Follow-up on 2011 

Report: Status of Actions 

Taken to Reduce 

Duplication, Overlap, 

and Fragmentation, 

Save Tax Dollars, and 

Enhance Revenue 

Report to Congressional Addressees

February 2012 

GAO-12-453SP 

United States Government Accountability Office

GAO 
Page i GAO-12-453SP Follow-up on 2011 Report 

Letter 1 

Enclosure I Overall Progress Made in Each of the 81 Areas 7 

Enclosure II Progress Update for Each of the 176 Actions Needed 

within the 81 Areas 13 

Enclosure III Scope and Methodology 110

Tables 

Table 1: Overall Progress Made in Each of the GAO Identified 

Areas of Potential Duplication, Overlap, and 

Fragmentation, as of February 10, 2012 7

Table 2: Overall Progress Made to Address GAO-Identified 

Cost-Saving and Revenue-Enhancing Areas, as of February 

10, 2012 10

Contents 
Page ii GAO-12-453SP Follow-up on 2011 Report 

Abbreviations 

ASC alternative simplified credit 

ATF Bureau of Alcohol, Tobacco, Firearms, and Explosives 

BEST Border Enforcement Security Task Force 

BLM Bureau of Land Management 

CBP Customs and Border Protection 

CDE Community Development Entity 

CIO Chief Information Officer 

CMS Centers for Medicare & Medicaid Services 

Commerce Department of Commerce 

CDBG Community Development Block Grant 

Coordinating Interagency Transportation Coordinating Council on 

 Council Access and Mobility 

Corps U.S. Army Corps of Engineers 

CPRA Civilian Real Property Realignment Act 

DHS Department of Homeland Security 

DOD Department of Defense 

DOT Department of Transportation 

EAS Essential Air Service 

EDA Economic Development Administration 

ESEA Elementary and Secondary Education Act of 1965 

FAM Foreign Affairs Manual 

FBI Federal Bureau of Investigation 

FCC Federal Communications Commission 

FEMA Federal Emergency Management Agency 

FMCSA Federal Motor Carrier Safety Administration 

GPRAMA Government Performance and Results Modernization Act 

of 2010 

GSA General Services Administration 

HHS Department of Health and Human Services 

HUD Department of Housing and Urban Development 

IBET Integrated Border Enforcement Team 

IED improvised explosive device 

iEHR integrated electronic health record 

IILCM integrated investment life cycle model 

Interior Department of the Interior 

IPERA Improper Payments Elimination and Recovery Act of 

2010 

IRS Internal Revenue Service 

IT information technology 

JIEDDO Joint Improvised Explosive Device Defeat Organization 

Justice Department of Justice 
Page iii GAO-12-453SP Follow-up on 2011 Report 

Labor Department of Labor 

MOU memorandum of understanding 

MPPR multiple procedure payment reduction 

NSS National Security Staff 

OFPP Office of Federal Procurement Policy 

OMB Office of Management and Budget 

O&S operating and support 

PAR Performance and Accountability Report 

RAC recovery audit contractor 

R&D research and development 

ROI return on investment 

SBA Small Business Administration 

SIOC Strategic Information Operation Centers 

SPOT Screening of Passengers by Observation Techniques 

S&T Science and Technology Directorate 

State Department of State 

TANF Temporary Assistance for Needy Families 

T&E testing and evaluation 

Treasury Department of the Treasury 

TRIAD Transit and Rail Intelligence Awareness Daily 

TSA Transportation Security Administration 

USAID U.S. Agency for International Development 

USDA U.S. Department of Agriculture 

USICH U.S. Interagency Council on Homelessness 

VA Department of Veterans Affairs 

VEETC Volumetric Ethanol Excise Tax Credit 

VR vocational rehabilitation 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 
Page 1 GAO-12-453SP Follow-up on 2011 Report 

