) and composed of members from USACE and the  U.S. Army Installation Management Command (IMCOM). Each of these  offices has representatives who are either full-fledged or advisory  members of the Centers of Standardization Management Board (the  Board). The Board members directly oversee the activities of the Centers  and are responsible for developing performance measures and reporting  them to the Committee.

The Centers have primary responsibility for developing and managing  Army standard design packages for designated facility types. The  Centers, among other things, ensure that these standard designs and  construction of projects comply with two other sets of facility guidelines:  DOD’s Unified Facilities Criteria (Facilities Criteria) and general Army  standards.

As we previously reported, the Facilities Criteria are overarching, DOD-wide technical manuals and standards used for planning, design, construction, restoration, and maintenance of DOD facility projects. These criteria must be used to the greatest extent possible by all DOD components. They are developed through the joint efforts of the U.S. Army Corps of Engineers, the Naval Facilities Engineering Command, and the Air Force Civil Engineer Center, and they are approved by the Engineer Senior Executive Panel of the  Unified Facilities Criteria Program.

According to Army Regulation 420-1, Army standards are the immutable, unchanging, required facility elements and criteria that define the fundamental purpose and function of a facility’s design and construction. These Army standards are authorized by the Committee. Army standard designs define the facility key components, features, and characteristics that must be included in the design and construction or major renovation of all facilities of the same type regardless of location, available funding, command preferences, or installation mission. Essentially, Army standard designs may consist of architectural and engineering drawings as well as written design specifications that a construction team can easily adapt or modify for site-specific requirements.

Figure 3 below compares Army standard designs with Facilities Criteria  and general Army standards.

In addition to developing and managing Army standard design packages,  the Centers’ staff function principally as engineering and architectural  consultants within larger project teams as they monitor and oversee the  appropriate use of Army standard designs (as well as any incorporated  Army standards or Facilities Criteria). According to Centers officials, 12  full-time and 21 part-time staff are currently dedicated to the Centers.  Staff are located in USACE headquarters in Washington, D.C., as well as  in eight USACE districts and one Engineering and Support Center. Each  Center specializes in and is responsible for specific facility types and their  designs. While the Centers support the Army’s overall efforts for  standardization, not every Army facility is built according to a standard  design. Appropriate Centers staff are required to review every proposed  Army construction project at its outset and, if an installation has requested  a waiver from an existing Army standard or standard design, all voting  members of the Committee may authorize waivers in accordance with  certain procedures. According to Centers officials, Army standard designs  have been developed for about 70 regularly constructed facility types out  of the Army’s nearly 900 facility types. For example, the Army has  standard designs for fire stations, chapels, dining facilities, and weapons  storage. (See appendix II for a listing of the 70 facility types that currently  have standard designs or for which standard designs are under  development.)

According to Centers officials, the Centers’ 70 facility types account for  approximately 60 percent of Army Military Construction (MILCON)  projects and represent an estimated 55 percent to 70 percent of the  overall Army MILCON budget for any given year. (See appendix III for  information on overall DOD standardization program, including the Navy  and Air Force standard design programs.) In fiscal year 2019, the Centers  reported a combined annual budget of about $6.2 million for their  operations and personnel.

The Centers Have Engaged in Activities That Support Key Objectives and Are Consistent with Key Principles and Concepts in OMB Guidance

The Centers identified and engaged in a number of activities designed to  support the key objectives found in their charter and these activities are  consistent with key principles and concepts in OMB guidance for a  disciplined capital programming process. The Centers’ charter includes  the following three objectives: (1) developing and refining Centers’  policies and processes; (2) assuring consistent application of standards of  the Centers program; and (3) monitoring the Centers’ execution to meet  the overarching objectives and priorities of the AFSP and standardization  process. To meet the three objectives, the Centers engage in different  activities throughout the military construction process. Figure 4 below  shows the various points at which the Centers are involved in the life- cycle of a military construction project and examples of the activities in  which the Centers engage. For example, Engineer Regulation 1110-3- 113 states that during the design phase of projects, the Centers maintain  a lead role and will be the technical lead for coordination, review, and  acceptance of design deliverables, including providing field technical  assistance, identifying and advising when a waiver is required and  coordinating with appropriate authorities in this matter, and reviewing and  editing requests for proposal documents—activities that according to our  analysis support the Centers’ second objective.

Based on our review of supporting documentation from five projects that  used standard designs, we found that the Centers were undertaking the  activities mentioned above. In addition, activities in which the Centers  engaged during the design, construction, and post-construction phases of  these projects were consistent with key principles and concepts in OMB  guidance. Specifically, we found evidence that, for these five projects,  Centers’ staff participated as integrated members of the project delivery  teams in planning meetings, design reviews, assessments of the need for  standard design waivers, value engineering studies, and life-cycle cost  analyses during the projects’ design and construction phases. These  activities were consistent with key principles and concepts in OMB  guidance for a disciplined capital planning process, including that  agencies should use integrated project teams, as appropriate, to manage  the various capital programming phases or major acquisition programs  within the agency.

