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20 of 38: Leadership Capacity as a Mission Risk, in GAO’s Own Words

By Gotham Government Services

If you are building a budget argument for leadership development inside a federal agency, the strongest sentence available to you was not written by a consultant. It was written by the Government Accountability Office, and it is four words longer than a tweet.

“Twenty areas are on GAO’s High-Risk List in part due to skills gaps or an inadequate number of staff.” — GAO-25-107743, February 25, 2025

The edition matters, so state it precisely: the current High-Risk List is High-Risk Series: Heightened Attention Could Save Billions More and Improve Government Efficiency and Effectiveness (GAO-25-107743), published February 25, 2025. It identifies 38 high-risk areas across the federal government. GAO updates the list biennially, at the start of each new Congress; as of this writing the February 2025 edition remains current, and Comptroller General Dodaro’s 2026 testimony (GAO-26-108824) still cites the same 38 areas.

Twenty of thirty-eight. More than half of the federal government’s most serious, most persistent vulnerabilities are on that list at least partly because of people — who is there, and what they can do. Not systems. Not process. People.

Twenty-Five Years of the Same Finding

Strategic Human Capital Management is not a recent addition. GAO is explicit about the vintage:

“Strategic human capital management, specifically the federal government’s efforts to address government-wide and agency specific skills gaps, has been on GAO’s High-Risk List since 2001.” — GAO-23-105528, February 27, 2023

Twenty-five years is long enough to rule out most of the comfortable explanations. This is not a hiring-freeze artifact, not a single administration’s policy choice, not a budget cycle that went badly. A finding that survives six presidential terms and thirteen Congresses is structural.

The 2025 update reinforces the point by omission. In GAO’s ratings table, Strategic Human Capital Management shows no change since 2023 — neither progress nor regression. Ten areas improved in that window and three declined. Human capital simply held still.

What GAO Means by “Skills Gap” — and Why It Is Not Just Headcount

The definition is the useful part, and most internal budget memos skip it. GAO writes:

“A skills gap may consist of an insufficient number of individuals, individuals without the appropriate skills, abilities, or behaviors to perform the work successfully; or both.” — GAO-23-105528

Read the word “behaviors” slowly. GAO’s own construction of a mission risk includes conduct — how people exercise judgment, coordinate across boundaries, and make decisions under ambiguity. That is the territory leadership development actually occupies. It is inside GAO’s definition, not adjacent to it.

GAO and OPM have identified government-wide gaps in fields including human resources, science, technology, engineering, mathematics, cybersecurity, and acquisitions. Those are the occupational categories. The high-risk areas are where the consequences land — in weapons systems acquisition, IT acquisition and management, program integrity, and health care delivery, among the thirty-eight on the list. GAO does not publish which twenty of those areas its skills-gap finding covers, so read these as illustrations of what is at stake rather than as a roster.

GAO publishes the count but not the roster. The 2025 High-Risk Series states that “[t]wenty areas are on GAO’s High-Risk List in part due to skills gaps or an inadequate number of staff,” without identifying which twenty of the thirty-eight they are. The practical consequence for an agency is that “are we one of them?” has to be answered from the individual high-risk area write-up covering your mission, not from a published list.

The Finding About OPM Itself

Here is the part that changes the internal conversation. Agencies build workforce plans on OPM guidance and OPM capacity. In February 2023, GAO published a report whose title states the problem in full: Federal Workforce: OPM Advances Efforts to Close Government-wide Skills Gaps but Needs a Plan to Improve Its Own Capacity (GAO-23-105528).

“…in 2022, an independent workforce assessment found that OPM had its own skills gaps in key capabilities… According to the assessment and GAO’s analysis, this could compromise OPM’s ability to implement its strategic objectives related to closing government-wide skills gaps.” — GAO-23-105528

GAO made two recommendations. OPM concurred with both. The second — document and monitor the risks those gaps pose to OPM’s strategic objectives — was implemented and closed in June 2024. The first, designated a Priority Recommendation, asked OPM to establish an action plan to address its own skills gaps. That one is still open. GAO’s recommendation tracker records that as of June 2026, OPM “continues to reassess the path forward and identify potential funding sources for enterprise workforce development initiatives and efforts to close skills gaps.”

For an agency leader, the operational read is direct: the central body your workforce strategy depends on has a documented capacity gap of its own, and the corrective action is unfunded and in reassessment. Waiting for centralized guidance to arrive is not a neutral posture. It is a risk position, and it is one you now have a citation for.

Reframing the Line Item: From Discretionary to Risk Mitigation

GAO publishes five criteria for removing an area from the High-Risk List. Two of the five are about people:

“Leadership Commitment. Demonstrated strong commitment and top leadership support.”
“Capacity. Agency has the capacity (i.e., people and resources) to resolve the risk(s).” — GAO High-Risk List criteria

The other three — action plan, monitoring, demonstrated progress — describe management discipline. None of the five is a technology criterion. An agency cannot buy its way off the High-Risk List with a system procurement, because two of the exit conditions are conditions of its leadership bench.

Be precise about what this does and does not establish. GAO does not recommend leadership development programs. It does not endorse curricula, vendors, or coaching models, and any argument that implies otherwise will not survive contact with a skeptical reviewer. What GAO does establish is narrower and more durable: leadership commitment and organizational capacity are formal conditions of exiting high-risk status, and skills gaps — including behavioral ones — are a named driver of that status across twenty areas.

That distinction is the whole budget argument. A leadership development line defended as engagement, morale, or retention competes against mission and loses. The same line defended as capacity-building against a named, GAO-designated high-risk area is mission work with an external auditor already on record about the risk.

Making the Case Internally — in GAO’s Language, Not a Vendor’s

The argument works because it is not yours. Build it that way.

  1. Name the high-risk area exactly. Use GAO’s published title from the 2025 list — not a paraphrase. Reviewers check.
  2. Quote the criteria, not the brochure. Cite “Leadership Commitment” and “Capacity” verbatim and show where your area currently sits: met, partially met, or not met.
  3. Use GAO’s definition of a skills gap, including “behaviors.” It is the sentence that connects leadership capability to a documented mission risk without a single unsupported claim.
  4. Anchor the scale. GAO reports that progress on high-risk areas produced roughly $759 billion in financial benefits over fiscal years 2006–2024, including about $84 billion in the two years since the 2023 update. That is GAO’s own evidence that closing these gaps returns money.
  5. Acknowledge the OPM dependency. Cite the open Priority Recommendation. It preempts the obvious counter — “shouldn’t we wait for OPM guidance?” — with GAO’s own record.
  6. State what would count as demonstrated progress. GAO’s fifth criterion is not aspiration; it is evidence. Define the measure before you ask for the money, and you have written half of next year’s justification.

None of this requires overstating the record. The strength of the argument comes from restraint — from quoting an independent auditor accurately and letting the count carry the weight. Twenty of thirty-eight. Human capital on the list since 2001. No change since 2023. The oversight body that grades federal performance has already written your premise. The work is citing it correctly.

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