INTRAGOVERNMENTAL 

REVOLVING FUNDS

Commerce Departmental 

and Census Working 

Capital Funds Should 

Better Reflect Key 

Operating Principles

Report to the Subcommittee on 

Commerce, Justice, Science, and 

Related Agencies, Committee on

Appropriations, House of 

Representatives

November 2011

GAO-12-56

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-56, a report to the 

Subcommittee on Commerce, Justice, 

Science, and Related Agencies, Committee on 

Appropriations, House of Representatives 

November 2011 

INTRAGOVERNMENTAL REVOLVING FUNDS

Commerce Departmental and Census Working 

Capital Funds Should Better Reflect Key Operating 

Principles

Why GAO Did This Study

Agencies can improve their efficiency 

through the use of shared services, 

which are often financed through 

intragovernmental revolving funds 

(IRF). GAO was asked to (1) identify 

key operating principles the Commerce 

Departmental and Census Bureau

Working Capital Funds (WCF), which 

are one type of IRF, should follow to 

ensure appropriate tracking and use of 

federal funds and (2) evaluate how

departmental and Census policies and 

procedures for managing these WCFs 

reflect these principles. GAO identified 

four key operating principles based on 

a review of governmentwide guidance 

on business principles, internal 

controls, managerial cost accounting, 

and performance management. GAO 

also discussed the reasonableness of 

the principles with staff of the two 

WCFs and the Office of Management 

and Budget; these staff generally found 

the principles to be reasonable. GAO 

reviewed WCF authorizing legislation 

and statutory authorities, analyzed 

agency policies and data, and 

interviewed agency officials. 

What GAO Recommends

GAO is making seven 

recommendations to improve the 

management of the two WCFs, 

including updating and consolidating 

WCF guidance, establishing a process 

to measure WCF performance, and 

examining opportunities to consolidate 

certain WCF services. The Commerce 

Secretary agreed with all of our 

findings and recommendations and 

has directed managers of both the 

departmental WCF and the Census 

WCF to begin implementing GAO’s

recommendations.

What GAO Found 

Four key operating principles offer a framework for effective WCF management: 

• Clearly delineate roles and responsibilities 

• Ensure self-sufficiency by recovering the agency’s actual costs 

• Measure performance

• Build in flexibility to obtain customer input and meet customer needs

Commerce and Census guidance do not identify the roles and responsibilities of 

all key WCF personnel. While all involved had a clear informal understanding of

who is responsible for managing the Departmental WCF, Commerce’s guidance 

does not discuss its CFO Council—an entity with an important role related to 

WCF increases and changes. Census lacks a process to coordinate and 

consolidate information managed by disparate divisions and ensure appropriate 

tracking of funds. There are also opportunities for the agencies to achieve 

greater management efficiencies by consolidating certain WCF services. 

Commerce has a transparent process to ensure recovery of actual costs. 

However, Census’ process could be more transparent. The Commerce

Departmental WCF’s rate setting and review processes are clearly described, 

coordinated, and designed to recover actual annual costs. Entities such as the

Commerce CFO Council and algorithm review group help to facilitate shared 

understanding among fund managers, customers, and service providers. Census 

has a fragmented and limited description of its processes and lacks a formal 

process to communicate with customers. Census customers GAO spoke with

had a mixed understanding about how certain WCF costs are determined, 

limiting their ability to make appeals and suggest improvements. 

Both WCFs could benefit from performance measures that assess operational 

effectiveness. Commerce and Census have identified performance measures 

related to organizational strategic goals. However, neither has established WCF

operational performance measures such as responsiveness to customer inquiries 

and billing error rates. Moreover, both WCFs support similar management and 

administrative services that could potentially be consolidated.

Both WCFs obtain customer input and have flexibility to adjust to customer 

needs, but challenges exist. In general, customers GAO interviewed said they 

had regular and ongoing discussions with fund managers or service providers. At 

Commerce, its CFO Council and WCF managers periodically assess and shift 

resources to address changes in customer needs and prioritize requests for 

services. However, the statutory cap on one bureau’s payments into the WCF 

limits the level of services that can be provided to all Commerce bureaus. To 

provide services beyond the capacity of the WCF, Commerce enters into a 

memorandum of understanding with specific customers. The Census WCF’s 

ability to build and maintain an operating reserve helps to provide price stability 

for customers throughout the decennial census cycle when the costs of 

management and administrative services supported through the WCF fluctuate 

dramatically. Similar to Commerce, Census has the flexibility to provide 

additional services by billing customers directly. 

View GAO-12-56. For more information, 

contact Denise M. Fantone at (202) 512-6806 

or fantoned@gao.gov. 
Page i GAO-12-56 Intragovernmental Revolving Funds

Letter 1 

Background 3

Key Operating Principles Provide a Framework for Effective WCF 

Management 8

Principle 1: Clearly Delineate Roles and Responsibilities 11

Principle 2: Ensure Self-sufficiency by Recovering the Agency’s 

Actual Costs 14

Principle 3: Measure Performance 16

Principle 4: Build in Flexibility to Obtain Customer Input and Meet 

Customer Needs 18

Conclusions 20

Recommendations for Executive Action 21

Agency Comments and Our Evaluation 22

Appendix I Expanded Version of WCF Key Operating Principles 24

Appendix II Comments from the Department of Commerce 26

Appendix III GAO Contact and Staff Acknowledgments 27

Table

Table 1: Largest Customers of Services Supported by the 

Commerce Departmental and Census Working Capital 

Funds, Fiscal Year 2009 8

Figures

Figure 1: Overview of the Flow of Funds for the Commerce 

Departmental WCF 6

Figure 2: Overview of the Flow of Funds for the Census WCF 7

Figure 3: Working Capital Fund Key Operating Principles 10

Contents
Page ii GAO-12-56 Intragovernmental Revolving Funds

Abbreviations

BLS Bureau of Labor Statistics

CFO Chief Financial Officer

CBS Commerce Business System

HUD Department of Housing and Urban Development 

IRF Intragovernmental Revolving Fund

ITA International Trade Administration 

M&A Management and Administrative

MOU Memorandum of Understanding 

NIST National Institute of Standards and Technology

NOAA National Oceanic and Atmospheric Administration

OEB Office of Executive Budgeting

OMB Office of Management and Budget 

TAS Treasury Account Symbol

WCF Working Capital Fund

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Page 1 GAO-12-56 Intragovernmental Revolving Funds

United States Government Accountability Office 

Washington, DC 20548

November 18, 2011

The Honorable Frank R. Wolf

Chairman

The Honorable Chaka Fattah

Ranking Member

Subcommittee on Commerce, Justice, Science, and Related Agencies

Committee on Appropriations

House of Representatives

In an increasingly constrained budget environment, federal agencies are 

asked to operate as efficiently as possible. One way federal agencies can 

increase their efficiency is to share services, by consolidating services 

used by multiple organizations within an agency or more than one agency 

within a department. Consolidated services may be financed or supported 

through an intragovernmental revolving fund (IRF). IRFs, such as working 

capital funds (WCF), are primarily used to conduct business-like activities 

within and between federal agencies.