In addition, we found that other Centers’ activities—performing post- occupancy evaluations (POE) and updating standard designs when  applicable—were also consistent with key principles and concepts in  OMB guidance for a disciplined capital planning process. For instance,  we found that a POE was completed for one project, a post-occupancy  questionnaire was completed for another project, a POE was planned  during fiscal year 2020 for a third project, and a fourth project was still  under construction. According to OMB capital programming guidance,  POEs are tools to evaluate the overall effectiveness of an agency’s  capital acquisition process. The primary objectives of a POE include (1)  identifying how accurately a project meets its objectives, expected  benefits, and strategic goals of the agency and (2) ensuring the continual  improvement of an agency’s capital-programming process based on  lessons learned. The guidance identifies factors to be considered for  evaluation in conducting a POE, such as standards and compliance,  customer/user satisfaction, and cost savings. The guidance also notes  that a POE should generally be conducted 12 months after the project  has been occupied, to allow time for the tenant to evaluate the building’s  performance and relevant aspects of project delivery. However, the  guidance allows agencies some flexibility in the timing of a POE to meet  their unique needs if 12 months is not the optimal timing to conduct the  evaluation.

Our review of Centers guidance and project documents also found that  the Centers’ activities supported the Centers’ objectives as well as AFSP  objectives and priorities. In addition, Centers officials emphasized that the  Centers participate in all Army standard design construction projects to  ensure that the facility designs support the objectives of the AFSP,  specifically improving the programing, design, and construction processes  for Army facilities. As shown in table 1 and further outlined below, we  assessed whether the Centers’ activities undertaken on standard design  construction projects were applicable to the Centers’ objectives. Then, for  those that were applicable, we determined whether those activities  supported the Centers’ objectives. (See appendix IV for a detailed  analysis of how the Centers activities support the program’s objectives.)

Centers use POEs to evaluate standard designs: We found, for example, that the POEs led by the Centers are designed to evaluate whether the project met fundamental Army functional and mission requirements, whether the project implemented Army standard design, and whether improvements to the design could be made. These reviews support Centers objectives 1, 2, and 3— developing and refining Centers’ policies and processes, consistently applying Army standard designs, and supporting AFSP objectives and priorities—by identifying areas of the design needing improvement, evaluating whether a facility was constructed in accordance with the approved project design, and eliciting customer feedback concerning whether the finished facility meets mission requirements.

Centers review standard design waivers: The Centers review an installation’s waiver request and advise whether a waiver to Army standards or standard designs is required for that specific project. This process supports Centers objectives 1, 2, and 3—developing and refining Centers’ policies and processes, consistently applying Army standard designs, and supporting AFSP objectives and priorities. Specifically, part of the waiver review and approval process is the Centers’ assessing whether a waiver request represents a unique need of a specific end user or a possible permanent change to the Army standard design or Unified Facilities Criteria. In addition, if the Centers waive the use of or approve deviations from standard design prior to the beginning of the construction phase, it may reduce the number of change orders that occur during construction.

Army Has Limited Performance Measures to Track the Centers’ Progress toward Key Objectives

The Army, through its Centers of Standardization Management Board, is  responsible for oversight of the Centers and has performance measures  to track their progress in achieving one of their three key objectives.  However, the Army does not have performance measures for assessing  progress for their other two objectives.

Army’s Centers of Standardization Management Board Is Responsible for Oversight of the Centers

The Board provides oversight to the Centers in support of the AFSP. The  Board members are responsible for developing, implementing, and  reporting on program metrics. The Centers’ Charter of 2006 broadly  identifies the mission and objectives of the Board, while more recent  program guidance and regulations describe its functions in more detail.  The Charter states that the mission of the Board is to provide corporate  oversight and consistent Centers execution in support of the AFSP.

In overseeing the Centers, it is key that the Board has performance  measures that provide it with evaluative information to help make  decisions about the program—information that tells them whether, and  why, a program is working well or not. Performance measurement is the  ongoing monitoring and reporting of program accomplishments,  particularly progress toward pre-established goals. It is typically  conducted by program or agency management and is critical for providing  information concerning whether a program is working well or not.  Performance measures may address the type or level of program  activities conducted (processes), the direct products and services  delivered by a program (outputs), or the results of those products and  services (outcomes).