United States Government Accountability Office

Washington, DC 20548 

February 28, 2012 

Congressional Addressees 

In March 2011, GAO issued its first annual report to the Congress on 

potential duplication, overlap, and fragmentation in the federal 

government.1

 The report also identified opportunities to achieve cost 

savings and enhance revenues. We identified 81 areas—which span a 

wide range of government missions2

—with a total of 176 actions3 that the 

Congress and the executive branch could take to reduce or eliminate 

unnecessary duplication, overlap, and fragmentation or achieve other 

potential financial benefits. We also presented areas where programs 

may be able to achieve greater efficiencies or become more effective in 

providing government services. In many areas, we suggested actions—

identifying some new options, as well as underscoring numerous existing 

GAO recommendations—that policymakers could consider. This status 

report provides an overall assessment of progress in implementing 

actions for the 81 areas, as well as an assessment of each of the 176 

suggested actions. 

As of February 10, 2012, the Congress and the executive branch had 

made some progress in addressing the majority of the 81 areas that we 

identified, including the implementation of all actions in 4 areas; however, 

additional steps are needed to fully implement the remaining actions to 

achieve associated benefits. GAO suggested a wide range of actions for 

the Congress and the executive branch to consider, such as developing 

strategies to better coordinate fragmented efforts, implementing executive 

 

1

GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save Tax 

Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011). This 

report was issued in response to a new statutory requirement that GAO identify federal 

programs, agencies, offices, and initiatives, either within departments or governmentwide, 

which have duplicative goals or activities. Congress asked GAO to conduct this work and 

to report annually on our findings. See Pub. L. No. 111-139, §21, 124 Stat. 29 (2010), 31 

U.S.C. § 712 Note. 

2

Agriculture, defense, economic development, energy, general government, health, 

homeland security, international affairs, and social services were among the government 

missions included in the March 2011 report. 

3

These actions were identified in the “Actions Needed” section for each respective issue 

area. 

 
 

Page 2 GAO-12-453SP Follow-up on 2011 Report 

initiatives to improve oversight and evaluation of overlapping programs, 

considering enactment of legislation to facilitate revenue collection, and 

examining opportunities to eliminate potential duplication through 

streamlining, collocating, or consolidating program efforts or 

administrative services. 

GAO’s specific assessment of progress as of February 10, 2012, showed 

that 4 (or 5 percent) of the 81 areas GAO identified were addressed; 60 

(or 74 percent) were partially addressed; and 17 (or 21 percent) were not 

addressed. Enclosure I presents GAO’s assessment of the overall 

progress made in each area. GAO applied the following criteria in making 

these overall assessments for the 81 areas. We determined that an area 

was: 

 “addressed” if all actions needed in that area were addressed; 

 “partially addressed” if at least one action needed in that area showed 

some progress toward implementation, but not all actions were 

addressed; and 

 “not addressed” if none of the actions needed in that area were 

addressed. 

As of February 10, 2012, the majority of 176 actions needed within the 81 

areas identified by GAO have been partially addressed. Specifically, 23 

(or 13 percent) were addressed4

; 99 (or 56 percent) were partially 

addressed; 54 (or 31 percent) were not addressed5

. Enclosure II presents 

a progress update for each of the 176 legislative and executive actions 

needed that GAO identified within the 81 areas, as well as GAO’s 

assessment of that progress. GAO applied the following criteria in making 

these assessments. 

 

4

In one instance, the legislative action needed required Congress to consider several 

options, including allowing a tax credit to expire. Thus, because Congress did not renew 

the provision, the action was considered addressed. 

5

Members of Congress have introduced a wide range of bills and amendments, that if 

enacted, could help address a number of the issues raised in our March 2011 report. 

However, for the purposes of this report, only those bills that have passed a committee 

are discussed in the progress updates contained in Enclosure II. 
 

Page 3 GAO-12-453SP Follow-up on 2011 Report 

For legislative branch actions: 

 “addressed,” means relevant legislation is enacted and addresses all 

aspects of the action needed;6

 “partially addressed,” means a relevant bill has passed a committee, 

the House or Senate, or relevant legislation has been enacted, but 

only addressed part of the action needed; and 

 “not addressed,” means a bill may have been introduced, but did not 

pass out of a committee, or no relevant legislation has been 

introduced. 