This report is the second in response to the Committee’s request to 

review IRFs and builds upon our work on the National Institute of 

Standards and Technology’s (NIST) Working Capital Fund and its 

interagency agreements.1

To identify key principles, we reviewed governmentwide guidance on 

business operating principles, internal controls, managerial cost 

In this report, we examined two WCFs—the 

Department of Commerce (Commerce Departmental) and Census 

Bureau (Census) WCFs—which collected approximately $143 million and 

$912 million respectively in fiscal year 2010 to support a variety of 

administrative and specialized activities. To analyze these funds, we (1) 

identified key operating principles these WCFs should follow to ensure 

the appropriate tracking and use of federal funds and (2) evaluated how 

departmental and Census policies and procedures for managing these 

WCFs reflect these principles.

 

1 GAO, Intragovernmental Revolving Funds: NIST’s Interagency Agreements and 

Workload Require Management Attention, GAO-11-41 (Washington, D.C.: Oct. 20, 2010).

 
 

Page 2 GAO-12-56 Intragovernmental Revolving Funds

accounting, and performance management.2 In addition, we met with the 

agency staff responsible for managing the two WCFs, as well as staff 

from the Office of Management and Budget (OMB) to obtain their views 

on the use of these principles to assess WCFs. Commerce Departmental, 

Census, and OMB staff generally found the principles to be reasonable. 

Moreover, our prior work on user fees, franchise funds,3

To evaluate each fund’s management against these key principles, we 

reviewed Commerce Departmental and Census WCF authorizing 

legislation and statutory authorities, supporting guidance and 

transactional data, and various budget documents and data from fiscal 

years 2001 through 2010. In addition, we analyzed policies and 

procedures for charging and monitoring WCF resources. We also met 

with budget and finance officials responsible for managing each WCF, as 

well as their major customers. We identified the funds’ largest customers 

based on the amounts they paid into the respective WCFs in fiscal year 

2009. We interviewed customer agencies’ program and budget officials to 

obtain their perspective on services they received, billing and payment 

methods, and communication with WCF managers.

performance 

management, and customer service also informed the development of 

these principles. Finally, we considered agency guidance and 

requirements.

During our review, we identified discrepancies between aggregate and 

the corresponding disaggregate amounts of funds collected in the Census 

WCF. A Census official explained that the aggregate amounts are 

reported externally, but the disaggregate amounts had to be created upon 

our request. We worked with Census to resolve the discrepancies in the 

data and received multiple data revisions that included unexplained 

adjustments. In the final analysis, we considered the data to be 

sufficiently reliable for the purpose of providing background information 

 

2 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999); Federal Accounting Standards Advisory Board, 

Statement of Federal Financial Accounting Standards 4: Managerial Cost Accounting 

Standards and Concepts (Washington, D.C.: July 31, 1995); GAO, Budget Issues: 

Franchise Fund Pilot Review, GAO-03-1069 (Washington, D.C.: Aug. 22, 2003) and GAO, 

Government Performance: GPRA Modernization Act Provides Opportunities to Help 

Address Fiscal, Performance, and Management Challenges, GAO-11-466T (Washington, 

D.C.: Mar. 16, 2011).

3 GAO-03-1069. 
 

Page 3 GAO-12-56 Intragovernmental Revolving Funds

on the relative size of WCF activity. We examined the rate-setting 

process for both WCFs; however, we did not independently verify whether 

the process resulted in the equitable distribution of costs among 

customers or in the recovery of actual costs.

We conducted our review from July 2010 through November 2011 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.

IRFs generally do not receive appropriations directly. Instead, they are 

accounts that may receive reimbursements and advances from other 

federal accounts. In addition, they may accept fees collected from 

nonfederal sources for the sale of government products or services. The 

use of IRFs to fund consolidated or shared services allows agencies to 

benefit from economies of scale or take advantage of specialized 

expertise that they may not have. The market-like atmosphere promoted 

by IRF-supported services is intended to create incentives for federal 

customers and managers to exercise cost control and economic restraint. 

IRF management affects the success of the programs they support.

Within the Department of Commerce (Commerce), there are six IRFs4

 

4 The six IRFs are: (1) the Commerce Departmental WCF, (2) the Commerce 

Departmental Franchise Fund, (3) the National Oceanic and Atmospheric Administration’s 

Damage Assessment and Restoration Revolving Fund, (4) the Census Bureau’s WCF, (5) 

the National Technical Information Service’s Revolving Fund, and (6) the National Institute 

of Standards and Technology’s WCF. 

that support either management and administrative services—such as 

building security and human capital management—or specialized 

services based on the unique nature of the agency’s mission. For 

example, Census maintains a nationwide survey infrastructure and has 

expertise and address lists that would be uneconomical for others to 

replicate. Thus, it conducts surveys on behalf of other organizations (e.g., 

Department of Housing and Urban Development’s (HUD) American 

Housing Survey and the Bureau of Labor Statistics’ (BLS) Consumer 

Expenditure Survey).

Background
 

Page 4 GAO-12-56 Intragovernmental Revolving Funds

The Commerce Departmental and the Census WCFs were established to 

support services and projects that are performed more advantageously 

when centralized, such as information technology services and 

acquisition management.5

Three entities play important roles in the management of the Commerce 

Departmental WCF. First, the Commerce Office of Executive Budgeting 

(OEB) is responsible for overall management of the Commerce 

Departmental WCF. Second, the algorithm review group, which includes 

representatives from the fund’s customer bureaus and OEB, convenes 

every other year to review rate-setting formulas. At this meeting, service 

providers present their billing methods and implement any changes to the 

rate-setting formulas that are agreed upon within the group. Finally, the 

Commerce Chief Financial Officer Council (Commerce CFO Council) is 

comprised of the CFOs from each of Commerce’s bureaus, giving each 

customer bureau a “seat at the table.” This Commerce CFO Council has 

an important role related to WCF increases and changes to the 

algorithms used to determine charges. It meets at least annually to review 

and update service rates, but may meet more frequently as needs arise.