Army’s Oversight Processes for the Centers Have Limited Performance Measures for Tracking Progress toward Achieving Centers’ Objectives

The Army has a performance measure to support its first key objective.  Each fiscal year, the nine Centers develop budget execution plans that  outline how they will support the design standards for the specific facility  types for which they have responsibility. In these plans, the Centers  establish goals for updating specific existing standard designs and  developing new standard designs (that is, the output from the Centers’  efforts). The Board’s primary oversight process consists of monitoring  program execution of the nine Centers. According to Center officials, the  Board reviews these execution plans at the semi-annual board meetings  to determine whether the Centers are executing as planned, that is have  the Centers met their goals for updating and developing standard  designs. We found that this oversight process enables the Board to  assess the progress each of the Centers has made toward achieving its  goals for updating existing standard designs and developing new ones.  For example, in fiscal year 2017 the Fort Worth Center completed all four  of its planned standard design updates, and the Honolulu Center  completed three of its four planned updates.

We also found that the Board does not evaluate progress toward ensuring  that the Centers consistently apply standard designs across the Centers  of Standardization program (second objective of the Centers).  Specifically, as shown in table 1 above, the Centers engage in a number  of activities that support the consistent application of Centers standards  on a project-by-project basis. However, the Board does not maintain,  consolidate, or analyze information about how frequently the Centers  engage in such activities, or how the Centers’ activities affect the  program. That is because, according to Army and Centers officials,  neither the Board nor the Centers have developed and implemented  performance measures to assess the progress the Centers are making in  ensuring that standard designs are consistently used. Absent such  measures, the Army lacks assurance that standard designs are being  applied, when appropriate, and that standard designs are being applied  consistently across the service.

In fact, to provide the project-specific documentation that we reviewed,  the Centers needed to request documents from the USACE district office  responsible for the projects. According to Centers officials, this was  necessary because the Centers currently do not have a document  management system in which project documentation is stored. Instead,  as the USACE organization responsible for specific projects, each district  maintains its own project records. The officials stated that USACE  recently moved to a cloud-based system for storing project documents  and is exploring whether this system could provide a more central  document storage system. We note that having access to such  information, along with creating appropriate performance measures, could  enable the Board to measure whether progress has been made in  ensuring that standard designs are applied consistently.

In addition, we found that the Board does not evaluate whether the  Centers are making progress in supporting the objectives and priorities of  the AFSP (third objective of the Centers). One of the objectives of the  AFSP is to reduce design costs and time, construction costs and time,  and the number of change orders issued during construction. Although  Army and Centers officials told us that the use of standard designs  reduces project costs, time, and change orders, they could not provide  supporting data. That is because, according to Army and Centers  officials, neither the Board nor the Centers have developed and  implemented performance measures to assess the effects of the use of  standard designs. Creating such measures could enable the Army to  assess the extent to which the Centers are reducing design costs and  time, construction costs and time, and the number of change orders  issued.

DOD’s Fiscal Year 2020 Annual Performance Plan and Fiscal Year 2018  Annual Performance Report established a goal of simplifying, delivering  faster, and reducing costs of product and service procurement. One of the  performance measures associated with this goal was to reduce cost  overruns and schedule delays by up to 50 percent for military construction  projects. Developing and implementing performance measures related to  reducing design costs and time, construction costs and time, and the  number of change orders issued would enable the Centers to  demonstrate the extent to which they are supporting DOD’s annual  performance goals.

Use of Standard Design Does Not Introduce Increased Liability to Facility Projects

We found that the use of the standard design does not introduce  increased liability for the Centers if issues arise during a construction  project. Centers officials stated that a contractor could file a claim against  the government if the contractor felt there was a flaw in the Army’s  standard design or that using the standard design resulted in  unanticipated costs during the design or construction phase. However,  Centers officials stated that there have been no instances in which any of  the Centers was a party to legal action related to the use of a standard  design.

According to Centers officials, the design for a facility project is typically  developed by one of the USACE district offices or an architect-engineer  contractor. Further, these officials stated that while the pertinent Army  standard design guides the development of Army project designs, the  final project design, certified by the USACE district office or an  architecture/engineering contractor, represents the plan for a specific  project. In addition, according to the Federal Acquisition Regulation  (FAR), the architect-engineer contractor is responsible for the  professional quality, technical accuracy, and coordination of all designs,  drawings, specifications, and other services furnished by the contractor  under its contract.  Furthermore, the FAR states that the contractor  shall, without additional compensation, correct or revise any errors or  deficiencies in its designs, drawings, specifications, and other services.  The FAR also stipulates that the contractor may be liable for government  costs resulting from errors or deficiencies in designs furnished under the  contract. Consequently, according to USACE officials, because the  Centers are not responsible for the design of a specific project, they  would not have increased liability in the event that changes were required  during construction.