For executive branch actions: 

 “addressed,” means implementation of the action needed has been 

completed; 

 “partially addressed,” means the action needed is in development, 

started but not yet completed; 

 “not addressed,” means the administration and/or agencies have 

made minimal or no progress toward implementing the action needed. 

In addition to the actions taken reported above, Congress has held a 

number of hearings and the Office of Management and Budget (OMB) 

has provided guidance to executive branch agencies on areas that GAO 

identified that could benefit from increased attention and ongoing 

oversight. Since the issuance of our March 2011 report, GAO has testified 

numerous times on its first annual report and on specific issues 

highlighted in the report. On August 17, 2011, OMB issued its Fiscal Year 

2013 Budget Guidance, which stated that agencies’ 2013 budget 

submissions and management plans should take into consideration areas 

of duplication or overlap identified by GAO, as well as by others. The 

guidance also advised agencies to take a number of other steps to 

achieve efficiency increases, such as identifying and including in their 

 

6

In situations where our action needed suggested that Congress should let a provision 

expire, we classified it as “addressed” if Congress permitted such expiration to happen. 
 

Page 4 GAO-12-453SP Follow-up on 2011 Report 

budget submissions cost-saving efforts that will improve operational 

efficiency and taxpayers’ rate of return, including program integration, 

reorganizations within and between agency components, and resource 

realignment to improve public services. 

Streamlining federal efforts, reducing government costs, and enhancing 

revenue collections can offer financial and other benefits. Today, and 

concurrently with this report, GAO issued its second annual report to 

Congress in response to the statutory requirement that GAO identify 

federal programs, agencies, offices, and initiatives with duplicative goals 

or activities.7

 That report identifies 51 additional issue areas and 

numerous actions within those issue areas that, if implemented, may 

further improve programs’ effectiveness and efficiency, achieve cost 

savings, and enhance revenues. 

Opportunities exist for the Congress and federal agencies to continue to 

address the identified actions needed in our March 2011 and February 

2012 reports. Collectively, these reports show that, if the actions are 

implemented, the government could save tens of billions of dollars 

annually. A number of the issues are difficult to address and 

implementing many of the actions identified will take time and sustained 

leadership. 

To prepare this report, we conducted our work from July 2011 through 

February 2012 in accordance with all sections of GAO’s Quality 

Assurance Framework that are relevant to our objectives. The framework 

requires that we plan and perform the engagement to meet our stated 

objectives and to discuss any limitations in our work. We believe that the 

information and data obtained, and the analysis conducted, provide a 

reasonable basis for any findings and conclusions in this product. GAO 

provided the draft to the agencies involved and OMB for their comments 

and incorporated comments as appropriate. The information in this report 

is current as of February 10, 2012 and does not reflect any actions that 

might have been taken after that date. Enclosure III contains additional 

details of our scope and methodology. 

 

7

GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington, 

D.C.: February 28, 2012). 
 

Page 5 GAO-12-453SP Follow-up on 2011 Report 

This report was prepared under the coordination of Janet St. Laurent, 

Managing Director, Defense Capabilities and Management, who may be 

reached at (202) 512-4300, or stlaurentj@gao.gov and Zina Merritt, 

Director, Defense Capabilities and Management, who may be reached at 

(202) 512-4300 or merrittz@gao.gov. 