The statutory authority requires both funds to 

charge rates that recover agencies’ actual costs of operations. Customers 

of both WCFs either pay in advance or reimburse the fund depending on 

the terms of the agreement.

Management responsibility for the Census WCF is delegated across 

various divisions of the bureau. For example, the Budget Division leads 

the setting and reviewing of service rates each year as well as fund 

reconciliation. The Finance Division records and tracks customer charges 

and payments in the Commerce Business System (CBS), which is the 

financial system used throughout the Department of Commerce. The 

Acquisition Division reviews, approves, and tracks the status of 

interagency agreements with Census’ external customers. The program 

offices—also referred to as the sponsoring divisions—are responsible for 

the day-to-day management of the agreements and build relationships 

with the customer agencies.

 

5 See 15 U.S.C. § 1521 (establishing the U.S. Department of Commerce Working Capital 

Fund); and Pub. L. No.104-208, div. A, title II, § 210 110 Stat. 3009-41 (Sept. 30, 1996) 

(establishing the Bureau of the Census Working Capital Fund). The Commerce 

Department advised us that both WCFs accept advances or reimbursements.
 

Page 5 GAO-12-56 Intragovernmental Revolving Funds

Both the Commerce Departmental and Census WCFs primarily support 

centralized management and administrative services (M&A) for their 

respective bureaus and programs. For example, almost all of the 

Commerce Departmental WCF collections support centralized M&A 

services for its 13 bureaus. In contrast, about half of the Census WCF 

collections support M&A services for its internal divisions; most of the 

remaining collections support survey-related services Census performs 

for other federal agencies and a small share is provided to nonfederal 

entities.6

Figure 1 illustrates the flow of funds from customers into the Commerce 

Departmental WCF for the provision of M&A services. The majority of 

activity is attributed to services provided by four offices—General 

Counsel, Human Resources Management, Security, and Administrative 

Services. Customers of the Commerce Departmental WCF are billed 

directly for services provided.

This range of activities complicates management of the fund. 

Accordingly, Census maintains separate fund components to account for 

these different activities.

 

6 Federal customer agencies use Census’ nationwide polling structure, expertise, and 

address lists, which would otherwise be uneconomical for them to replicate on their own. 

For example, Census supports HUD’s American Housing Survey by gathering information 

on the size and composition of the housing inventory in the United States.

Both WCFs Support 

Management and 

Administrative Services, 

but the Census WCF Also 

Supports Mission 

Activities
 

Page 6 GAO-12-56 Intragovernmental Revolving Funds

Figure 1: Overview of the Flow of Funds for the Commerce Departmental WCF

A combination of mostly federal customers, including internal Census 

divisions/offices, pay into each of the various components of the Census 

WCF: Reimbursable, Cost Collection, and Cost Allocation. As shown in 

figure 2, the Reimbursable component supports services purchased by a 

single federal agency or nonfederal entity, such as the American Housing 

Survey for HUD, or services for New York City and Duke University. The 

Cost Collection component supports services where multiple federal 

agencies or customers share the costs and benefits of a single project,

such as the Current Population Survey.7

 

7 The Current Population Survey is a monthly survey of about 50,000 households and is 

the primary source of information on labor force characteristics of the U.S. population.

In addition, the direct and 

indirect costs for customers are distributed among separate components 

of the Census WCF: direct costs are distributed to the Reimbursable and 

Cost Collection components whereas indirect costs are distributed to the 

Cost Allocation component.
 

Page 7 GAO-12-56 Intragovernmental Revolving Funds 

Figure 2: Overview of the Flow of Funds for the Census WCF 

a

Charges to external customers include management and administrative (overhead) costs. As a 

result, some of the funds in the Cost Allocation component are from other federal agencies and 

nonfederal entities. 

b The Reimbursable component includes activity from the Fixed Fee component, which accounts for 

less than 1 percent of total WCF receipts. 

While all Commerce bureaus pay into the Commerce Departmental WCF, 

3 of the 13 bureaus provided the majority of funds. For the Census WCF, 

the majority of funds were provided by 4 of the 33 federal customers for 

which the bureau performed work and by internal Census program offices 

(see table 1). 
 

Page 8 GAO-12-56 Intragovernmental Revolving Funds

Table 1: Largest Customers of Services Supported by the Commerce Departmental 

and Census Working Capital Funds, Fiscal Year 2009

Commerce customers National Oceanic and Atmospheric Administration (NOAA)

International Trade Administration (ITA)

Census Bureau

Census customers Department of Labor/Bureau of Labor Statistics

Department of Health and Human Services/National Center for 

Health Statistics

Department of Housing and Urban Development

Department of Justice/Bureau of Justice Statistics

Internal Census Programs

Source: GAO analysis of Department of Commerce and U.S. Census Bureau data.

Note: The largest internal Census customers are the 2010 Decennial Census program, the American 

Community Survey, the Current Economic Statistics program, and the Economic Census program. 

We identified four key operating principles that offer a framework to 

effectively manage WCFs. As previously discussed, to identify key 

principles, we reviewed governmentwide guidance on business operating 

principles, internal controls, managerial cost accounting, and performance 

management. In addition, we met with staff from the two WCFs and OMB 

to obtain their views on the use of these principles to assess WCFs. 

Commerce Departmental, Census, and OMB staff generally found the 

principles to be reasonable. Moreover, we considered our past work. The 

significance of these four principles is described below.

1. Clearly Delineate Roles and Responsibilities: Appropriate delineation 

of roles and responsibilities promotes a clear understanding of who 

will be held accountable for specific tasks or duties such as 

authorizing and reviewing transactions, implementing controls over 

WCF management, and helping ensure that related responsibilities 

are coordinated. In addition, this reduces the risk of mismanaged 

funds and tasks or functions “falling through the cracks.” Moreover, it 

helps customers know who to contact in the event they have 

questions.