The Centers of Standardization develop and update Army standards and  Army standard designs within the Army Facilities Standardization  Program. In addition, the Centers are responsible for ensuring that the  design and construction of Army military construction projects comply with  approved Army standards and Unified Facilities Criteria. While the Army  tracks the Centers’ program execution related to the Centers’ efforts to  develop new and update existing standard designs (first objective of the  Centers), it does not have performance measures for assessing progress  toward the Centers’ other two objectives. Specifically, the Army does not  have performance measures in place to assess the progress the Centers  have made toward assuring consistent application of standards from the  Centers’ program (second objective of the Centers) or monitoring the  Centers’ execution to meet the overarching objectives and priorities of the  AFSP and standardization process (third objective of the Centers)  including, among other things, reducing design costs and time,  construction costs and time, and change orders during construction. This  hinders the Centers’ ability to determine how well they are supporting the  objectives of both the Army Facility Standardization Program and DOD’s  annual performance plans, as well as the Centers’ ability to demonstrate  the extent to which they are achieving their objectives.

We are making two recommendations to the Secretary of the Army.

The Secretary of the Army should ensure that the Assistant Chief of Staff  for Installation Management, in conjunction with the Centers of  Standardization and the U.S. Army Corps of Engineers, establish and  implement performance measures to assess the progress the Centers are  making in ensuring that standard designs are used consistently.  (Recommendation 1)

The Secretary of the Army should ensure that the Assistant Chief of Staff  for Installation Management, in conjunction with the Centers of  Standardization and the U.S. Army Corps of Engineers, establish and  implement performance measures to assess the effects of the use of  standard designs, specifically the progress the Centers are making in  reducing design costs and time, construction costs and time, and change  orders. (Recommendation 2)

We provided a draft of this report to the Department of the Army for  review and comment. In its written comments, the Army concurred with  both of our recommendations, and stated it would take actions to  implement them. The Army’s comments are printed in their entirety in  appendix V.

We are sending copies of this report to the appropriate congressional  committees; the Secretary of Defense and the Secretaries of the Army,  Navy, and Air Force.

In addition, the report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions concerning this report, please  contact Diana Maurer at (202) 512-9627 or maurerd@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this report. Key contributors to this report are  listed in appendix VI.

Appendix I: List of Projects GAO Reviewed

Appendix II: Facility Types Supported by Centers of Standardization

According to Centers officials, a total of 12 full-time and 21 part-time staff  are assigned to the Centers of Standardization. Each Center specializes  in and is responsible for specific facility types and their designs. Table 3  below lists the current staffing levels and the facility types supported by  each of the Centers.

Appendix III: Department of Defense Standardization Program

The Department of Defense’s (DOD) department-wide standardization  program has the goals of improving military operational readiness,  reducing total ownership costs, and reducing cycle time. Overseen by the  Office of the Under Secretary of Defense for Research and Engineering  (OUSD(R&E)), the Department of Defense Standardization Program is  described in DOD Manual 4120.24, which outlines its governing council,  definitions, and procedures that apply to all components within the  department.

Under the Defense Standardization Program, DOD component heads  ensure that materiel standardization, including information technology and  facilities, is addressed throughout the acquisition process. The three  overarching goals of the Defense Standardization Program are to (1)  improve military operational readiness, (2) reduce total ownership costs of  the department, and (3) reduce cycle times. The manual also defines the  following terms:

Standard. A document that establishes uniform engineering or technical criteria, methods, processes, and practices.

Standardization. The process of developing and agreeing on (by consensus or decision) uniform engineering criteria for products, processes, practices, and methods for achieving compatibility, interoperability, interchangeability, or commonality of materiel.

Defense standard. A document that establishes uniform engineering and technical requirements for military-unique or substantially modified commercial processes, procedures, practices, and methods. There are five types of defense standards: interface standards, design criteria standards, manufacturing process standards, standard practices, and test method standards.

DOD’s Unified Facilities Criteria (Facilities Criteria) and Unified Facilities  Guide Specifications (UFGS) provide facility planning, design,  construction, operation and maintenance, sustainment, restoration, and  modernization criteria for facility owned by the DOD. The Facilities  Criteria contain technical guidance; introduce new and innovative  technology; or provide mandatory requirements to implement laws,  regulations, executive orders, and policies prescribed by higher authority  documents. The Facilities Criteria also define performance and quality  requirements for facilities to support their mission throughout their life  cycle. According to DOD guidance, the Facilities Criteria provide the most  current operationally effective, cost-efficient, and safe criteria at the time  of publication. Both the Facilities Criteria and UFGS are developed  through the joint efforts of the U.S. Army Corps of Engineers, the Naval  Facilities Engineering Command, and the Air Force Civil Engineer Center,  and are approved by the Engineer Senior Executive Panel of the Unified  Facilities Criteria Program.

