In June 2013, State doubled the number of countries for which  it required FACT training. Most State and USAID Assigned Personnel Completed FACT Training, but Gaps in State Department Data Prevent Compliance Assessment for Short-Term TDY Personnel

Using data from multiple sources related to State and USAID assigned  personnel, we determined that 675 of 708 State personnel and all of the  143 USAID personnel on assignments to the designated high-threat  countries on March 31, 2013, were in compliance with the FACT training  requirement. We found 33 State assigned personnel who were not in  compliance with the mandatory training requirement. We were unable to  assess compliance among short-term TDY personnel because of gaps in  State’s data. According to GAO’s Standards for Internal Control in the Federal  Government, program managers need operating information to determine  whether they are meeting compliance requirements. First, State does not systematically maintain data on the  universe of U.S. personnel on short-term TDY status in designated high- threat countries who are required to complete the training. State Department’s Guidance and Management Oversight of Compliance with FACT Training Requirement Has Weaknesses

Several weaknesses in State oversight of personnel’s compliance with  the FACT training requirement limit State’s ability to help ensure that all  personnel subject to the requirement are prepared for service in high- threat countries. State’s Policy and Guidance on FACT Training Requirement Are Outdated, Inconsistent, or Unclear

State has not updated the Foreign Affairs Manual to reflect changes  made to the FACT training requirement in June 2013. Moreover, we found that State’s guidance  regarding the required frequency of FACT training is unclear. State’s Foreign Affairs Manual Has Not Been Updated

As of January 2014, State had not updated its Foreign Affairs Manual to  reflect its policy change, announced in June 2013, that (1) increased the  number of designated high-threat countries requiring FACT training from  9 to 18, (2) changed the cumulative-days threshold for the FACT training  requirement from 30 or more cumulative days in one high-threat country  to more than 45 cumulative days in one or more of the countries, and (3)  described the conditions that indicate whether eligible family members  must complete the course. State does not verify compliance for personnel assigned to the  other designated high-threat countries (see fig. While State’s Foreign Affairs Manual notes that it is the employee’s  responsibility to ensure compliance with the FACT training requirement, it  also notes that agency management is responsible for ensuring adequate  controls over all agency operations. To strengthen State’s ability to ensure that U.S. civilian personnel are in  compliance with the FACT training requirement, we recommend that the  Secretary of State  identify a mechanism to readily determine the universe of assigned  U.S. civilian personnel under chief-of-mission authority who are  required to complete FACT training; identify a mechanism to readily determine the universe of short-term  TDY U.S. civilian personnel who are required to complete FACT  training—specifically, required personnel who have spent 45 days or  more in the designated high-threat countries in a calendar year; ensure that eCC instructions regarding the documentation of the  FACT training requirement for short-term TDY personnel are  consistent for all designated high-threat countries;  take steps to ensure that management personnel responsible for  assigning personnel to designated high-threat countries consistently  verify that all assigned U.S. civilian personnel under chief-of-mission  authority who are required to complete FACT training have completed  it before arrival in the designated high-threat countries; take steps to ensure that management personnel responsible for  granting country clearance consistently verify that all short-term TDY  U.S. civilian personnel under chief-of-mission authority who are  required to complete FACT training have completed it before arrival in  the designated high-threat countries; and monitor or evaluate overall levels of compliance with the FACT  training requirement among U.S. civilian personnel under chief-of- mission authority who are subject to the requirement. State fundamentally concurred with our recommendations. Objective 2: State’s and USAID’s Oversight of Their Personnel’s Compliance with the FACT Training Requirement

To assess State and USAID’s management oversight of assigned and  short-term TDY personnel’s compliance with the FACT training  requirement, we reviewed relevant documents from State and USAID,  including State’s Foreign Affairs Manual, USAID’s Automated Directives  System, and other standard operating procedures.
Why GAO Did This Study

U.S personnel engaged in efforts overseas have faced numerous threats to their security. To mitigate these threats and prepare U.S. personnel for work in high-threat environments, State established a mandatory requirement that specified U.S. executive branch personnel under chief-of-mission authority and on assignments or short-term TDY complete FACT security training before arrival in a high-threat environment. This report examines (1) State and USAID personnel's compliance with the FACT training requirement and (2) State's and USAID's oversight of their personnel's compliance. GAO reviewed agencies' policy guidance; analyzed State and USAID personnel data from March 2013 and training data for 2008 through 2013; reviewed agency documents; and interviewed agency officials in Washington, D.C., and at various overseas locations. This public version of a February 2014 sensitive report excludes information that State has deemed sensitive.

What GAO Found

Using data from multiple sources, GAO determined that 675 of 708 Department of State (State) personnel and all 143 U.S. Agency for International Development (USAID) personnel on assignments longer than 6 months (assigned personnel) in the designated high-threat countries on March 31, 2013, were in compliance with the Foreign Affairs Counter Threat (FACT) training requirement. GAO found that the remaining 33 State assigned personnel on such assignments had not complied with the mandatory requirement. For State and USAID personnel on temporary duty of 6 months or less (short-term TDY personnel), GAO was unable to assess compliance because of gaps in State's data. State does not systematically maintain data on the universe of U.S. personnel on short-term TDY status to designated high-threat countries who were required to complete FACT training. This is because State lacks a mechanism for identifying those who are subject to the training requirement. These data gaps prevent State or an independent reviewer from assessing compliance with the FACT training requirement among short-term TDY personnel. According to Standards for Internal Control in the Federal Government , program managers need operating information to determine whether they are meeting compliance requirements.
State's guidance and management oversight of personnel's compliance with the FACT training requirement have weaknesses that limit State's ability to ensure that personnel are prepared for service in designated high-threat countries. These weaknesses include the following:
State's policy and guidance related to FACT training—including its Foreign Affairs Manual , eCountry Clearance instructions for short-term TDY personnel, and guidance on the required frequency of FACT training—are outdated, inconsistent, or unclear. For example, although State informed other agencies of June 2013 policy changes to the FACT training requirement, State had not yet updated its Foreign Affairs Manual to reflect those changes as of January 2014. The changes included an increase in the number of high-threat countries requiring FACT training from 9 to 18.
State and USAID do not consistently verify that U.S. personnel complete FACT training before arriving in designated high-threat countries. For example, State does not verify compliance for 4 of the 9 countries for which it required FACT training before June 2013.
State does not monitor or evaluate overall levels of compliance with the FACT training requirement.
State's Foreign Affairs Manual notes that it is the responsibility of employees to ensure their own compliance with the FACT training requirement. However, the manual and Standards for Internal Control in the Federal Government also note that management is responsible for putting in place adequate controls to help ensure that agency directives are carried out. The gaps in State oversight may increase the risk that personnel assigned to high-threat countries do not complete FACT training, potentially placing their own and others' safety in jeopardy.

What GAO Recommends

GAO is making several recommen-dations to improve oversight of compliance with the FACT training requirement. These include identifying a mechanism to readily determine the universe of U.S. personnel subject to the requirement, updating State's policy manual to reflect changes made to the requirement in June 2013, consistently verifying that all U.S. civilian personnel have completed FACT training before arriving in designated high-threat countries, and monitoring compliance with the requirement. State concurred with the recommendations and stated that it will take steps to address them. USAID did not specifically agree or disagree but noted it plans to take additional steps.