2. Ensure Self-Sufficiency by Recovering the Agency’s Actual Costs: 

Transparent and equitable pricing methodologies allow agencies to 

ensure that rates charged recover agencies’ actual costs and reflect 

customers’ service usage. If customers understand how rates are 

determined or changed including the assumptions used, customers 

can better anticipate potential changes to those assumptions, identify 

Key Operating 

Principles Provide a 

Framework for 

Effective WCF 

Management
 

Page 9 GAO-12-56 Intragovernmental Revolving Funds

their effect on costs, and incorporate that information into budget 

plans. A management review process can help to ensure the 

methodology is applied consistently over time and provides a forum to 

inform customers of decisions and discuss as needed.

3. Measure Performance: Performance goals and measures are 

important management tools applicable to all levels of an agency, 

including the program, project, or activity level.8

4. Build in Flexibility to Obtain Customer Input and Meet Customer 

Needs: Opportunities for customers to provide input about WCF 

services, or voice concerns about needs, in a timely manner enable 

agencies to regularly assess whether customer needs are being met 

or have changed. This also enables agencies to prioritize customer 

demands and use resources most effectively,

Performance 

measures and goals could include targets that assess fund managers’ 

responsiveness to customer inquiries, the consistency in the 

application of the funds’ rate-setting methodology, the reliability of 

cost information, and the billing error rates. Performance measures 

that are aligned with strategic goals can be used to evaluate whether, 

and if so how, WCF activities are contributing to the achievement of 

agency goals. A management review process comparing expected to 

actual performance allows agencies to review progress towards goals 

and potentially identify ways to improve performance.

9

By incorporating these principles in written guidance, agencies promote 

consistent application of management processes and provide a baseline 

for agency officials to assess and improve management processes. 

Moreover, agencies can use the guidance as a training tool for new staff 

and as an information tool for customers, program managers, 

stakeholders, and reviewers.

enabling them to adjust 

WCF capacity up or down as business rises or falls.

Figure 3 summarizes the four principles and their underlying components.

 

8 GAO-11-466T. 

9 GAO, Managing for Results: Opportunities to Strengthen Agencies’ Customer Service 

Efforts, GAO-11-44 (Washington, D.C.: Oct. 27, 2010).
Interactive graphic Figure 3: Working Capital Fund Key Operating Principles

Page 10 GAO-12-56 Intragovernmental Revolving Funds

Source: GAO analysis.

Directions:

Print instructions To print text version of this graphic, go to appendix I

Clearly delineate roles and 

responsibilities

Ensure self-sufficiency by recovering the 

agency’s actual costs

Measure performance

Build in flexibility to obtain customer 

input and meet customer needs

Establish management review and approval process at the functional

or activity level that ensures appropriate tracking and use of funds

Define key areas of authority and responsibility

Segregate duties to reduce error or fraud

Establish transparent and equitable pricing methodology

Set rates to cover agency’s actual costs of providing service

Establish management review process for rate-setting

Establish performance measures and goals

Align performance measures with strategic goals

Establish management review of WCF performance

Communicate with customers regularly and in a timely manner

Develop process to assess resources needed to meet changes in 

customer demand

Establish process to prioritize requests for services

Key principle Components of principle

Mouse over buttons for definitions of key principles, and buttons

to see examples of evidence that support key principles

Description Example
 

Page 11 GAO-12-56 Intragovernmental Revolving Funds

The responsibility for managing and overseeing aspects of the Commerce 

Departmental and Census WCFs is segregated across a number of 

offices and entities, thus minimizing the risk of error in fund management. 

However, neither agency’s WCF guidance includes complete information 

on the roles and responsibilities of all key personnel.

The Commerce Department’s Office of Executive Budgeting has created 

a working environment that promotes communication, according to 

customers and service providers. This has resulted in a clear 

understanding among Commerce Departmental WCF managers, service 

providers, and customers about the roles and responsibilities of key 

personnel who manage the Commerce Departmental WCF. Customers 

and service providers we interviewed said that OEB is where they go to 

get answers or raise concerns. In addition, customers and service 

providers said they communicate directly with each other or through OEB 

about services they receive and rates charged. Service providers 

expressed appreciation for OEB’s role in facilitating and coordinating 

regular communication between the service providers and customers. For 

example:

• two of the four service providers said they interact with OEB on a daily 

basis, and 

• all four service providers said that communication occurs on at least a 

monthly or quarterly basis through meetings or status reports.

However, while the Commerce Departmental WCF handbook includes 

the roles and responsibilities of many key personnel and review groups 

involved with fund management, it leaves out information on the crossdepartmental role of the Commerce CFO Council, which is comprised of 

the CFOs from each of Commerce’s bureaus and has an important role 

regarding increases or changes to the WCF. The absence of this entity 

from the handbook results in an incomplete reflection of the process and 

a missed opportunity to promote understanding by new staff and 

customers.

Principle 1: Clearly 

Delineate Roles and 

Responsibilities

Agencies’ Guidance Does 

Not Identify Roles and 

Responsibilities of All Key 

Personnel
 

Page 12 GAO-12-56 Intragovernmental Revolving Funds

In contrast to the centralized management of the Commerce 

Departmental WCF, management responsibilities for the Census WCF 

are delegated across several divisions including the Census Budget, 

Finance, and Acquisition Divisions. Although decentralization provides 

segregation of duties, Census does not have a formal process to 

coordinate and consolidate information managed by these disparate 

divisions to provide a corporate view of the WCF. In addition, information 

about the roles and responsibilities of Census management is incomplete, 

spread across three documents, and contains varying levels of detail and 

clarity. For example, the Census WCF Manual lists key personnel 

responsible for management of the WCF but does not describe their 

duties and responsibilities or provide specific contact information. This 

limits the usefulness of the guidance for bureau staff, customers, and 

other stakeholders. For example, one of the Census WCF’s larger 

customers we interviewed was unsure who to speak with about questions 

relating to service needs (e.g., the level of service to expect and the wait 

times before receiving services) and suggested that the Census WCF 

develop guidelines about service needs and expectations.

The Commerce Business System (CBS), which is the financial system 

used throughout most of Commerce, does not provide a mechanism to 

record the period of availability of appropriations10 advanced from 

customer agencies. The Commerce Department advised us that both 

WCFs accept advances or reimbursements. When customers pay in 

advance, those advances have not yet been “earned”11 in performance of 

an agreed-upon service and still retain the period of availability from the 

original appropriation.12

 

10 An appropriation’s period of availability refers to the period of time in which those funds 

are available for new obligations. Appropriations may be time-limited and therefore only 

available for 1, 2, or more years, or they can be available for obligation without fiscal year 

limitation. Amounts in both funds are available without fiscal year limitation once earned.