The Facilities Criteria and UFGS systems were designed not only to  establish uniformity among defense facilities, but to standardize and  streamline the process for developing, maintaining, and disseminating  construction criteria. The procedures for the development and  maintenance of the Unified Criteria and Unified Specifications are outlined  in Military Standard 3007G, which is updated by the Engineering Senior  Executive Panel.

Each military department (Army, Navy, and Air Force) has its own  facilities standardization program that implements the Unified Criteria and  Unified Specifications as well as service-specific facilities criteria,  standards, and guides. The Army’s program, known as the Army Facilities  Standardization Program (AFSP), is the oldest among the three  departments, having been initiated in 1993. Due largely to the unique  construction needs of the Army, the AFSP is the most complex and  comprehensive of the facility standardization programs. It utilizes two  levels of guidance for standardized facility types: a broad standard, called  “Army Standards,” and a specific standard, called “Standard Design.” The  Department of the Navy program began in 2014 and provides policy and  standards for the design development, and revision of Navy project  documents in Navy and Marine Corps Design and Facilities Criteria, while  the Air Force program was started in 2016 and provides criteria in an Air  Force Instruction for design and construction of Air Force facilities.

Appendix IV: Crosswalk of Key Centers of Standardization Activities and Objectives

The Centers of Standardization (Centers) undertake a number of  activities designed to support the key objectives found in their charter,  which includes supporting the objectives of the Army Facilities  Standardization Program (AFSP). Table 4 identifies each of these  activities along with the specific objectives that we determined the  activities support.  developing and refining Centers of Standardization policies and processes, assuring consistent application of standards of the Centers’ program, and monitoring the Centers’ execution to meet the overarching objectives of the AFSP and standardization process. increased credibility with the Congress through more consistent construction program development, increased consistency in facility types with equal treatment among Army Commands, installations, and users, improved master planning and site development activities, improved design quality, and the promotion of design excellence, simplified design and construction project management, reduced design costs and times, reduced construction costs and time, and reduced change orders during construction, and increased customer satisfaction through improved responsiveness to users’ functional and operational requirements.

Appendix V: Comments from the Department of the Army

The Army uses standard designs for 70 types of facilities it regularly builds, e.g., barracks and fitness centers. Doing so can improve quality, reduce costs, and streamline contracting.

The Army Corps of Engineers’ “Centers for Standardization” should:

Ensure application of the Centers’ standards

The Army tracks the Centers’ progress in developing and refining designs, but doesn’t ensure that standards are consistently applied or assess the effects of designs on reducing costs or contract changes. We recommended establishing performance measures to do these things.


Department of Homeland Security: Continued Leadership Is Critical to Addressing a Range of Management Challenges

In 2003, GAO designated Implementing and Transforming DHS as a high-risk area to the federal government. DHS has made considerable progress in transforming its original component agencies into a single cabinet-level department, and as a result, in 2013, GAO narrowed the scope of the high-risk area to focus on Strengthening DHS Management Functions .

In addition, DHS leadership is responsible for implementing numerous recommendations that GAO has made to the department and its component agencies. Current vacancies in top leadership positions could pose a challenge to addressing high-risk areas and priority recommendations that span DHS's diverse missions, which include preventing terrorism and enhancing security, managing our borders, administering immigration laws, securing cyberspace, and responding to disasters.

This testimony discusses the need for DHS leadership commitment to strengthen its management functions and address GAO's priority recommendations. This testimony is based on GAO's 2019 high-risk update and other reports issued from March 2006 through April 2019.

With the support and commitment of top leadership, the Department of Homeland Security (DHS) has made important progress in strengthening its management functions; however, considerable work remains. As of March 2019, DHS had fully addressed 17 of the 30 outcomes related to its management functions (see table). DHS needs to continue to show sustained leadership commitment in implementing its Integrated Strategy for High-Risk Management to achieve the remaining outcomes. Leadership commitment is also pivotal in addressing other GAO high-risk areas where DHS has a role, such as ensuring the cybersecurity of the nation, the National Flood Insurance Program, and limiting the federal government's fiscal exposure by better managing climate change risks. Currently, DHS has acting officials serving in eight positions requiring Senate confirmation, including positions with responsibilities for implementing high-risk outcomes, such as the Secretary, Deputy Secretary, and Under Secretary for Management.

a “Mostly addressed”: Progress is significant and a small amount of work remains.

b “Partially addressed”: Progress is measurable, but significant work remains.

c “Initiated”: Activities have been initiated to address the outcome, but it is too early to report progress.

