Background Coast Guard Organizational Changes since 9/11 Since 9/11, the Coast Guard has made a series of organizational changes to realign its functions. First, from 2004 through 2006, under an effort known as “Sectorization,” the Coast Guard revised its field structure by consolidating field activities under individual commands, known as sectors. The Coast Guard’s 37 sectors report to nine districts, and each district reports to one of two area commands. District commanders are responsible for regional operations and execute operations and missions within their area of responsibility. Sector commanders are responsible for local operations within each district. Each of the Coast Guard area commands, districts, and sectors is responsible for managing its assets and accomplishing missions within its geographic area of responsibility and, for the purposes of this report, are referred to as field units. Figure 1 shows the Coast Guard’s field structure. In June 2006, the Coast Guard implemented another organizational change effort known as modernization. The goal of modernization was to realign its mission planning and mission support functions, among other things. According to Coast Guard documents, the effort was intended to address challenges the Coast Guard faced in aligning its operations with Coast Guard-wide priorities, and delivering mission support in a more cost effective manner. It was also intended to realign the Coast Guard’s operations and policies across multiple headquarters program offices. For example, the Coast Guard has six operational mission programs overseeing its statutory missions, and before modernization the leadership of each of them developed separate action plans and policies to execute their missions, while independently making resource decisions. Through modernization, the Coast Guard also sought to improve delivery of mission support services throughout the field, particularly with respect to maintenance of the Coast Guard’s assets, including its vessels, aircraft, and shore infrastructure. Coast Guard Actions to Determine Workforce Requirements The Coast Guard uses three analytical tools to determine its workforce requirements: manpower requirements determinations, the Sector Staffing Model, and the Activity-Based Staffing Model for boat stations. Manpower requirements determinations, which begin with a manpower requirements analysis (MRA), are the Coast Guard’s preferred tool for determining the number of personnel and mix of skills its units require to meet mission needs, according to Coast Guard documents. The analysis identifies both the number of personnel required, and their necessary competencies, while also taking into account the effect of existing, new, or modified requirements on Coast Guard’s workforce. The Coast Guard considers the manpower requirements determination process to be its preferred method to determine workforce requirements for its assets and field units. The Coast Guard’s other two analytical tools—the Sector Staffing Model and Activity-Based Staffing Model—use historic levels of activity to determine workforce requirements. The Sector Staffing Model assesses workforce requirements for shore force units, while the Activity-Based Staffing Model assesses boat stations. For comparison, while activity models may identify the workforce needed based on the activities previously conducted by a unit, determinations identify the workforce needed to conduct the activities required by a unit to accomplish its planned mission, based on documented requirements. For this reason, the Coast Guard considers activity models to be less reliable for determining workforce needs than manpower requirements. Table 1 summarizes these three Coast Guard analytical tools for determining workforce requirements. Coast Guard Realigned Operations and Mission Support Functions, but Did Not Consistently Apply Key Reform Practices to Modernization Effort The Coast Guard Realigned Operations and Mission Support Functions In a 2018 report to Congress, the Coast Guard stated that under the modernization effort, it realigned its operations and mission support functions to address deficiencies that affected its ability to fulfill missions. Between 2009 and 2015, the effort focused on establishing headquarters organizations and business processes to manage operations and mission support. Central to the effort was the Coast Guard’s establishment of three new headquarters organizations. Deputy Commandant for Operations. Created to manage operational strategy and policy. The Deputy Commandant for Operations is responsible for the strategic management of the Coast Guard’s mission programs. This includes assessing and monitoring the performance of the Coast Guard’s missions and developing Coast Guard-wide strategy and operational policy. The Deputy Commandant for Operations also provides support for issues that affect multiple Coast Guard missions, such as managing intelligence activities, coordinating interaction with external stakeholders, and identifying new and emerging issues that threaten operations, such as cyberattacks. According to the Coast Guard’s 2018 report to Congress, consolidating these functions under a single organization has enhanced operational effectiveness and efficiency and aligned national priorities with Coast Guard-wide planning efforts. In 2019, the Coast Guard placed its reserve component under the Deputy Commandant for Operations to better incorporate the Coast Guard’s reserves into its plans for meeting mission needs. Deputy Commandant for Mission Support. Created to manage mission support delivery and business processes. The Deputy Commandant for Mission Support is responsible for managing mission support policy, strategy, planning, and resourcing to meet mission needs for human resources, engineering and logistics, information systems, and acquisitions. At the field level, through the Director of Operational Logistics, this organization assists with maintenance of assets and logistics planning through a network of bases. The Director of Operational Logistics manages Coast Guard bases which deliver operations level support to specific assets and oversees the functions of each Coast Guard base. In addition, the Deputy Commandant for Mission Support organization manages Coast Guard Logistic and Service Centers. Each logistic or service center exercises authority over its functions and the delivery of mission support to the Coast Guard’s fleet of aircraft and vessels. For example, the Aviation Logistics Center, located in Elizabeth City, North Carolina, is the lead entity for ensuring aviation asset services, such as maintenance and supply, for Coast Guard’s aircraft, while the Surface Forces Logistics Center, in Baltimore, Maryland, is responsible for ensuring these services for its vessels. Coast Guard officials told us that the modernized mission support structure enabled the Coast Guard to standardize delivery of products and service. For example, they told us that this structure helped them ensure that the materials and parts provided remained consistent across the Coast Guard’s field units. Force Readiness Command (FORCECOM). Created as an organization within the Deputy Commandant for Mission Support to prepare the Coast Guard workforce to properly perform and execute missions. FORCECOM is responsible for overseeing Coast Guard’s training plans and policies. This includes developing and delivering training courses, and conducting performance and compliance assessments of units, to determine whether each mission has the necessary equipment and personnel skills to ensure operational readiness. Figure 2 provides an overview of the Coast Guard’s modernized organizational structure and the responsibilities of the headquarters organizations known as the Deputy Commandant for Operations and Deputy Commandant for Mission Support. Coast Guard Continues to Make Organizational Changes In 2018, the Coast Guard reported to Congress that while it completed its primary organizational changes, it continued to modernize its business processes. For example, it reported that it continued making improvements to its risk management process, organizational structure, and mission support functions, including human resources utilization and asset acquisition. In October 2019, Coast Guard officials told us that some of these adjustments continue in smaller, incremental efforts within the Deputy Commandant offices and individual Coast Guard programs. For example, Coast Guard officials from the Office of Mission Support Integration within the Deputy Commandant for Mission Support told us that efforts to modernize its mission support functions were ongoing. Officials told us that they were centralizing management of certain support delivery functions. Officials told us that centralization would help to ensure consistency in how functions are performed across the organization, as well as provide access to timely and complete information about the status of assets, personnel, and equipment. They told us that the Deputy Commandant for Mission Support had largely centralized such functions for one directorate—engineering and logistics—and expected to apply them for another directorate responsible for information systems in fiscal year 2020. According to officials, the Coast Guard has faced difficulty applying these same mission business practices to human resources since these practices focus on a specific capability and are geared more towards assets, such as vessels and aircraft, rather than personnel. Specifically, while information about the status of asset availability is generally static, there are more variables to determining the Coast Guard’s human resources needs. For example, in addition to identifying the size of the workforce necessary to perform missions, the Coast Guard must also consider how to retain personnel and develop a workforce that can adapt to changes such as addressing emerging threats like cyber-attacks. In 1995, the Coast Guard integrated the reserve and active duty workforce at the field level; however, the component did not have headquarters representation. In 2006, the Coast Guard issued a modernization goal to optimize the use of the reserve component by ensuring the workforce had the necessary training and support. In 2018, the Coast Guard chartered a project team to evaluate the state of the reserve component’s governance. The team found that the structure under the Deputy Commandant for Mission Support did not take into account the difference between the reserves workforce and Coast Guard programs. In 2019, the Coast Guard established a new reserve component organization under the Deputy Commandant for Operations. Changes stemming from modernization continued with the Coast Guard’s reorganization of its reserve component (see sidebar). In June 2019, the Coast Guard moved its reserve component from the Deputy Commandant for Mission Support to the Deputy Commandant for Operations. Coast Guard officials stated that the change was meant to address longstanding issues, such as not incorporating the reserve component into Coast Guard-wide policymaking. Coast Guard