If the providing agency were to obligate against 

advanced funds after the appropriation account closes, the customer 

agency would be required to transfer currently available funds to the 

11 Customer agency advances to WCFs cannot be earned until the providing agency

begins work on the agreement and bills against the advance as work progresses.

12 Advances made to WCFs become no-year money and are available without fiscal year 

limitation when they enter the fund’s corpus after being “earned.” 

Commerce Business 

System Does Not Facilitate 

Appropriate Tracking and 

Use of Funds
 

Page 13 GAO-12-56 Intragovernmental Revolving Funds

WCF. If the customer does not have such funds available,13 they could be 

exposed to possible Anti-Deficiency Act violations.14

Similar to what we found in our prior work at NIST, Census tracks 

customer funds by the period of performance, which may not always 

coincide with the availability of the funds. Although customer agencies 

bear ultimate responsibility for proper use of their funds, we have 

previously reported that the performing agency shares responsibility with 

its customer agencies to ensure the proper use of federal funds when 

entering into interagency agreements.

Thus, to 

appropriately manage the use of funds, agencies need a way to track 

whether funds remain available for purposes of the interagency 

agreement when it bills against the advance.

15 Census officials can verify the 

availability of advanced funds through the Treasury Account Symbol 

(TAS);16 however, TAS is not electronically captured in CBS. Unless CBS 

is updated to include a mechanism for tracking the availability of funds, 

the performing agency cannot ensure that funds are legally available 

when it bills against the advances. This is an indication of a potential 

internal control weakness over resources and, as mentioned above, 

creates a risk that customer agencies may incur an Anti-Deficiency Act 

violation.

 

13 Appropriations available for a definite period are canceled 5 fiscal years after their 

period of availability for new obligations expires. See 31 U.S.C. 1552.

14 The Anti-Deficiency Act (31 U.S.C. § 1341) prohibits, among other things, the making or 

authorizing of an obligation or expenditure from any appropriation in excess of the amount 

available in the appropriation. Obligating parties—in this case federal agency customers of 

the Census WCF—are responsible for complying with this act. See B-319349, June 4, 

2010.

15 GAO-11-41; See also B-318046, July 7, 2009.

16 The TAS is a code assigned by the Department of the Treasury, in collaboration with 

OMB and the owner agency, to an individual appropriation, receipt, or other fund account. 

All financial transactions of the federal government are classified by TAS for reporting 

purposes.
 

Page 14 GAO-12-56 Intragovernmental Revolving Funds

According to service providers and customers, the rate-setting processes 

for the Commerce Departmental WCF are transparent, clearly 

coordinated, and designed to recover annual actual costs. For example, 

the meetings of the Commerce CFO Council—which is comprised of 

CFOs from each of the Commerce Department’s bureaus—provide a 

regular source of information on the status of funding recommendations 

to Commerce’s CFO. In addition, the algorithm review group and OEB 

review rates charged at least annually to determine how much each 

customer bureau will pay into the Commerce Departmental WCF. These 

rates are based on algorithms that include variables such as prior year 

actual costs associated with customers’ service usage. For example, 

when determining rates for building maintenance, one important variable 

is the square footage of the customer office space. Similarly, when 

determining rates for human resource management services, the number 

of full-time equivalents is an important variable. This rate-setting process, 

including the method for setting and distributing charges among users, is 

clearly explained in the Commerce Departmental WCF handbook.

Moreover, Commerce customers said they understood how rates were 

determined and were satisfied with the amount of input they had in the 

process. Managers of the Commerce Departmental WCF said that their 

goal each year is to set rates that cover annual WCF costs and maintain 

at least the same level of services as the prior year. OEB officials said 

that the WCF has a limited number of significant cost increases, so a 

large carryover balance is not needed to sustain the fund.

The Census WCF is also designed to recover actual costs and bases its 

M&A service rates on algorithms linked to expected service usage. In 

contrast to the Commerce Departmental WCF, managers of the Census 

WCF maintain an operating reserve to help keep rates stable throughout 

the decennial census cycle. The Census WCF charges rates that are 

higher than needed earlier in the decennial cycle to break even later in 

the decennial cycle. Information about how rates are charged and costs 

distributed is incomplete and dispersed across three documents. Census 

customers we spoke with had mixed responses about how M&A costs are 

Principle 2: Ensure 

Self-sufficiency by 

Recovering the 

Agency’s Actual Costs

Commerce Has a 

Transparent Process for 

Ensuring Recovery of 

Actual Costs

Census’ Process to 

Recover Actual Costs 

Could Be More 

Transparent
 

Page 15 GAO-12-56 Intragovernmental Revolving Funds

determined. For example, five of the seven customers we spoke with said 

Census informed them of the charges in general terms but did not 

describe how the individual costs that make up the total M&A costs are 

determined. However, the customers provided no detail about their efforts 

to obtain such information from Census. Nonetheless, the lack of clarity in 

how M&A costs are determined makes it difficult for customers to 

challenge rates or suggest improvements. A recent Census task force 

report17 on cost-saving opportunities related to survey work performed for 

other federal agencies found that no one Census division had authority to 

oversee and manage the allocation of resources or the timing of 

delivering services to any one customer. This report recommended that 

Census provide greater details on survey costs and establish a “single 

point of authority” for communicating with customers.

Both Commerce and Census WCFs have a management review process 

that examines how rates are set. However, the level of transparency 

differs between the two organizations. For example, each month OEB 

creates and updates a “status of funds” document that tracks available 

funding in the Commerce Departmental WCF throughout the fiscal year. 

Commerce officials said OEB uses this document to regularly monitor the 

WCF and the document is shared with the Commerce CFO each month. 

In addition, OEB reconciles actual obligations with estimates to identify 

and investigate variances of 10 percent or more. The service providers 

meet quarterly with OEB to review budget status and any changes in 

customer service needs. This process is also documented in the 

Commerce WCF handbook and helps ensure that rates recover the 

agency’s actual costs.

In contrast, Census’ WCF reconciliation and review process lacks 

transparency. Census provides a fragmented and limited description of 

how it sets rates and there is no formal process to communicate with 

customers. According to Census officials, the rates for the M&A services 

are reviewed annually and the costs of the survey services are reconciled 

when a project concludes. However, two of the three Census WCF 

internal customers said they have limited discussions and input with 

Census WCF managers about how rates were determined. Moreover, it is 

 

17 Synthesis Report of the Survey Cost Savings Task Forces: U.S. Census Bureau Data 

Collection Cost Saving Opportunities in Federal Agency Sponsored Demographic Surveys 

(November 2010).