In April 2019, GAO sent a letter to the Acting Secretary of Homeland Security detailing 26 open recommendations that GAO believes warrant the highest priority personal attention from the department and its components. These 26 recommendations fall into six major areas—emergency preparedness and response, border security, transportation security, infrastructure and management, cybersecurity, and chemical and nuclear security. For example, GAO has recommended that DHS take steps to strengthen human capital management, such as better managing and assessing its cybersecurity workforce gaps and areas of critical need. Fourteen of the 26 recommendations have been issued to acting officials serving in vacant positions, including 12 to the Secretary of Homeland Security, and two to the Federal Emergency Management Agency which is currently operating under acting leadership.

Since the creation of DHS, GAO has made approximately 2,800 recommendations to the department, and DHS has implemented more than 75 percent of them, strengthening program management and performance measurement, among other things. GAO will continue to monitor DHS's progress in strengthening management functions and addressing priority recommendations.

I am pleased to be here today to discuss the importance of Department of  Homeland Security (DHS) leadership in addressing management  challenges and the department’s progress thus far. As you know, when  DHS began operations in 2003, department leadership faced the daunting  task of transforming 22 agencies—several with major management  challenges—into one department. At that time, we recognized that the  creation of DHS was an enormous undertaking that could take years to  implement. Failure to effectively address management challenges could  have serious national security consequences. In 2003, shortly after the  department was formed, we designated Implementing and Transforming  DHS as a high-risk area to the federal government. Today, the work to  strengthen DHS management continues.

DHS has made considerable progress in transforming its original  component agencies into a single cabinet-level department. As a result, in  2013, we narrowed the scope of the high-risk area to focus on  strengthening DHS management functions (i.e., acquisition management,  information technology management, financial management, human  capital management, and management integration) and changed the  name of the high-risk area to Strengthening DHS Management Functions  to reflect this focus. Over the last 16 years, leadership commitment has  been a key factor in DHS’s progress toward implementing our criteria for  removal from the High Risk List. It remains essential for DHS to maintain  top leadership support and sustained commitment to ensure continued  progress.

In addition to addressing its management functions high-risk area, DHS  leadership is responsible for implementing numerous recommendations  that we have made to the department and its component agencies. Since  DHS began operations in 2003, we have made about 2,800  recommendations, and DHS has implemented more than 75 percent of  them, thereby strengthening program management and performance  measurement, among other things. In April 2019, we sent a letter to the  Acting Secretary of Homeland Security detailing 26 open  recommendations that we deem highest priority for implementation.  Given that these recommendations are often the most complex and  difficult to implement, top DHS leadership will play an important role in the  actions to address these recommendations.

Current vacancies in top leadership positions could pose a challenge to  addressing high-risk areas and priority recommendations that span DHS’s  diverse missions, which include preventing terrorism and enhancing  security, managing our borders, administering immigration laws, securing  cyberspace, and responding to disasters. Based on information we have  received from DHS in compliance with the Federal Vacancies Reform Act  of 1998 (Vacancies Act), there are currently acting officials serving in  eight positions requiring Senate confirmation. Specifically, as of April 26,  2019, the following positions remain vacant: Secretary (16 days), Deputy  Secretary (377 days), Under Secretary for Management (16 days), Under  Secretary for Science and Technology (826 days), Director of U.S.  Immigration and Customs Enforcement (ICE) (826 days), Administrator of  Federal Emergency Management Agency (FEMA) (50 days), Chief  Financial Officer (826 days), and Inspector General (512 days).

Filling vacancies—including top DHS leadership positions and the heads  of operational components—with confirmed appointees, as applicable,  could help to ensure continued leadership commitment across all of  DHS’s mission areas. Although the department was formed as part of a  determined national effort to safeguard the United States against  terrorism, department leaders must execute all of the department’s  missions. For example, Hurricane Katrina in 2005, one of the largest  natural disasters in our nation’s history, refocused attention on the  importance of DHS’s role in providing the coordinated, comprehensive  federal response in the event of a natural disaster. In addition, DHS  focuses efforts on cybersecurity because cyber-based intrusions and  attacks on federal systems and systems supporting our nation’s critical  infrastructure are evolving and becoming more sophisticated, such as the  significant 2015 Office of Personnel Management (OPM) data breaches  that affected 21.5 million individuals. Such examples demonstrate the  range of threats that DHS leaders must be prepared to address.

