NMB Has Made Progress, but Has Not Yet Fully Implemented GAO’s 2013 Recommendations

NMB has made some progress in implementing each of the seven  recommendations we made in December 2013. NMB Has Not Established Procurement Policies and Processes That Reflect Its New Procurement Environment

NMB is following key procurement practices in 2 of 3 areas that our prior  work on assessing the acquisition function at federal agencies identified  as promoting agencies’ efficient, effective, and accountable procurement  functions—organizational alignment and leadership; and knowledge and  information management. However, additional actions are needed to fully respond  to those recommendations. Without fully  implementing these recommendations, NMB cannot ensure that its limited  resources are effectively targeted toward its highest priorities. Moreover,  it may be missing opportunities to improve performance and mitigate risks  in its program and management areas. NMB agreed with our recommendation to develop and implement policies  and processes to reflect the agency’s current procurement environment  and indicated it is taking steps to do so. However, because NMB’s interagency agreement with the Fiscal Service  for performance of certain procurement functions does not absolve NMB  of its responsibility to develop policies and processes as called for by  internal control standards and best practice, NMB must develop its own  set of complementary policies and processes to ensure the agency meets  its needs through efficient, effective, and accountable procurement  functions. Appendix I: Objectives, Scope, and Methodology

The FAA Modernization and Reform Act of 2012 included a provision for  us to evaluate and audit the programs, operations, and activities of the  National Mediation Board (NMB) every 2 years. Our first report was  issued in December 2013. This is the second review of NMB and this  report examines the extent to which NMB:  1.  has implemented each of our December 2013 recommendations, and  2.  has incorporated key procurement practices. To address our research objectives, we reviewed key NMB documents  and compared those documents with relevant federal laws, regulations,  guidance, and related leading practices identified in our previous work  (see table 3). We interviewed NMB officials and current board members.
Why GAO Did This Study

NMB was established under the Railway Labor Act to facilitate labor relations for railroads and airlines by mediating and arbitrating labor disputes and overseeing union elections. The FAA Modernization and Reform Act of 2012 included a provision for GAO to evaluate NMB programs and activities every 2 years. GAO's first report under this provision, issued in December 2013, included seven recommendations for NMB based on assessments of policies and processes in several management and program areas.
This second report examines the extent to which NMB has 1) implemented recommendations made by GAO in December 2013, and 2) incorporated key procurement practices. GAO reviewed relevant federal laws, regulations, and NMB documents, such as its strategic and workforce plans; and contracting data for fiscal years 2014-2015; and interviewed NMB officials.

What GAO Found

The National Mediation Board (NMB) has made some progress in addressing the seven recommendations GAO made in December 2013; however, additional actions are needed to fully implement those recommendations and strengthen operations (see table). Without full implementation, NMB lacks reasonable assurance that its limited resources are effectively targeted and may be missing opportunities to improve performance and mitigate risks in program and management areas.
Source: GAO analysis of NMB documents and interviews with officials. | GAO-16-240
NMB is following some key procurement practices that GAO has identified in prior work. However, NMB has not developed and implemented written policies and processes—consistent with internal control standards and best practice—that reflect its new interagency agreement with the Department of the Treasury for the performance of certain procurement functions. Without this documentation NMB cannot ensure the use of consistent processes in its new procurement environment.

What GAO Recommends

GAO recommends that NMB develop and implement written policies and processes to reflect its current procurement environment. NMB agreed with the recommendation and indicated it would take steps to implement it.