Both Commerce and 

Census Have a 

Management Review 

Process, but Census’ 

Process Could Be 

Improved 
 

Page 16 GAO-12-56 Intragovernmental Revolving Funds

unclear what information is provided, or when, to senior Census 

management (e.g., Census’ CFO). Documentation provided by Census 

officials did not show what assumptions were used to set rates, whether 

they were applied consistently, and if actual costs are fully recovered. 

Although the Census WCF is subject to periodic reviews conducted by 

the Budget Division to compare revenues generated with the costs 

captured, it does not include further details on how this is done or with 

whom the information is shared. Census officials said the WCF is 

discussed during quarterly budget review meetings with senior 

management. However, the document that Census officials shared with 

us, which is used to explain the components of the WCF balance, 

includes amounts only related to the Cost Allocation component. Without 

transparent processes for reviewing and updating the service rates, 

Census misses the opportunity to assure customers and other 

stakeholders that rates charged are set fairly and to receive suggestions 

from stakeholders on potential improvements.18

OEB has processes in place that help it manage the operations of the 

Commerce Departmental WCF. For example:

• A “status of funds” report is updated monthly and provided to 

Commerce’s CFO. This report helps WCF managers track the 

remaining balance of customers’ funds to pay for WCF services.

• Variances of 10 percent or more in the Commerce Departmental 

WCF’s estimated and actual obligations are investigated to obtain 

justification. In addition, OEB meets quarterly with the director of each 

office to review the current status of the organization’s budget.

• Customers are surveyed annually about the quality of OEB’s 

assistance and written guidance for the services OEB provides. 

However, this survey asks broad questions that are not targeted to a 

specific activity or level of performance. For example, the only 

 

18 GAO, Federal User Fees: A Design Guide, GAO-08-386SP (Washington, D.C.: May 29, 

2008).

Principle 3: Measure 

Performance 

Both WCFs Could Benefit 

from Performance 

Measures to Assess 

Operational Effectiveness
 

Page 17 GAO-12-56 Intragovernmental Revolving Funds

references to the Commerce Departmental WCF are general 

questions about customer interactions with OEB staff and whether the 

Commerce WCF handbook is useful.

While OEB finds these processes helpful in day-to-day management of 

WCF activities—such as tracking available balances of customer funds—

it does not define these processes as measures to assess WCF 

performance. We believe that Commerce could use these processes as a 

starting point to determine what specific measures would be helpful to 

continuously improve WCF management.

As part of its strategic plan, Commerce outlined departmentwide strategic 

goals and performance measures in its “balanced scorecard approach.”19

Measures that are specific to WCF activities allow fund managers to 

assess the fund’s operational effectiveness. However, Census lacks 

operational performance measures to show how it is managing the WCF. 

This is important for program efficiency and effectiveness and to pinpoint 

improvement opportunities. The departmental strategic plan may not 

necessarily need to specify the Census WCF; however, all operations 

should have some type of performance measures. While the Budget 

Division solicited performance feedback through periodic customer 

satisfaction surveys,

The offices that provide services supported through the Commerce 

Departmental and Census WCFs are assessed as part of this approach, 

but currently this does not include measures to assess how the WCFs are 

operating or if they could each function better as an entity.

20

 

19 The Commerce Secretary initiated the “balance scorecard approach” in 2010 to 

establish and maintain focus on the department’s top priorities, to support related datadriven reviews to achieve them, and to emphasize that customer service, organizational 

excellence, and workforce excellence are prerequisites to the achievement of the 

department’s programmatic goals.

the survey does not include a reference to the 

Census WCF. For example, the survey posed a number of questions 

about the work performance of budget staff but did not ask specific 

questions about the budget services provided through the Census WCF. 

This raises concern because the Budget Division has the sole 

responsibility of determining Census WCF spending allocations for all 

20 Customers corroborated receiving surveys from other service providers, such as the 

Acquisition and Finance Divisions, but were unable to provide copies of these surveys. 
 

Page 18 GAO-12-56 Intragovernmental Revolving Funds

participating divisions. Further, Census WCF managers could not provide 

any examples of fund-specific performance measures.

Although the Commerce Departmental and Census WCFs are intended to 

achieve economies of scale by supporting services and projects that are 

performed more advantageously when centralized, both WCFs support 

similar M&A services that could potentially be supported by one WCF.

Officials at Commerce and Census were unable to clearly explain why 

each WCF provides the same or similar services, or why these services 

could not be consolidated. For example, both the Commerce 

Departmental and Census WCFs support a range of space management, 

travel, and training services for staff, as well as other personnel-related 

activities. These are potential areas that could be consolidated. In 

addition, by establishing WCF-specific performance measures, fund 

managers could benchmark or compare fund performance, which would 

be useful in identifying improvement opportunities and deciding whether 

or not to consolidate services.

In general, customers we interviewed said they had regular and ongoing 

interactions with fund managers or service providers. Commerce 

Departmental customers said they communicate regularly about the type 

and amount of services received and rates charged. Census customer 

concerns about overhead costs initiated the recent Census task force 

report previously described. As a result of the report findings, Census 

made several rate changes. Also in response to customer input, the 

Census Bureau recently decided to close six field offices.

The Commerce CFO Council actively seeks WCF managers’ involvement 

in setting customer priorities and addressing customer needs. The council 

meets to discuss individual bureau requests and recommends final 

allocations to Commerce’s CFO, including identifying any potential need 

to shift funds across programs. When prioritizing customer demand, 

Commerce Departmental WCF managers also have to incorporate the 

Opportunities Exist for 

Management to Potentially 

Consolidate WCF Services

Principle 4: Build in 

Flexibility to Obtain 

Customer Input and 

Meet Customer Needs

Both WCFs Regularly 

Obtain Customer Input and 

Allow Some Flexibility to 

Adjust to Customer Needs, 

but Challenges Exist
 

Page 19 GAO-12-56 Intragovernmental Revolving Funds

statutory cap that limits the amount NOAA pays into the Commerce 

Departmental WCF.21

Although the Commerce Departmental WCF carries over some balances, 

the NOAA cap’s effective limit on revenues hinders the ability to build a 

reserve. During fiscal years 2001 through 2010, the Commerce 

Departmental WCF carryover balance ranged from $3 million to $13 

million. Census uses its operating reserve to maintain price stability for 

customers throughout the decennial cycle. During fiscal years 2001 

through 2010, the Census WCF carryover balance ranged from $21 

million to $430 million as reported in the President’s budget. According to 

Census officials, the operating reserve is a portion of the Census WCF 

carryover balance. In fiscal year 2010, they estimated the amount of the 

operating reserve ranged from $45 million to $75 million. However, they 

did not provide documentation to support this range. 