With DHS’s wide-ranging missions, DHS leadership also has a pivotal  role in addressing other DHS-specific and government-wide areas on our  high-risk list. Specifically, DHS is responsible for addressing a high-risk  area related to FEMA’s management of the National Flood Insurance  Program. DHS and FEMA will also play key roles in the high-risk area of  Limiting the Federal Government's Fiscal Exposure by Better Managing  Climate Change Risks. Additionally, DHS has a key role in ensuring  cybersecurity of the nation. For example, DHS has established the  National Cybersecurity and Communications Integration Center, which  functions as the 24/7 cyber monitoring, incident response, and  management center for the federal civilian government. Further, DHS has  a nexus and responsibilities in several of our other government-wide,  high-risk areas including (1) improving management of information  technology acquisitions and operations, (2) strategic human capital  management, (3) managing federal real property, and (4) the  government-wide security clearance process.

My statement today discusses the need for DHS’s continued leadership  commitment to (1) strengthen its management functions and (2) address  our priority recommendations. This statement is based on our 2019 high- risk update and other reports we issued from March 2006 through April  2019. For these products we analyzed DHS strategies and other  documents related to the department’s efforts to address its high-risk  areas and interviewed DHS officials, among other things. More detailed  information on the scope and methodology of our prior work can be found  within each specific report. We conducted the work on which this  statement is based 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.

Top Leadership Commitment Is Critical to Sustained Progress in Strengthening Management Functions

With top leadership support and commitment, DHS has made important  progress in strengthening its management functions, but considerable  work remains. As shown in figure 1, as of March 2019, DHS had met  three out of five criteria for removal from our High Risk List—leadership  commitment, action planning, and monitoring progress.

DHS has partially met the remaining two criteria: capacity (i.e., people  and other resources) and demonstrated, sustained progress. To address  the criteria for capacity, DHS needs to make additional progress in  identifying and allocating resources in certain areas—namely, acquisition,  information technology, and financial management—to fully demonstrate  its capacity. For the criteria for demonstrated, sustained progress, we  reported in March 2019 that DHS had fully addressed 17 out of the 30  outcomes that are the basis for gauging DHS’s progress across  management areas, as shown in table 1.

To fully meet the criteria for demonstrated, sustained progress, DHS  needs to continue implementing its Integrated Strategy for High-Risk  Management and maintain engagement with us to show measurable,  sustainable progress in implementing corrective actions and achieving  outcomes. DHS can accomplish this by, among other things, maintaining  a high level of top leadership support and sustained commitment to  ensure continued progress in executing its corrective actions through  completion, and increasing employee engagement and morale.

Examples of important programs and remaining work in the key  management functions include:  In the key management function of human capital management, DHS  leadership is needed to address skills gaps that have had a significant  role in the DHS management high-risk area. For example, we have  found that DHS lacks guidance on how to identify critical cybersecurity  and acquisition skills needed to support its new information  technology delivery model. We have also found that DHS has  insufficient technical skills to support its biometric identification  services program. Addressing these skill gaps could help DHS fully  demonstrate its capacity to strengthen and integrate its management  functions.

Additionally, within human capital management, DHS has struggled  with low employee morale scores since it began operations in 2003.  DHS’s 2018 score ranked 20th among 20 large and very large federal  agencies. Increasing employee engagement and morale is critical to  strengthening DHS’s mission and management functions. DHS has  continued to strengthen its employee engagement efforts by  implementing our 2012 recommendation to establish metrics of  success within components’ action plans for addressing its employee  satisfaction problems. Further, DHS has conducted audits to better  ensure components are basing hiring decisions and promotions on  human capital competencies. In addition, OPM’s 2018 Federal  Employee Viewpoint Survey data showed that in the past 2 years,  DHS’s score on the Employee Engagement Index (EEI) increased by  4 points—from 56 in 2016 to 60 in 2018—which was 1 point more  than the government-wide increase over the same period. While this  improvement is notable, DHS’s current EEI score is 1 point below its  EEI baseline score in 2010, suggesting that DHS is still working to  regain lost ground after an 8 point drop between 2010 and 2015.

In the key management function of financial management, DHS  officials have faced challenges modernizing DHS components’  financial management systems and business processes that affect the  department’s ability to have ready access to timely and reliable  information for informed decision-making. Effectively modernizing  financial management systems for the Coast Guard, FEMA, and ICE  would help improve the reliability of their financial reporting.

As we have reported, perhaps the single most important element of  successful management improvement and transformation initiatives is the  demonstrated commitment of top leaders, as shown by their personal  involvement in reform efforts. With regard to leadership commitment,  DHS’s top leadership, including leaders at the Secretary and Deputy  Secretary level, has demonstrated exemplary commitment and support  for addressing the department’s management challenges. They have also  taken actions to institutionalize this commitment to help ensure the long- term success of the department’s efforts. One such effort is the Under  Secretary for Management’s Integrated Priorities initiative to strengthen  the integration of DHS’s business operations across the department.