officials stated that when the reserve component was under the mission support organization, it was not strategically managed to align with Coast Guard- wide mission needs. For example, when reserve components were dispatched, there was no plan to support all of the operational needs of the mission, such as by providing additional equipment needed by the reserve workforce. Figure 3 provides a timeline of key actions the Coast Guard took from 2004 through 2019 to modernize its organizational structure. Coast Guard Has Not Consistently Applied Selected Key Reform Practices to Modernization Effort The Coast Guard has not consistently applied selected key reform practices to its modernization effort. Specifically, the Coast Guard did not apply or partially applied 5 of 7 selected key practices. We have previously reported that an agency must closely and carefully manage organizational reforms, since fully implementing major transformations can span several years. This is particularly important when the transformations include several major changes to the organization. The Coast Guard’s 2018 report to Congress on its modernization effort acknowledged that the risk of complications increases significantly with large-scale reorganization efforts, such as modernization, and noted that such changes require formal processes to look for complications as they arise and to fully assess their impact on the organization, including its workforce. To this end, we assessed the Coast Guard’s implementation of its modernization effort against selected key reform practices in three subcategories—Leadership focus and attention; Managing and monitoring; and Strategic workforce planning—and found the Coast Guard did not consistently apply these practices. Additionally, we assessed the extent to which the Coast Guard’s reorganization of its reserve component applied key reform practices under the Leadership focus and attention, Managing and monitoring and Strategic workforce planning subcategories. Figure 4 shows our assessment of the extent to which the Coast Guard’s actions to implement the modernization effort applied selected key reform practices. Leadership Focus and Attention We found that the Coast Guard generally applied two key practices under this subcategory, including identifying a case for change and dedicating a team to lead the initial implementation effort, and it partially applied the key practice of holding leadership accountable for its success. Identify case for change. The Coast Guard generally applied this key practice because it identified a case for change to continue to drive the need for the modernization effort. Our prior work shows that key elements of successful initiatives are the demonstrated commitment of top leaders and accountability for change. Further, top leadership involvement and clear lines of accountability for making improvements are critical to overcoming organizations’ natural resistance to change. According to Coast Guard documents, in 2006, when the modernization effort started, Coast Guard leadership promoted the changes outlined in the Coast Guard’s 10 modernization initiatives through internal memos and action plans. Coast Guard documentation highlighted the benefits of the change and identified the next steps to be taken in order to complete the change. Additionally, commandants issued their strategic priorities highlighting plans for the modernization effort. More recently, the Coast Guard’s 2018 report to Congress reiterated the importance of the modernization effort, noting that the challenges that initially drove the need for organizational changes continue to challenge the Coast Guard. Dedicated implementation team. The Coast Guard generally applied this key practice because it established a team to implement its modernization changes. In 2007, Coast Guard created the Strategic Transformation Team to coordinate the early implementation of the modernization effort. According to Coast Guard officials from the Office of Resource, Organizational Analysis, and Workforce Management, as the effort moved from the planning stages to implementation, the team consolidated the goals in the Coast Guard’s 10 modernization initiatives into five main reorganization efforts. The team was responsible for ensuring that the implementation of these five efforts was consistent with the initial goals of modernization. This included facilitating the use of the Coast Guard’s existing organizational review and approval processes for organizational changes and leading the measurement processes for ensuring that the goals of modernization were met. Hold leaders accountable. The Coast Guard partially applied this key practice because it initially established an office to oversee its modernization but did not continue these efforts to ensure leadership accountability for modernization implementation. In 2009, the Coast Guard created a permanent oversight office under the Office of the Vice Commandant to transition the coordination responsibilities of the Strategic Transformation Team to monitor implementation of the modernization effort. The office was given an expanded role of managing change efforts across the Coast Guard, including overseeing the development of metrics related to organizational change efforts to ensure that these changes achieved goals. However, in 2015 the Coast Guard disestablished this oversight office and did not specify any office responsible for ensuring organizational change efforts met intended goals. According to Coast Guard officials from the Office of Resource, Organizational Analysis, and Workforce Management, the Coast Guard redistributed some of the oversight office’s responsibilities among other offices within the established headquarters organizations. The officials told us they did so since they determined the initial goals of modernization—to create the new headquarters organizations—had been met and oversight was no longer needed. These officials stated that the individual headquarters organizations could manage any necessary planning moving forward for their specific organization. As such, the Coast Guard’s shifting leadership priorities affected what parts of the modernization effort were implemented and, in some cases, resulted in years spent working towards a change that was later terminated. For example, in 2012, the Commandant stated that the original modernization initiative to establish a single operations command to manage field operations was not near completion, taking up institutional energy, and impacting operations. As a result, he decided to discontinue the effort and retain the two area field command structure. However, according to Coast Guard officials from the Office of Resource, Organizational Analysis, and Workforce Management, planning for the effort was close to completion, and ending it led to the reassignment of staff. During this time, the Coast Guard also reduced FORCECOM’s role from managing and measuring the overall readiness capabilities of the service to focusing on workforce training, and moved the organization under the Deputy Commandant for Mission Support. At that point, the Coast Guard had already prepared and issued a business plan for FORCECOM outlining the initial primary mission, goals and metrics for evaluating effectiveness. We also assessed the Coast Guard’s application of key reform practices against its reorganization of the reserve component and found, similar to our determinations of the modernization effort, it partially applied key practices under Leadership focus and attention. For example, while the Coast Guard identified key leadership and stakeholders currently responsible for implementing the effort, it could not demonstrate that there is a process to ensure leaders are held accountable for this implementation. Managing and Monitoring The Coast Guard did not apply the two key practices of tracking implementation progress or collecting data to measure progress of the effort, and partially applied the other key practice of measuring employee satisfaction with the modernization effort. We have previously found that organizational transformations must be carefully and closely managed in order to monitor progress towards achieving intended goals, since fully implementing major transformations can span several years. This is particularly important for the modernization effort which the Coast Guard reported in 2018 had fundamentally altered how it conducts business across the organization, for every mission and at every level. Managing and monitoring organizational reforms includes applying key practices such as tracking and measuring progress and developing mechanisms to seek and monitor employee satisfaction with changes resulting from reforms. Track implementation progress. The Coast Guard did not apply this key practice because it did not track its progress in implementing the modernization effort on an ongoing basis. Officials told us that during the early stages of modernization, the Coast Guard developed implementation plans and engaged in a significant planning effort to finalize the organizational realignment. These plans provided a method to track the Coast Guard’s progress as they implemented each phase of modernization; however, as the effort matured, the Coast Guard determined that the effort did not require the same amount of planning as initial implementation. In 2009, during the early stages of modernization, the Coast Guard reported that it had efforts planned or underway to monitor the implementation progress of the modernization effort, including developing implementation plans, goals, and performance metrics. As the modernization effort matured and the Deputy Commandant for Mission Support and Deputy Commandant for Operations were created, Coast Guard officials determined that they did not need the same amount of planning, and the Coast Guard stopped updating its implementation plans. Additionally, for the reorganization of the reserve component, the Coast Guard has minimally applied practices under the Managing and monitoring category. In particular, the Coast Guard did not track implementation progress of the reorganization. For example, the Coast Guard established the new reserve component without finalized plans or milestones and metrics against which it could track implementation progress. Collect data to measure progress. The Coast Guard did not apply this key practice because it did not collect data to measure the extent to which the modernization effort achieved its goals. In 2009, the Coast Guard reported that it had plans underway to identify existing metrics and gather data that would enable evaluation of the performance and effectiveness of its modernized processes and facilitate continued improvements. This was to include indicators that could be applied across the modernization efforts’ multiple goals and priorities such as quality, timeliness, cost, and outcomes. At the time, the Coast Guard reported that this would take approximately 6 months to 1 year to complete. However, according to officials from the Office of Resource, Organizational Analysis, and Workforce Management, its plans were