Because fund managers strive to ensure selfsufficiency of the WCF and equitably distribute costs across customers, 

this cap limits the amount other bureaus pay into the Commerce 

Departmental WCF and thus the level of services that can be supported 

for all customers. As a result, Commerce Departmental WCF managers in 

the past have had to propose reductions to services to compensate for 

the NOAA cap and still provide needed services. When the needs of 

customers exceed the capacity of the Commerce Departmental WCF, the 

department and the customer enter into a memorandum of understanding 

(MOU), outside of the standard suite of services offered through the 

WCF. However, this additional process somewhat works against the 

efficiencies that WCFs are intended to provide as WCF managers must 

rely on a separate mechanism to provide the same type, but a higher 

level, of service to customers.

In certain cases, Census also provides separate services to customers 

outside the WCF’s standard offerings. Census’ process to meet changes 

in customer demand is designed to address the fluctuating costs of 

providing services to internal customers during the decennial cycle while 

equitably distributing costs among all internal customers. For example, in 

the peak years of the decennial cycle, the decennial program requires 

such an increased level of M&A services to support temporary staff that 

not all of those costs can be supported by the WCF reserve without 

 

21 Over the past several years, NOAA’s appropriations included a statutory cap that has 

increased from $34 million in fiscal year 2006 to $41.9 million in fiscal year 2010.
 

Page 20 GAO-12-56 Intragovernmental Revolving Funds

undermining the goal of equitable cost distribution among customers.

Therefore, Census directly bills these additional costs to the decennial 

program.

WCFs provide agencies with an opportunity to operate more efficiently by 

consolidating services and creating incentives for customers and 

managers to exercise cost control and economic restraint. Given the 

fiscal pressures facing the federal government, consolidating operations 

could potentially achieve cost savings and help agencies provide more 

efficient and effective services. Agencies can maximize the potential of 

these opportunities by following four key WCF operating principles. 

Incorporating these principles in written guidance could promote 

consistent application, provide a baseline for officials to assess and 

improve management processes, and serve as an information tool for 

customers, program managers, stakeholders, and reviewers.

Clear guidance on the roles and responsibilities of key personnel for 

managing the WCF promotes understanding of who will be held 

accountable, helps ensure that related responsibilities are coordinated, 

and reduces the risk that funds will be mismanaged. While the roles and 

responsibilities of the Commerce Departmental WCF’s management are 

well understood by customers, the guidance does not include complete 

information about all key participants. Because Census WCF guidance is 

fragmented and incomplete, it lacks clarity and is of limited use for 

employees and customers. Additionally, Census does not have a process 

to facilitate coordination among key WCF personnel to ensure appropriate 

tracking of funds.

To appropriately manage the use of funds advanced from customers for 

projects spanning multiple fiscal years, performing agencies need a way 

to track whether funds advanced remain available to bill against. Both 

Commerce and Census use the Commerce Business System (CBS) to 

manage funds, but the system does not track a key element to confirm 

that funds advanced in support of an interagency agreement are available 

to cover the costs of performance. Modifying CBS would help ensure that 

customer funds are legally available and avoid potential Anti-Deficiency

Act violations for the customer agencies. A transparent rate-setting 

process helps assure that customers are being charged accurately and 

fairly for services supported through the WCF. Commerce clearly explains 

its rate-setting process and customers feel they have sufficient input on 

the process. Census’ rate-setting process is less transparent, which limits 

Conclusions
 

Page 21 GAO-12-56 Intragovernmental Revolving Funds

the ability of fund managers to confirm that the WCF is self-sufficient and 

makes it difficult for customers to make appeals.

WCF managers can better foster a results-oriented environment focused 

on continuous improvement by establishing performance measures and 

goals for WCF operations, ensuring those performance measures and 

goals align with the agency’s strategic goals, and by establishing a 

management review process to track WCF performance. The purpose of 

the WCFs is to achieve economies of scale through shared services. 

However, the lack of performance measures makes it difficult to know 

whether these economies are being achieved. Moreover, WCF-specific 

performance information and a corresponding management review 

process could be used to hold fund managers accountable for achieving 

the efficiencies that WCFs were designed to produce. Furthermore, the 

two WCFs may provide services in overlapping areas, which warrants 

further examination.

We make seven recommendations to the Secretary of Commerce.

To improve the management of the Commerce Departmental Working 

Capital Fund, we recommend that the Secretary of Commerce take the 

following actions:

1. Update the Commerce Departmental WCF handbook to include a 

description of the Commerce CFO Council and its roles and 

responsibilities.

2. To meet its responsibilities in ensuring the proper use of federal funds 

and to help guard against the use of canceled appropriations, revise 

its financial systems to electronically record and monitor the period of 

availability of appropriations advanced to Commerce and its bureaus 

from client agencies.

3. Establish performance measures to assess performance of WCF 

operations, such as billing error rates, and determine what additional 

measures would be helpful to improve WCF management.

4. Coordinate with the Census Bureau to examine the M&A services 

provided through both WCFs to determine what services might be 

consolidated.

Recommendations for 

Executive Action
 

Page 22 GAO-12-56 Intragovernmental Revolving Funds

To improve the management of the Census Bureau Working Capital 

Fund, we recommend that the Secretary of Commerce require the Under 

Secretary for Economic Affairs as well as the Census Director to take the 

following actions:

5. Develop guidance that clarifies and consolidates existing WCF 

policies to include:

a. roles and responsibilities of key personnel responsible for WCF

 management, and

b. a process to coordinate information managed by disparate

 divisions to provide an overarching view of the WCF and ensure

 the appropriate tracking of funds.

6. Include a more detailed explanation in WCF guidance on the ratesetting process for all components of the fund, such as an explanation 

of how rates are determined and costs distributed, and establish a 

formal process similar to the Departmental WCF’s process to 

communicate with customers.

7. Establish performance measures to assess performance of WCF 

operations and determine what would be helpful to improve WCF 

management.