During monthly leadership meetings with the Under Secretary for  Management, the department’s Chief Executive Officers have been  providing status updates on their respective actions to address this high- risk designation. Furthermore, top DHS leaders, such as the Under  Secretary for Management and the department’s Chief Executive  Officers, routinely meet with our management to discuss progress on  high-risk areas.

Continued Leadership Commitment Is Critical to Addressing Priority Open Recommendations

In April 2019, we sent a letter to the Acting Secretary of Homeland  Security detailing 26 open recommendations that we deem highest  priority for implementation. Priority recommendations are those that we  believe warrant priority personal attention from heads of key departments  or agencies. These 26 recommendations fall into six major areas— emergency preparedness and response, border security, transportation  security, infrastructure and management, cybersecurity, and chemical  and nuclear security. Many of these recommendations cut across DHS’s  mission areas that are critical for national security. Given that these  recommendations are often the most complex and difficult to implement,  top DHS leadership will play a critical role in addressing them.

Fourteen of the 26 priority open recommendations we identified in the  April 2019 letter are directed to acting officials serving in vacant positions.  We have issued 12 recommendations to the Secretary of Homeland  Security who is currently an acting official. We have also issued two  recommendations to FEMA which is currently operating under acting  leadership.

Committed and consistent leadership at the department and component  levels will be critical for addressing our priority recommendations. For  example:  In September 2014, we recommended that the Secretary of  Homeland Security work jointly with the Administrator of the General  Services Administration to strengthen management of the ongoing  acquisition project to develop the multi-billion dollar headquarters  facilities at the St. Elizabeth’s campus in Washington, D.C.

Leadership is critical in this effort, given the magnitude of the project  and the impact of headquarters consolidation on DHS operations.

In October 2008, we recommended actions that FEMA should take to  improve its administration of the National Flood Insurance Program  high-risk area. We also recommended in September 2012 that  FEMA develop a methodology to better assess a jurisdiction's  capability to respond to and recover from a disaster without federal  assistance. In July 2015, we further recommended that the  Mitigation Framework Leadership Group establish an investment  strategy to identify, prioritize, and guide federal investments in  disaster resilience. Implementing these actions could limit the  federal government’s fiscal exposure and increase the nation’s  resilience to extreme weather events as the costs and impacts of  weather disasters resulting from floods, drought, and other events are  expected to increase in significance as previously “rare” events  become more common and intense.

In July 2018, we recommended that U.S. Customs and Border  Protection (CBP) analyze the costs associated with future barrier  segments along the southwest border and include cost as a factor in  the Impedance and Denial Prioritization Strategy. Obtaining this key  information could help CBP evaluate designs and prioritize locations  for future border barrier segments to deter cross-border illegal  activity.

In February 2017, we recommended that DHS establish metrics and  methods by which to evaluate the performance of DHS’s National  Cybersecurity and Communications Integration Center in relation to its  statutorily-required cybersecurity functions. Until it develops metrics  and methods to evaluate its performance, the center cannot ensure  that it is effectively meeting its statutory requirements, while cyber- based intrusions and attacks on federal systems and systems  supporting our nation’s critical infrastructure are becoming more  numerous, damaging, and disruptive. We also recommended in  February 2018 that DHS take steps to better manage and assess its  cybersecurity workforce gaps and areas of critical need. Given its  important role in the nation’s cybersecurity, taking steps to address  these issues will be critical.

We will continue to monitor DHS’s progress in strengthening  management functions and addressing priority recommendations. We  also plan to continue to meet quarterly with DHS management to gauge  leadership commitment, discuss progress, and review DHS’s goals and  corrective action plans in its Integrated Strategy for High-Risk  Management, which DHS issues twice per year.

Thank you, Chairman Thompson, Ranking Member Rogers, and  Members of the Committee. This concludes my testimony. I would be  pleased to answer any questions.

For further information on this testimony, please contact Christopher P.  Currie at (404) 679-1875 or curriec@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this statement. Other individuals making key contributions  to this work include Alana Finley, Assistant Director; Luis E. Rodriguez,  Analyst-in-Charge; Karin Fangman; Andrew Howard; and Thomas  Lombardi. Key contributors for the previous work that this is based on are  listed in each product.

This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.

When the Department of Homeland Security began operations in 2003, its leadership faced the daunting task of transforming 22 agencies into one department. Although DHS has been on our High Risk List since then, the department has made considerable progress.

We testified about this progress, as well as actions still needed to address management challenges. For example, we recommended that DHS strengthen its management of an ongoing acquisition project to develop new headquarters facilities. DHS leadership should also continue its commitment to addressing our recommendations, especially those we've designated as high priority.