discontinued due to the disestablishment of the oversight office and changing leadership priorities. Further, they stated that the Coast Guard no longer felt the need to monitor the effort since it determined the initial goals had been achieved with the establishment of the new headquarters organizations. In 2018, the Coast Guard reported to Congress that changes to mission support systems and business processes were significant changes and demonstrated the success of the modernization effort by developing a more effective and efficient organization. However, while officials from multiple offices told us that these changes resulted in better data and greater efficiency, the Coast Guard could not identify metrics or a data collection system that could demonstrate that the Coast Guard’s implementation of the modernization effort had improved effectiveness or efficiency. Moreover, in our review of the Coast Guard’s organizational change process, we found no metrics, time frames, or milestones to track whether, and to what extent, its organizational changes were achieving the goals of the effort. Similarly, for the reorganization of the reserve component, the Coast Guard did not collect data to measure progress. For example, the Coast Guard established no milestones or metrics against which to measure the reserve components’ progress in achieving its intended goal of improved mission performance. Measure employee satisfaction. The Coast Guard partially applied this key practice because it sought employee feedback during the early stages of the modernization effort, but did not continue to measure employee satisfaction with the effort. During the initial implementation of modernization, the Coast Guard used a combination of informal and formal mechanisms to seek employee satisfaction. For example, according to a 2009 National Academy of Public Administration report, the Commandant reached out to personnel through informal means, such as social media, to communicate and obtain real time feedback from staff affected by the organizational changes. Formally, the Coast Guard obtained anecdotal information through surveys of staff through the Organizational Assessment Survey and the Office of Personnel Management’s Federal Employee Viewpoint Survey; however, these methods do not include specific questions related to the impact of organizational change efforts. Specifically for modernization, beyond efforts during the early stages of modernization, there has been no sustained Coast Guard-wide effort to monitor the impact of the change on employees. According to a senior Coast Guard official from the Office of Resource, Organizational Analysis, and Workforce Management, the Coast Guard is not required to conduct such assessments as changes are implemented. Specifically, the document governing the Coast Guard’s organizational change process does not specify measuring employee satisfaction as part of the organizational change request process. Additionally, though the Coast Guard currently has formal mechanisms in place that would enable it to seek employee satisfaction, our review of recent surveys found that these instruments do not include questions specific to the impact of organizational change efforts; nor do they capture employee perspective in a timely manner. Strategic Workforce Planning We found that the Coast Guard partially applied the key practice of assessing effects of modernization on its workforce by engaging in some activities that assess its impact on its current and future workforce and planning to determine whether needed resources and capacity were in place. We have previously reported that people are at the heart of any serious reform effort because people define the organization’s culture, drive its performance, and embody its knowledge base. This is echoed in the Coast Guard’s large-scale enterprise-wide change management guidance, which stresses the need for a formal, structured approach to manage the people side of change to increase likelihood of success. One of the goals of the modernization effort was to create a Coast Guard- wide human resources strategy to better support mission execution. The Commandant reiterated this commitment in September 2018 testimony to Congress by stating that the Coast Guard’s strategic plan would incorporate its 2016 Human Capital Strategy, a 10-year plan to ensure that the Coast Guard develops the workforce necessary to meet mission demands. In addition, the Coast Guard has taken steps to build a Force Planning Construct model to inform leadership on the forces and capabilities needed to execute its steady state and contingency operations. In its April 2018 Manpower Requirements Plan to Congress, the Coast Guard stated that it envisioned using the model to assess future workforce needs. According to developers of the model, the foundation of the tool was the completion of manpower requirements determinations for all 158 Coast Guard unit types. However, the Coast Guard has completed such determinations for a small fraction of its workforce, as we discuss later in this report. Finally, for the reorganization of the reserve component, we found that the Coast Guard had minimally applied the key practice under Strategic workforce planning. In particular, officials from the new reserve component told us that even though the reserve force is not covered by existing workforce planning tools, the Coast Guard continued to proceed with reorganizing the reserve force structure. For each of the key reform practices that were not fully implemented, we found that the Coast Guard’s organizational change request process and associated guidance documents did not require such practices to be followed, nor did they require tracking implementation of changes, collecting data to measure progress, or assessing employee satisfaction. By not fully implementing each of these key practices, the Coast Guard may miss opportunities to demonstrate that its investment in the modernization effort meets its ultimate goals to enhance efficiency and effectiveness and to improve the overall performance of the Coast Guard. Systematically tracking progress of organizational change efforts and measuring their effects, including employee satisfaction, would better position the Coast Guard to identify challenges, if any, to meeting the goals of the organizational change in a timely manner. Further, the Coast Guard noted that metrics used to show the effect on its efficiency, mission effectiveness, and operations may be used to measure and influence future modernization efforts. Coast Guard Has Assessed a Small Portion of its Workforce Needs and Does Not Have the Information Needed to Achieve its Manpower Assessment Goal The Coast Guard’s manpower requirements determination process is its preferred method for determining workforce needs because it identifies the workforce needed to conduct required mission activities; however, since it began implementing the process in 2003, the Coast Guard has completed it for only 6 percent of its workforce. Further, for those positions with which the Coast Guard has used the manpower requirements determination process, it has not consistently done so in accordance with Coast Guard guidance. For example, while required by Coast Guard guidance, the Coast Guard has not tracked the number of MRAs and manpower requirements determinations completed. In its April 2018 Manpower Requirements Plan to Congress, the Coast Guard set a goal for using the manpower requirements determination process to identify staffing needs for all positions in all units, but does not have information on the resources it would need to do so. Coast Guard Has Assessed Workforce Requirements for a Small Portion of its Workforce The Coast Guard has completed workforce assessments for a small portion of its 58,000 personnel across its 158 unit types. From calendar years 2014 through 2019, the Coast Guard used its three analytical tools—manpower requirements determinations, the Sector Staffing Model, and the Activity-Based Staffing Model—to complete workforce assessments for approximately 21 percent of its 58,000 position workforce. According to Coast Guard guidance, manpower requirements determinations are to be updated every 5 years. However, the Coast Guard completed the manpower requirements determination process, its primary workforce analysis tool, for only about 2 percent of positions during this 5-year span. In 2019, the Coast Guard used the Sector Staffing Model to assess workforce requirements for about 9 percent of positions. Finally, in 2019 the Coast Guard used the Activity-Based Staffing Model for boat stations to assess workforce requirements for about 9 percent of positions, according to officials. Coast Guard Has Generally Not Implemented the Manpower Requirements Determination Process According to its 2016 Human Capital Strategy, the manpower requirements determination process is the Coast Guard’s primary tool for defining the human capital its units require to meet mission needs. To this end, the Coast Guard’s goal is to use this process to establish manpower requirements for all positions in all units. Coast Guard guidance for implementing the manpower requirements determination process includes three key steps as noted in the service’s 2015 Staffing Logic and Manpower Requirements Manual. MRA. The manpower requirements determination process begins with programs or Coast Guard leadership, such as the Commandant or Vice Commandant, requesting an MRA, which is a comprehensive review of workforce needs as determined from a wide range of factors. These factors include regulations, training, and competencies needed to effectively perform each mission. The MRA assesses the information necessary to adjust personnel, resources, mission, or risk, depending on availability of resources. Officials from the manpower requirements determination program, contractors, or in some cases, other Coast Guard programs, may conduct MRAs. After Action Report. MRA requesters are to submit an after action report within 6 months after the MRA is completed. The after action report is to outline actions to be taken based on an MRA. These actions could include adding resources, adjusting requirements, or assuming additional risk. Manpower Requirements Determination. The process is to conclude with a manpower requirements determination. The determination identifies the number and type of positions a unit type requires to meet mission-based capability requirements. In developing the determination, stakeholders are to review MRA results and develop the determination, while documenting any changes from the initial MRA. These stakeholders typically include representatives from the program assessed in the MRA and experts from around the Coast Guard in areas such as personnel assignments, workforce forecasting, training availability and capacity, and resource oversight, among others. The manpower requirements determination program then submits the determination to be signed by the Assistant Commandant for Human Resources. This signed memorandum, known as the determination, formalizes the final manpower requirement. Figure 5 