We provided a draft of this report to the Secretary of the Department of 

Commerce for official review and comment. In his letter that is reprinted in 

appendix II, the Secretary agreed with our findings and recommendations 

and has directed the managers of both the Commerce Departmental 

WCF and the Census Bureau WCF to begin implementing our 

recommendations. Commerce and Census provided technical comments 

that were incorporated into the report as appropriate. We also provided 

portions of the report to the customer agencies with which we met. None 

of these customer agencies offered any technical comments.

We are sending copies of this report to the Secretary of Commerce, the 

Under Secretary for Economic Affairs, and the Director of the Census 

Bureau. We are also sending copies to the appropriate congressional 

Committees. In addition, the report is available at no charge on GAO’s 

website at http://www.gao.gov. 

Agency Comments 

and Our Evaluation
 

Page 23 GAO-12-56 Intragovernmental Revolving Funds 

If you or your staff have any questions about this report, please contact 

Denise M. Fantone at (202) 512-6806 or fantoned@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. GAO staff who made major 

contributions to this report are listed in appendix III. 

Denise M. Fantone 

Director, Strategic Issues 
Appendix I: Expanded Version of WCF Key 

Operating Principles 

Page 24 GAO-12-56 Intragovernmental Revolving Funds

WCF Key Operating Principles

Principle Components of principle Examples of evidence supporting principle

Clearly delineate roles and responsibilities

Appropriate delineation of roles and 

responsibilities promotes a clear 

understanding of who will be held accountable 

for specific tasks or duties, such as authorizing 

and reviewing transactions, implementing

controls over WCF management, and helping

ensure that related responsibilities are 

coordinated. In addition, this reduces the risk 

of mismanaged funds and tasks or functions 

“falling through the cracks.” Moreover, it helps 

customers know who to contact in the event 

they have questions.

Segregate duties to reduce 

error or fraud

Written roles and responsibilities specify how key 

duties and responsibilities are divided across multiple 

individuals/offices and are subject to a process of 

checks and balances. This should include separating 

responsibilities for authorizing transactions, 

processing and recording them, and reviewing the 

transactions.

Define key areas of authority 

and responsibility

Written description of all WCF roles and 

responsibilities in an accessible format such as a fund 

manual. Discussions with providers and clients 

confirm a clear understanding.

Establish management review 

and approval process at the 

functional or activity level that 

ensures appropriate tracking 

and use of funds

A routine review process exists to ensure proper 

execution of transactions and events.

Ensure self-sufficiency by recovering the 

agency’s actual costs

Transparent and equitable pricing 

methodologies allow agencies to ensure that 

rates charged recover agencies’ actual costs 

and reflect customers’ service usage. If 

customers understand how rates are 

determined or changed including the 

assumptions used, customers can better 

anticipate potential changes to those 

assumptions, identify their effect on costs, and 

incorporate that information into budget plans. 

A management review process can help to 

ensure the methodology is applied consistently 

over time and provides a forum to inform 

customers of decisions and discuss as 

needed.

Establish transparent and 

equitable pricing methodology

Published price sheets for services are readily 

available. Documentation of pricing formulas supports 

equitable distribution of costs.

Set rates to cover agency’s 

actual costs of providing 

service 

Pricing methodology and accompanying process 

ensures that, in aggregate, charges recover the 

actual costs of operations.

Establish management review 

for rate-setting

Management review process allows fund managers 

to receive and incorporate feedback from customers. 

Discussions with customers confirm an understanding 

of the charges and that they are viewed as 

transparent and equitable.

Appendix I: Expanded Version of WCF Key 

Operating Principles
Appendix I: Expanded Version of WCF Key 

Operating Principles 

Page 25 GAO-12-56 Intragovernmental Revolving Funds

Principle Components of principle Examples of evidence supporting principle

Measure performance

Performance goals and measures are 

important management tools applicable to all 

operations of an agency, including the 

program, project, or activity level. Performance 

measures and goals could include targets that 

assess fund managers’ responsiveness to 

customer inquiries, the consistency in the 

application of the funds’ rate-setting 

methodology, the reliability of cost information, 

and the billing error rates. Performance 

measures that are aligned with strategic goals 

can be used to evaluate whether, and if so 

how, WCF activities are contributing to the 

achievement of agency goals. A management 

review process comparing expected to actual 

performance allows agencies to review 

progress towards goals and potentially identify 

ways to improve performance.

Establish performance 

measures and goals

Performance indicators and metrics for WCF 

management (not just for the services provided) are 

documented.

Align performance measures 

with strategic goals

Indicators or metrics to measure outputs and 

outcomes are aligned with strategic goals and WCF 

priorities. 

Establish management review 

of WCF performance

WCF managers regularly compare actual 

performance with planned or expected results and 

make improvements as appropriate. In addition, 

performance results are periodically benchmarked 

against standards or “best in class” in a specific 

activity.

Build in flexibility to obtain customer input 

and meet customer needs

Opportunities for customers to provide input 

about WCF services, or voice concerns about 

needs, in a timely manner enable agencies to 

regularly assess whether customer needs are 

being met or have changed. This also enables 

agencies to prioritize customer demands and 

use resources most effectively, enabling them 

to adjust WCF capacity up or down as 

business rises or falls.

Communicate with customers 

regularly and timely

Established forum, routine meetings, and/or surveys 

solicit information on customer needs and satisfaction 

with WCF performance.

Develop process to assess 

resources needed to meet 

changes in customer demand

Established communication channels regularly and 

actively seek information on changes in customer 

demand and assess the resources needed to 

accommodate those changes.

Establish process to prioritize 

requests for services

Established management review process that allows 

for trade-off decisions to prioritize and shift limited 

resources needed to accommodate changes in 

demand across the organization.

Source: GAO analysis.
Appendix II: Comments from the Department 

of Commerce

Page 26 GAO-12-56 Intragovernmental Revolving Funds

Appendix II: Comments from the Department 

of Commerce
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 27 GAO-12-56 Intragovernmental Revolving Funds

Denise M. Fantone, (202) 512-6806 or fantoned@gao.gov

In addition to the contact named above, Carol M. Henn, Assistant Director 

and Leah Q. Nash, Analyst-in-Charge managed this assignment. Anna 

Chung, Elisabeth Crichton, Wati Kadzai, Margit Myers, and Amrita Sen 

made major contributions to this report. Tom Beall, Robert Gebhart, 

Felicia Lopez, and Jack Warner also made key contributions to this 

report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO contact

Staff 

Acknowledgments

(450843)
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