summarizes the Coast Guard’s manpower requirements determination process, according to Coast Guard guidance. We found that the Coast Guard has not ensured that all three key steps of the manpower requirements determination process are completed since it began implementing it in 2003. Since 2003, the Coast Guard conducted MRAs for 28 percent of its workforce. However, the Coast Guard completed manpower requirements determinations for only 6 percent of its workforce. Moreover, we found that this trend continued with MRAs that the Coast Guard completed within the past 5 years. For example, according to our analysis of Coast Guard documentation, from calendar years 2014 through 2019, the Coast Guard conducted MRAs for 13 percent of its workforce, but completed determinations for 2 percent. Further, Coast Guard officials reported they did not have documentation of having conducted after action reports for any MRAs. Figure 6 shows the share of the Coast Guard’s workforce that is supported by the manpower requirements determination process. The top row shows the share of workforce supported by this process since its inception in 2003. The bottom row shows the workforce supported by up to date MRAs and determinations—completed between 2014 and 2019— according to guidance. The Coast Guard’s 2018 Manpower Requirements Plan to Congress states that the Coast Guard’s goal is to have updated manpower requirements determinations for all authorized positions in all units. When it reaches that goal, the manpower requirements determination process will allow the Coast Guard to know which units are the most understaffed, and to make service-wide decisions based on where the most urgent needs are. Only when determinations have been completed for its entire workforce can Coast Guard leadership allocate personnel in the most effective and efficient manner. Notably, Coast Guard documents emphasize the importance of an enterprise-wide approach to track and manage resources because it enables leadership to compare needs and make informed trade-offs across programs. In 2019, officials in the manpower requirements determination program told us that MRAs were to be updated every 5 years. Officials stated that this is a best practice that aligns with the Department of Homeland Security’s workforce strategy. Pacific Area Command officials we spoke with also told us that they view the guidance as requiring that MRAs should not be older than 5 years. Additionally, the Coast Guard’s 2015 Staffing Logic and Manpower Requirements Manual states that the Manpower Requirements Determination Program Division Chief is responsible for ensuring that each unit type has undergone an MRA within the past 5 years. Nevertheless, in November 2019, Coast Guard officials in the manpower requirements determination program told us that they view it as a goal to update MRAs every 5 years, not a requirement. We found that the Coast Guard does not have current guidance explaining the process steps for Coast Guard officials to follow to systematically execute the manpower requirements determination process. Coast Guard officials told us they were using a combination of two documents to guide its manpower requirements determination process, and neither document was both current and comprehensive in terms of detailing the steps to follow. For example, the 2015 Staffing Logic and Manpower Requirements Manual contains individual process step requirements, but has been rescinded. In contrast, the 2018 Manpower Requirements Manual provides current policy, but does not include guidance on process steps that program officials are to follow. In its 2018 manual, the Coast Guard rescinded the 2015 manual without replacing or affirming its process steps. Officials stated that analysts in the manpower requirements determination program use the rescinded 2015 guidance in executing the process because they have no other guidance to follow. Officials in the manpower requirements determination program provided several reasons for why the program has not consistently ensured that all steps are completed. First, officials told us that completing a determination for each MRA had not always been a priority for the Coast Guard. Officials said that in some cases manpower requirements determinations were not completed due to disagreement among stakeholders about how to apply the results of the MRA. Officials said, for example, that while an MRA may find that a program is significantly understaffed, some stakeholders may argue against including the full scale of the shortfall in the determination due to limited resources and competing needs. Second, officials stated that some determinations were not completed because some programs requesting MRAs were not interested in obtaining the final determination upon receiving the MRA. Specifically, they explained that sometimes the program that requested to initiate the manpower requirements determination process is most interested in the staffing data contained in the MRA, rather than the final determination, which formalizes the trade-offs and results proposed in the MRA. Officials in the manpower requirements determination program told us that both the 2015 and 2018 manpower requirements determination guidance did not identify circumstances when a manpower requirements determination was not required to be completed for an MRA. Further, program officials told us that they were not aware that the process guidance they reported using required after-action reports. Coast Guard officials also stated that having the process guidance in a rescinded document had made their ability to implement and oversee the process a challenge due to the possibility of officials applying the guidance inconsistently. They further said they recognized the manpower requirements determination process was not clear and needed to be revised, and that doing so may help ensure officials consistently implement the process. In June 2019, officials said they planned to issue updated guidance, but had not established a timeframe for doing so. By issuing updated guidance for conducting manpower requirements determinations that outlines required process steps, and any circumstances in which the process steps do not need to be performed, the Coast Guard can better ensure that those responsible for implementing the process do so consistently. Coast Guard Has Not Tracked the Extent of Manpower Requirements Analyses and Determinations Completed In addition to requiring MRAs to be conducted every 5 years, the rescinded 2015 Coast Guard guidance, which officials reported using to execute the manpower requirements determination process, states that the manpower requirements determination program is to maintain and update a master list of MRAs conducted to enable the program to track and organize its workload. However, the Coast Guard has not tracked the extent to which it has assessed Coast Guard unit types through the manpower requirements determination process, as required in the 2015 process guidance, which officials report is still in use. For example, in March 2019 Coast Guard officials stated that they did not maintain a list of MRAs or manpower requirements determinations completed since the program began in 2003, and they were not aware that maintaining a list was a requirement. Officials prepared a list to respond to our request, and in April 2019, provided us with a list of MRAs and determinations the Coast Guard had completed since 2003. However, we found that the list was not accurate. The Coast Guard’s list underrepresented the number of MRAs completed by almost half. Specifically, it showed the Coast Guard had completed MRAs for 34 unit types since 2003, whereas our review of Coast Guard documents found that the Coast Guard had completed MRAs for 63 unit types during this span. We also found that the Coast Guard had not accurately reported to Congress about its progress in assessing workforce requirements. While the list the Coast Guard compiled for us underrepresented the number of MRAs completed, the information it provided to Congress in its April 2018 report overrepresented the extent to which it has assessed its workforce needs. Specifically, in April 2018 the Coast Guard reported to Congress that it had recently analyzed workforce needs for 54 percent of its workforce using the manpower requirements determination process and its activity models. However, more than half of the MRAs it had completed had not been updated in the past 5 years, as Coast Guard guidance requires. We found that less than half of the Coast Guard’s reported figure—21 percent of its workforce—is supported by a workforce analysis that has been updated in the last 5 years. The Coast Guard’s manpower requirements plan does not have time frames or milestones outlining how it plans to reach its manpower requirements determination goal of completing MRAs and determinations for its entire workforce. Coast Guard officials stated that their April 2018 Manpower Requirements Plan to Congress lays out their goal with respect to conducting manpower requirements determinations. However, this plan does not include time frames or milestones for completing determinations for all unit types, nor does it signal that the Coast Guard will track MRAs and determinations it has completed. Coast Guard officials stated that they were using a multi-year program to prioritize manpower studies and complete them as resources allowed. When asked for further information about this plan, officials stated that there was no specific document outlining the plan; rather, the intent of the 2018 Manpower Requirements Plan was to indicate their manpower analysis goal involves a multi-year journey. By updating its manpower requirements plan to include time frames and milestones for completing MRAs and determinations for all positions in all units, the Coast Guard can track progress toward its goal and make necessary adjustments in its planning, as needed. The Coast Guard has reported on the importance of tracking and completing manpower requirements determinations to justify its resource allocation decisions. For example, its 2018 Manpower Requirements Manual states that methods to determine workforce requirements have historically varied from program to program. This variability prevented the Coast Guard from compiling reliable workforce data and comparing workforce needs across the Coast Guard. According to the 2018 manual, manpower requirements determinations enable key decision-makers to effectively manage workforce needs because they provide the data needed to objectively predict future manpower requirements and compare staffing needs across the entire workforce. By tracking and documenting the extent to which it has completed MRAs and determinations for its workforce, the Coast Guard will be better positioned to know which unit types have a defensible basis for the number and type of personnel needed to meet mission demands and to prioritize which MRAs to conduct. Coast Guard Does Not Have Information on the Resources Needed to Reach its Manpower Assessment Goal The Coast Guard has not determined the resources—both staff and funding—it needs to meet its goal for its manpower requirements determination program to complete determinations for all units. Program officials told us that they have used the manpower requirements determination process for a limited share of its workforce because of resource limitations. Coast Guard documents show that it has been almost 10 years since the Coast Guard last performed an MRA for the manpower requirements determination program to determine its own workforce needs. The 2010 analysis found that the program would require at least 30 full-time equivalent positions to accomplish the Coast Guard’s goal of completing about 25 MRAs each year, which would enable it to assess the Coast Guard’s 158 unit types roughly every 5 years. As of January 2020, the program had six analysts dedicated to conducting manpower analyses and, according to officials, may only be able to produce one MRA each year. Program officials estimated that the cost of conducting an MRA may vary widely, from $170,000 to more than $5 million for more complex unit types. Nevertheless, program officials told us they generally did not track information on the costs of conducting MRAs. According to officials, the manpower requirements determination program cannot track all such costs because cost data is spread across different program offices. For example, officials stated that for contracted MRAs, contracting fees are easier to identify, but the manpower requirements determination program does not have access to other major costs, such as travel by officials conducting the analysis. While the manpower requirements determination program oversees the MRA process, and is tasked with ensuring manpower requirements determinations are completed for every unit in the Coast Guard, officials said that generally the program that is the subject of the MRA provides funding for the study, and only that program maintains access to travel costs associated with the MRA. They said the manpower requirements determination program does not request cost information from the programs requesting MRAs. Additionally, the manpower requirements determination program does not collect cost information from programs that conduct their own MRAs. The Coast Guard has increasingly used contractors to complete MRAs. While the Coast Guard has not tracked the costs of conducting MRAs, Coast Guard analysis has shown that having MRAs completed by contractors is more costly than completing them in-house. Program officials said they have increasingly used contractors because of staffing limitations. For example, from calendar years 2010 through 2019, contractors completed nearly half of the Coast Guard’s 54 MRAs. Figure 7 shows the MRAs and manpower requirements determinations completed by the Coast Guard and contractors from 2003 through 2019. Coast Guard guidance states that in a resource constrained environment, leaders need to make risk-based decisions to prioritize tasks and optimally allocate resources to execute its missions. In addition, our work in the area of strategic human capital management has shown that reassessing resource requirements helps organizations to achieve their missions and match resources to their needs. Developing information on the resources needed for staffing and funding the manpower requirements determination program to achieve its manpower goal would better position the Coast Guard to make informed trade-off decisions and allocate its limited resources to those units most in need of manpower requirements determinations. Conclusions The Coast Guard’s roles and responsibilities have grown over the past two decades following the terrorist attacks of 9/11. Among other things, increased national security roles, first response duties during natural disasters, and compliance duties for ensuring the safety of increased commercial maritime activity have underscored the importance of the Coast Guard’s multiple missions. Organizational changes it made through the modernization effort were intended to realign operations and support functions. To that end, the creation of headquarters organizations achieved modernization’s initial goals. However, the Coast Guard continues to change as a result of modernization, and it has placed less effort on ensuring achievement of the longer-term goals of creating a more efficient and effective organization. Establishing a process for tracking and measuring the effectiveness of the organizational changes brought on by modernization, including measuring employee satisfaction, would better position Coast Guard to understand whether its goals have been achieved. The Coast Guard reported to Congress in April 2018 that it faced challenges in meeting its daily mission demands because it was operating below the workforce necessary to meet its mission demands. However, the service does not have a complete picture of the workforce necessary to meet its mission demands or whether its existing mix of personnel is efficiently and effectively allocated across units. The Coast Guard considers its manpower requirements determination process instrumental in determining the workforce needed to perform its duties, and the foundation of models the Coast Guard uses to determine workforce size in times of contingency or heightened security. Updated guidance for its staff tasked with conducting such assessments would enable the Coast Guard to better ensure that the process is fully implemented. Further, as of January 2020, the Coast Guard had updated analyses for a small fraction of its workforce, and had not updated its Manpower Requirements Plan with time frames and milestones for achieving its goal of assessing its entire workforce. Additionally, it does not have information on the extent to which analyses have been completed over the years or the resources it needs to complete assessments for its entire workforce. By tracking and updating the completion of MRAs and determinations, updating its plan to complete manpower requirements determinations, and obtaining information on the resources needed to implement such a plan, the Coast Guard will better ensure that it has the right number of people with the right set of skills to meet its mission demands. In this way, the Coast Guard will be better positioned to inform Congress of its workforce and associated resource needs. Recommendations for Executive Action We are making the following six recommendations to the Coast Guard: The Commandant of the Coast Guard should establish a systematic mechanism to track implementation and measure the Coast Guard’s progress in achieving organizational change goals. (Recommendation 1) The Commandant of the Coast Guard should establish a mechanism to periodically seek and monitor employee satisfaction with organizational change efforts. (Recommendation 2) The Commandant of the Coast Guard should update its Manpower Requirements Manual with guidance for how to execute its manpower requirements determination process, and take steps to ensure the process is implemented. (Recommendation 3) The Commandant of the Coast Guard should track and document the extent to which it has completed manpower requirements analyses and determinations for each unit type. (Recommendation 4) The Commandant of the Coast Guard should update its April 2018 Manpower Requirements Plan to include time frames and milestones for completing manpower requirements analyses and determinations for all positions and units. (Recommendation 5) The Commandant of the Coast Guard should determine the resources its manpower requirements determination program needs, both staff and funding, to achieve its goal of completing manpower requirements determinations for all positions and units. (Recommendation 6) Agency Comments and Our Evaluation We provided a draft of this report to DHS for review and comment. DHS provided comments, reproduced in appendix V. DHS concurred with our six recommendations and described actions planned to address them. DHS also provided technical comments, which we incorporated into the report, as appropriate. With regard to our first recommendation, DHS stated that the Coast Guard’s Office of Resources, Organizational Analysis, and Workforce Management will update the Coast Guard Organizational Manual to establish policy requiring that requests to change organizational structure include a plan, and establish a mechanism to track implementation and measure progress in achieving organizational change goals. The Coast Guard estimated completing the effort by December 31, 2020. With regard to our second recommendation, DHS stated that Coast Guard leadership agrees that mechanisms to periodically seek and monitor employee satisfaction with organizational change efforts are valuable. DHS stated that the Coast Guard already conducts periodic surveys and each of these instruments provide opportunities for the workforce to provide feedback, including on organizational issues, and that it seems preferable for survey owners to add questions to existing surveys, as opposed to implementing new survey instruments. DHS requested GAO consider the recommendation as implemented because such feedback mechanisms were already in place, and therefore establishing new mechanisms was unnecessary. As we note in our report, it is important that the Coast Guard identify challenges, if any, to meeting the goals of organizational change in a timely manner. We found the Coast Guard’s current surveys do not capture employee perspectives as organizational changes are implemented. In determining whether to close this recommendation, we will review Coast Guard documentation demonstrating that the Coast Guard has modified its existing surveys with added questions that monitor employee satisfaction with organizational changes, and that it has plans for implementing the surveys in a timely manner. With regard to our third recommendation, DHS stated that the Coast Guard’s Office of Human Resources Strategy and Capability is developing a Tactics, Techniques and Procedures document to provide guidance for executing the manpower requirements determination process. The document will provide additional guidance on the overall MRD process, including explicit directions for the collection and analysis of manpower data, and will establish Coast Guard enterprise standards for key factors and allowances used when conducting manpower analysis. The Coast Guard estimated completing the effort by September 30, 2020. With regard to our fourth recommendation, DHS stated that in December 2019 the Coast Guard’s Office of Human Resources Strategy and Capability initiated the process to document and track manpower requirements in the Coast Guard’s system of record. The Coast Guard estimated completing the effort by December 31, 2020. With regard to our fifth recommendation, DHS stated that the Coast Guard’s Assistant Commandant for Human Resources Directorate would update its Manpower Requirements Plan during the next periodic report submitted to Congress, due in fiscal year 2022. The Coast Guard estimated completing the effort by March 31, 2022. With regard to our sixth recommendation, DHS stated that the Coast Guard’s Office of Human Resources Strategy and Capability will review its September 2010 MRA, revalidate the inputs, and update the findings of the MRA to reflect the current needs of the manpower requirements determination program. The Coast Guard estimated completing the effort by September 30, 2020. We are sending copies of this report to the appropriate congressional requesters, the Secretary of the Department of Homeland Security, and other interested parties. 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 about this report, please contact me at (202) 512-3841 or AndersonN@gao.gov. GAO staff who made key contributions to this report are listed in appendix VI. Appendix I: Objectives, Scope and Methodology This appendix provides additional information on our objectives, scope and methodology. This report examines (1) how the Coast Guard modernized its organization and the extent to which it has applied key reform practices to its organizational change efforts and (2) the extent to which the Coast Guard has assessed its workforce needs. To address our first objective we analyzed Coast Guard documents related to the modernization effort. The documents included policies and guidance regarding how the effort was to be implemented, as well as descriptions of the status of these efforts. To evaluate the extent to which the Coast Guard applied key reform practices and considerations for evaluating organizational change efforts we assessed Coast Guard policies and procedures related to Coast Guard operations against the key practices we outlined in our June 2018 report on government reorganization. We collected and analyzed documentation related to Coast Guard’s actions taken to implement organizational change efforts such as the modernization effort and the integration of the Coast Guard’s reserve component into the headquarters governance structure. We assessed these reports, data and documents against selected criteria for key practices and considerations for agency reorganization identified in our June 2018 report. We selected relevant key practices by examining each of the potential four categories and 12 subcategories identified in our June 2018 report to determine the extent to which the practices under each applied to the Coast Guard’s modernization and reserve component integration efforts. The four categories are Goals and outcomes,” “Process for developing reforms,” “Implementing the reforms,” and “Strategically managing the federal workforce.” We deemed two subcategories under the category of “Implementing the reform”, “Leadership focus and attention” and” Managing and monitoring” and one subcategory “Strategic workforce planning” under the “Strategic planning for the federal workforce” category as relevant criteria for assessing the Coast Guard’s modernization efforts. We deemed the remaining nine subcategories not relevant to the Coast Guard’s modernization efforts since modernization was implemented in 2006 and retrospective analysis of these criteria would not result in the agency being able to make changes. For the three subcategories included in our assessment, we determined seven key practices from these subcategories that were most relevant to the Coast Guard’s modernization efforts and applied those practices to our assessment. We reviewed Coast Guard documentation and then made qualitative determinations about the extent to which the Coast Guard’s implementation of its modernization efforts addressed these criteria. A second analyst independently reviewed and validated each determination. We evaluated the Coast Guard’s actions against key reform practices to determine if they were generally, partially, or not at all applied. Generally applied. Agency documentation demonstrated that Coast Guard officials substantially applied applicable key practices. Partially applied. Agency documentation demonstrated that Coast Guard officials applied some key practices but not to a significant degree. Not at all applied. Agency documentation did not demonstrate that Coast Guard officials applied key practices. We deemed the following seven subcategories under the four categories as relevant criteria for assessing the Coast Guard’s reserve component Integration efforts: “Establishing goals and outcomes,” “Involving employees and key stakeholders,” “Using data and evidence,” “Addressing high risk and Longstanding management challenges,” “Leadership focus and attention,” “Managing and monitoring,” and “Strategic workforce planning.” We determined that the remaining three subcategories were not relevant to the Coast Guard’s reserve component integration efforts because we deemed the key practice more applicable to a government-wide effort or determined that it was too early to consider as the reserve integration effort was in its initial implementation stage. For the seven subcategories included in our assessment, we determined 19 key practices from these subcategories were most relevant to the Coast Guard’s reserve component integration efforts and applied those practices to our assessment. We reviewed Coast Guard documentation and made qualitative determinations about the extent to which the Coast Guard’s reserve component Integration actions addressed these criteria. A second analyst independently reviewed and validated each determination. We assessed the Coast Guard’s actions using the modernization effort scale: (1) Generally applied; (2) Partially applied; (3) Not applied; and (4) Minimally applied. Minimally applied. Agency documentation demonstrated that Coast Guard officials applied a limited number of key practices with significant gaps associated with each key practice. Our determinations are preliminary observations of the effort because Coast Guard’s reserve component organizational effort was in its nascent stages during our review. This presented several challenges in determining the point at which Coast Guard actions justify a rating of generally applied and partially applied. We applied the following decision rules to resolve these discrepancies: If one practice of the subcategory was rated partially applied, then we concluded that the subcategory as a whole partially applied. If one practice of the subcategory was rated generally applied, but one or more other key practices as either partially applied or not at all applied, then we concluded that the subcategory as a whole partially applied. If one practice of the subcategory was rated partially applied, but one or more other key practices rated either minimally applied or not at all applied, then we concluded that the subcategory as a whole minimally applied. We interviewed cognizant officials at Coast Guard headquarters, and field units, including the Atlantic and Pacific Area commands, and two Coast Guard districts and two Coast Guard sectors collocated with them. We interviewed officials from the two area commands because of their role in implementing organizational changes, and the districts and sectors for their perspectives on the Coast Guard workforce assessment process. Headquarters and field officials interviewed were responsible for the overall management of their organization in addition to officials responsible for facilitating the implementation of organizational change efforts. We reviewed prior GAO reports on organizational realignment, Coast Guard organizational changes, and high-risk issues in the federal government. In addition, we reviewed other reports evaluating long- standing agency management challenges. Finally, we reviewed documents and information on these organizational change efforts and compared them against Coast Guard guidance on organizational changes. To address our second objective, we analyzed Coast Guard documents related to management tools the Coast Guard has developed to determine its workforce requirements and identify personnel needs. Documentation included guidance and analysis related to developing workforce staffing needs, and strategies that set out the Coast Guard’s stated human capital principles. As with the first objective, we interviewed cognizant officials at Coast Guard headquarters, its Atlantic and Pacific area commands, and the two Coast Guard districts and two sectors collocated with them. Headquarters officials we interviewed were responsible for the development of manpower requirements and overseeing implementation of workforce assessments for Coast Guard units. We also reviewed prior GAO reports on workforce planning and Coast Guard personnel issues. Finally, we reviewed documents and information on these efforts to assess workforce requirements, and compared them against Coast Guard guidance on organizational changes for conducting the manpower requirements determination process, and our prior work related to strategic human capital management. To assess the extent to which the Coast Guard has supported its workforce with manpower requirements analyses and determinations, we analyzed all manpower requirements analysis (MRA) and determination documents the Coast Guard completed from 2003, when it began implementing the manpower requirements determination process, through calendar year 2019, the last full year of data available at the time of our review. Specifically, we requested the entire collection of MRA and determination documents from the Coast Guard. We then requested the number of positions that make up each unit type with a completed MRA. We assessed the reliability of the Coast Guard’s data through electronic testing, reviewing documentation, and interviewing Coast Guard headquarters and field unit officials regarding how these data were collected and used. We determined that these data were sufficiently reliable for determining the number of positions within each type of Coast Guard unit. With this information, for every MRA and determination completed, we calculated the number of positions in the Coast Guard’s workforce supported by available data. We conducted this performance audit from December 2018 to February 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. Appendix II: Overview of the Coast Guard’s Modernization Effort Case for Change, Intended Goals, and Examples of Key Actions Taken, Calendar Years 2006 - 2015 In 2006, the Commandant of the Coast Guard issued 10 Commandant Intent Action Orders intended to address elements of the Coast Guard’s command and control structure, mission support systems, and business processes that were identified as detracting from mission execution. Table 2 provides an overview of the issues that drove the Coast Guard’s modernization effort, the intended goals for the effort as outlined in the 2006 Commandant Intent Action Orders, and examples of key actions the Coast Guard has taken to address the goals. Appendix III: Extent to Which the Coast Guard’s Reorganization of its Reserve Component Applied Key Reform Practices The Coast Guard’s reserve component is its only workforce dedicated to respond to contingency operations such as natural and manmade disasters. The Coast Guard found that demand for reserve forces to augment its active duty workforce had grown as the service was called to respond to more contingencies. In 2006, under its organizational modernization effort, the Coast Guard issued a goal to optimize the use of the reserve component by ensuring the reserve workforce had the necessary training and support. The Coast Guard shifted governance of the reserve component under the Deputy Commandant for Mission Support; however under this structure, the Coast Guard did not take into account the difference between the reserves workforce being considered a program as opposed to a distinct component of the United States military. As such, in 2018, the Coast Guard chartered a project team to evaluate the state of the reserve component’s governance and develop alternate options to better integrate the reserves into the Deputy Commandant for Operations. In 2019, the Coast Guard integrated its reserve component into its Deputy Commandant for Operations governance structure. Officials told us that the goals for the new reserve component organization are to provide headquarters decision-makers enhanced visibility of operational readiness, competencies assigned and attained, and to use predictive modeling to look 2 or 3 years ahead to anticipate readiness posture and administrative readiness. They noted that achieving these goals relies on better data collection and developing metrics that can capture Coast Guard-wide information. Officials told us that, as of June 2019, the new organization was at initial operational capacity using existing staff. Table 3 provides our assessment of the extent to which the Coast Guard’s actions to reorganize its reserve component governance structure had applied key reform practices and examples of actions and deficiencies. Appendix IV: Coast Guard Manpower Requirements Determination Process Completed from Calendar Years 2014 - 2019 From calendar years 2014 through 2019, the Coast Guard implemented the manpower requirements determination process for 30 of its 158 unit types. The Coast Guard completed manpower requirements analyses for 30 unit types. Of these 30 manpower requirements analyses, the Coast Guard completed required manpower requirements determinations— establishing a manpower requirement—for only four of these 30 unit types. Table 4 shows the most recent manpower requirements analyses, and corresponding determinations, completed from calendar years 2014 through 2019. Appendix V: Comments from the Department of Homeland Security Appendix VI: GAO Contact and Staff Acknowledgements GAO Contacts Staff Acknowledgements In addition to the above contacts, Jason Berman (Assistant Director), Jennifer Kamara (Analyst-in Charge), Ben Atwater, Susan Czachor, Elizabeth Dretsch, Eric Hauswirth, Tracey King, Daniel Kuhn, and Kevin Reeves made key contributions to this report.


Introduction The present structure of congressional oversight of the Intelligence Community (IC) largely resulted from investigations by two congressional committees in the 1970sâin the Senate, chaired by Idaho Senator Frank Church, and in the House, chaired by Representative Otis Pikeâthat suggested a need for permanent committees in each chamber: today's Senate Select Committee on Intelligence (SSCI) and the House Permanent Select Committee on Intelligence (HPSCI). It is important to note, however, that oversight of intelligence is a function of more than just the two congressional intelligence committees. Ten other committeesâthe Armed Services, Foreign Affairs/Foreign Relations, Homeland Security, Judiciary, and Appropriations committees of both chambersâexercise oversight responsibility to varying degrees over intelligence programs or IC elements that fall under their jurisdiction. The Church and Pike committees' oversight focused primarily on two themes: investigation of past abuses and IC organizational reform. Over the succeeding years those efforts have been both beneficial and occasionally burdensome. In protecting against the IC's abuse of its authorities, Congress has helped ensure intelligence activities were legal, ethical and consistent with American values. Congress's influence in IC organizational reform has resulted in improved performance and accountability. On other occasions, however, congressional oversight has tended toward micromanagement resulting in strains in the relationship with the IC. This report posits a potential framework for congressional oversight of intelligence-related programs and activities using the existing committee structure and notification standards for the most sensitive intelligence activities: covert action and clandestine intelligence collection. The framework may assist Congress in assessing the premises justifying each of these activities, their impact on national security, operational viability, funding requirements, and possible long-term or unintended consequences. Unlike areas with a broad public following, such as health care, veterans' services, and agriculture, intelligence programs and activities are generally classified, receive little public exposure, and have no natural public constituency. Highly classified covert action and clandestine intelligence programs do not often have visibility outside of Congress. Congressional oversight, therefore, provides one of the few meaningful checks on the President's execution of intelligence policy and programs that may have significant bearing on U.S. foreign relations and national security. Background Among the recommendations of the National Commission on Terrorist Attacks upon the United States (the "9/11 Commission") were those aimed at strengthening intelligence oversight. Since the Church and Pike committees of the 1970s, Congress occasionally has been able to refine its oversight of the IC. However, it has not been able to sustain its early momentum. As the Final Report of the 9/11 Commission put it, "...the oversight function of the Congressâ¦diminished over time. In recent years, traditional review of the administration of programs and implementation of laws has been replaced by 'a focus on personal investigations, possible scandals, and issues designed to generate media attention.' The unglamorous but essential work of oversight has been neglected, and few members past or present believe it is performed well....[T]he executive branch needed help from Congress in addressing the questions of counterterrorism strategy and policy, looking past day-to-day concerns....Congress...often missed the big questionsâas did the executive branch." Since 9/11, the Senate especially has made progress toward following through with organizational reform of the oversight process, following through on several of the 9/11 Commission's recommendations. S.Res. 445 (108 th Congress) amended Senate rules governing intelligence oversight ( S.Res. 400 ) aimed at increasing the authority of the SSCI relative to the standing committees, promoting bipartisanship, and building expertise. However, a number of factors have complicated Congress's efforts to improve oversight. This poses risks to national security when involving the most sensitive aspects of intelligenceâcovert action and clandestine activitiesâdue to their potential impact on U.S. foreign relations. Moreover, greater integration of military operations and intelligence activities has resulted in some confusion over the proper congressional jurisdiction for exercising oversight on Capitol Hill. Congress has expressed concern that the Department of Defense's (DOD) overuse of terms that are not defined in statute, such as operational preparation of the environment (OPE), to describe operations that may resemble intelligence activities allows DOD to circumvent the more stringent oversight requirements of the congressional intelligence committees. Despite these challenges, congressional oversight remains an important check on policy and decisions of the executive branch, to insure intelligence programs and activities are ethical, legal and properly aligned with U.S. national security and foreign policy objectives. Congressional oversight of covert action can be organized around a framework of five issue areas: (1) the activity's statutory parameters, (2) U.S. national security interests, (3) U.S. foreign policy objectives, (4) funding and implementation, and (5) risk assessment. These categories enable Congress to analyze and assess the specific elements of each activity from a strategic point of view. By extension, Congressional oversight of anticipated clandestine intelligence activities that might also shape the political, economic or military environment abroad can apply the same framework and, as with oversight of covert action, address the risk of compromise, unintended consequences, and loss of life. A conceptual framework for congressional oversight of covert action begins with its statutory definition: Covert action is codified as "an activity or activities of the United States Government to influence political, economic, or military conditions abroad, where it is intended that the role of the United States Government will not be apparent or acknowledged publicly." There are a number of exceptions in the statutory definition of covert action; these include some activities that could use clandestine methodology. Exceptions include activities primarily intended to collect intelligence; traditional counterintelligence activities; traditional military activities, or support to traditional military activities; traditional law enforcement activities, or routine support to law enforcement; and traditional diplomatic activities. How these exceptions are defined and applied to actual practice is not always straightforward and can complicate congressional oversight. For example, Congress has expressed concern that DOD too frequently applies the term traditional military activities to describe operations that in many respects resemble covert action. This is important insofar as it results in different committees being informed of the activity and different standards for the timeliness of notification. Oversight also requires a solid grasp of the U.S. national security interests and foreign policy objectives that each administration details its National Security Strategy, National Defense Strategy, and other strategy and policy documents. Covert action statutorily must support "identifiable foreign policy interests of the United States." Although not required by statute, it would be logical for clandestine intelligence (and military) activities that do not constitute covert action but have in common a high risk of compromise of sources and methods, a high impact on U.S. foreign relations, and a potential for the loss of life also to support identifiable (clearly articulated, documented) foreign policy objectives expressly. Moreover, congressional overseers may wish to identify or have expressly identified for them, the executive branch's assumptions about the international environment since these assumptions influence policy that in turn, influences decisions on covert action and clandestine activities. A Framework for Oversight; Lines of Inquiry for Congress Although Congress has no statutory prerogative to veto covert action when informed through a presidential finding, it can influence conduct of an operation through the exercise of congressional constitutional authority and responsibilities to authorize war, legislate, appropriate funds, and otherwise interact with the executive branch. As former CIA Inspector General L. Britt Snider wrote, If the committees do not support a particular operation or have concerns about aspects of it, an administration would have to think twice about proceeding with it as planned. If it is disclosed or ends in disaster, the administration will want to have had Congress on board. If it is going to last more than a year, the committees' support will be needed for continued funding. The committees are also likely to be better indicators of how the public would react if the program were disclosed than the administration's in-house pundits. As congressional oversight committees assess each impending covert action from a strategic point of view, Congress may wish to organize its review using the following five issue areas: 1. the activity's statutory parameters; 2. U.S. national security interests; 3. U.S. foreign policy objectives; 4. funding and implementation; and 5. risk of compromise, failure, loss of life, and unintended consequences. By extension, oversight of anticipated clandestine intelligence activities that might also shape the political, economic, or military environment abroad can apply the same framework, and, like oversight of covert action, address the risk of compromise, unintended consequences, and loss of life. Statutory Parameters of the Activity Section 3093(a)(5) of Title 50, U. S. Code specifies that "a finding [for a covert action] may not authorize any action that would violate the Constitution or any statute of the United States." Congressional oversight, then, ensures a covert action does not violate the law, to include any domestic law enacted to fulfill the terms of a non-self-executing treaty. Questions for Congress Does the covert action or clandestine intelligence activity violate domestic U.S. law? Does the activity violate any domestic law connected to a non-self-executing treaty? Is the activity likely to violate international law? What are the national security implications of conducting a covert action that may violate international law? Is the risk justified by the operation's importance to U.S. national security? Would Congress likely choose to provide limitations on the covert action through legislation? Does the covert action or clandestine activity, if conducted during hostilities, comply with the laws of armed conflict in accordance with DOD policy? National Security Interests Congressional oversight of covert action is generally recognized to be especially important to ensuring proper checks and balances, particularly under circumstances in which it is likely that no one outside of a small number of authorized intelligence professionals will know anything about the covert action or clandestine activity. Yet, the 9/11 Commission observed, Congress had a distinct tendency to push questions of emerging national security threats off its own plate, leaving them for others to consider. Congress asked outside commissions to do the work that arguably was at the heart of its own oversight responsibilities. Oversight, in accordance with notification requirements of Title 50, enables Congress to provide a timely check on the development of a covert action or clandestine intelligence activity that might have serious flaws. Maintaining necessarily tight security surrounding planning for intelligence activities may present a challenge, because the few individuals outside the intelligence community with access may offer only limited perspective, overlook essential details, and too easily accept premises that might not bear up against broader scrutiny. Questions for Congress What are the underlying premises of the threat and the international or regional environment that justify the covert action or clandestine activity? Is there any precedent for the particular covert action outlined in the presidential finding? If so, what were the similarities and differences with the covert action described in the current finding that may give perspective regarding the risk to U.S. personnel, unintended consequences, and implications for U.S. national security? What are the implications of involving third parties or countries in the covert action? Does the covert action or clandestine activity conform to American and democratic values, and promote free and fair elections? What are plausible long-term unintended consequences of the covert action? Do these possible long-term effects challenge the premises for conducting the covert action in the first place? What might be some plausible second/third order effects of not conducting the covert action? Foreign Policy Objectives Section 3093(a) of Title 50, U. S. Code specifies "[T]he President may not authorize the conduct of a covert action by departments, agencies, or entities of the United States Government unless the President determines such an action is necessary to support identifiable foreign policy objectives of the United States and is important to the national security of the United States." Questions for Congress Is the covert action being initiated as an instrument of policy in support of "identifiable" foreign policy objectives elaborated in the National Security Strategy? Is covert action a viable means of achieving these objectives? Are there other means by which the United States might achieve the same objectives involving less risk? Is the covert action consistent with American values to the extent that it is something the American people would support (if the activity were known to the public)? Funding and Implementation Congress can provide another level of review to ensure important details for successfully implementing the activity are not overlooked. Moreover, Congress's constitutional responsibility for appropriating funds extends to its oversight of sensitive intelligence activities like covert action. As former CIA Director and former Member of Congress Leon Panetta once remarked, "I do believe in the responsibility of the Congress not only to oversee our operations but to share in the responsibility of making sure that we have the resources and capability to help protect this country." Questions for Congress Is the department or agency named in the presidential finding as the lead agency for the covert action best suited to achieve the objectives? Are the operational elements planned for the covert action comprehensive and developed to achieve tactical success? Is the covert action or clandestine activity sufficiently funded over its projected duration to achieve the objectives? Risk Assessment "The executive branch is chiefly concerned with achieving the objectives of the president, whatever they might be. Because of this, it is sometimes tempted to downplay the risk and accentuate the gain." Congress's relative distance from conceiving and planning the activity may enable it to provide more dispassionate risk assessment and more tempered analysis of likely outcomes. Questions for Congress Does the covert action involve an unacceptable risk of escalating into a broader conflict or war? In the event of an unauthorized or untimely disclosureâor a popular perception of U.S. involvementâwhat are the risks to U.S. national security, U.S. personnel, or relations with states in the region? What are the consequences of failure of the covert action or clandestine intelligence activity to U.S. lives, U.S. national security, and relations with states in the region? If U.S. Armed Forces are involved, is the covert action or clandestine activity being conducted such that U.S. Armed Forces retain full protection under the terms of the Geneva Conventions? Is it plausible for the U.S. role to remain secret and deniable? Or is there substantial or unacceptable risk of compromising U.S. sponsorship to the detriment of U.S. national security? What risks does the covert action or clandestine activity pose to uninvolved American citizens who might be in the vicinity? An Iterative Process Statute requires the President update Congress with notifications of changes in conditions from those described in the original notification of a covert action. Congressional oversight consequently extends to periodically reviewing changes in the operational environment on the ground that may suggest a different outcome, a change in strategy, a shift in U.S. interests, or the development of unintended consequences. Along these lines, Â§3093(d)(1) and (2) of Title 50 U. S. Code includes the following provision: The President shall ensure that the congressional intelligence committees, or, if applicable, [the Gang of Eight], are notified in writing of any significant change in a previously approved covert action, or any significant undertaking pursuant to a previously approved finding, in the same manner as findings are reported pursuant to subsection (c). In determining whether an activity constitutes a significant undertaking for these purposes, the President shall consider whether the activity- involves significant risk of loss of life; requires an expansion of existing authorities, including authorities relating to research, development, or operations; results in the expenditure of significant funds or other resources; requires notification; gives rise to a significant risk of disclosing intelligence sources or methods; or presents a reasonably foreseeable risk of serious damage to the diplomatic relations of the United States if such activity were disclosed without authorization. Former CIA Inspector General L. Britt Snider has suggested that Congress, in carrying out its oversight responsibility, might be vulnerable to failure to review the premises and conditions for the covert action that may have changed, perhaps significantly, subsequent to the initial notification. The risk, as articulated by Snider is that "If members are satisfied with what they hear from administration witnesses [during the initial notification], not only will they acquiesce in the implementation of the operation, they are apt to devote less attention to it down the road." To guard against this outcome, this provision of the covert action statute underscores the importance of being alert to the possible tactical, political, and environment changes that warrant continued oversight to ensure the activity continues to be in the U.S. national interest. Questions for Congress Do the original premises or environmental conditions justifying the activity remain valid? Have there been any outcomes to suggest the intelligence activity is achieving its intended result? Does the activity continue to have the funding necessary to be effective? Have there been any changes in conditions on the ground that might influence a significant change in how the activity is executed? Is there an increase in the risk of premature or unauthorized disclosure? Do American citizens face a greater threat of exposure? Does the risk involved remain acceptable? Does the activity still conform to the statutory guidelines on the conduct of covert action or significant clandestine intelligence activities?