Gene L. Dodaro 

Comptroller General 

 of the United States 
Page 6 GAO-12-453SP Follow-up on 2011 Report 

List of Congressional Addressees 

The Honorable Daniel K. Inouye 

Chairman 

The Honorable Thad Cochran 

Vice Chairman 

Committee on Appropriations 

United States Senate 

The Honorable Kent Conrad 

Chairman 

The Honorable Jeff Sessions 

Ranking Member 

Committee on the Budget 

United States Senate 

The Honorable Joseph I. Lieberman 

Chairman 

The Honorable Susan M. Collins 

Ranking Member 

Committee on Homeland Security 

 and Governmental Affairs 

United States Senate 

The Honorable Harold Rogers 

Chairman 

The Honorable Norman D. Dicks 

Ranking Member 

Committee on Appropriations 

House of Representatives 

The Honorable Paul Ryan 

Chairman 

The Honorable Chris Van Hollen 

Ranking Member 

Committee on the Budget 

House of Representatives 

The Honorable Darrell Issa 

Chairman 

The Honorable Elijah E. Cummings 

Ranking Member 

Committee on Oversight 

 and Government Reform 

House of Representatives 

The Honorable Scott Brown 

United States Senate 

The Honorable Tom Coburn 

United States Senate 

The Honorable Claire McCaskill 

United States Senate 

The Honorable Mark R. Warner 

United States Senate 
Page 7 GAO-12-453SP Follow-up on 2011 Report 

This enclosure presents a summary of GAO’s assessment of the overall 

progress made in each of the 81 areas that we identified in our March 

2011 report1

 in which the Congress and the executive branch could take 

actions to reduce or eliminate potential duplication, overlap, and 

fragmentation or achieve other potential financial benefits. For each of the 

34 areas related to duplication, overlap, or fragmentation that GAO 

identified, table 1 presents GAO’s assessment of the overall progress 

made in implementing the actions needed in that area. For each of the 47 

areas where GAO identified cost saving or revenue enhancement 

opportunities, table 2 presents GAO’s assessment of the overall progress 

made in implementing the actions GAO identified. 

Table 1: Overall Progress Made in Each of the GAO Identified Areas of Potential Duplication, Overlap, and Fragmentation, as 

of February 10, 2012 

Mission Areas identified Assessment Page

Agriculture 1. Fragmented food safety system has caused inconsistent oversight, ineffective 

coordination, and inefficient use of resources ◐ 14

Defense 

2. Realigning DOD’s military medical command structures and consolidating 

common functions could increase efficiency and result in projected savings 

ranging from $281 million to $460 million annually ◐ 15

3. Opportunities exist for consolidation and increased efficiencies to maximize 

response to warfighter urgent needs ◐ 16

4. Opportunities exist to avoid unnecessary redundancies and improve the 

coordination of counter-improvised explosive device efforts ◐ 17

5. Opportunities exist to avoid unnecessary redundancies and maximize the 

efficient use of intelligence, surveillance, and reconnaissance capabilities ◐ 18

6. A departmentwide acquisition strategy could reduce DOD’s risk of costly 

duplication in purchasing Tactical Wheeled Vehicles ◐ 19

7. Improved joint oversight of DOD’s prepositioning programs for equipment 

and supplies may reduce unnecessary duplication ◐ 20

8. DOD’s business systems modernization: opportunities exist for optimizing 

business operations and systems ◐ 21

 

1

GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save Tax 

Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011). 

Enclosure I: Overall Progress Made in Each 

of the 81 Areas 
Page 8 GAO-12-453SP Follow-up on 2011 Report 

Mission Areas identified Assessment Page

Economic 

development 

9. The efficiency and effectiveness of fragmented economic development 

programs are unclear ◐ 23

10. The federal approach to surface transportation is fragmented, lacks clear 

goals, and is not accountable for results ◐ 25

11. Fragmented federal efforts to meet water needs in the U.S.-Mexico border 

region have resulted in an administrative burden, redundant activities, and an 

overall inefficient use of resources ○ 26

Energy 12. Resolving conflicting requirements could more effectively achieve federal fleet 

energy goals ○ 27

13. Addressing duplicative federal efforts directed at increasing domestic ethanol 

production could reduce revenue losses by more than $5.7 billion annually ● 28

General government 14. Enterprise architectures: key mechanisms for identifying potential overlap and 

duplication ◐ 29

15. Consolidating federal data centers provides opportunity to improve government 

efficiency ◐ 30

16. Collecting improved data on interagency contracting to minimize duplication 

could help the government leverage its vast buying power ◐ 31

17. Periodic reviews could help identify ineffective tax expenditures and 

redundancies in related tax and spending programs, potentially reducing 

revenue losses by billions of dollars ○ 32

Health 18. Opportunities exist for DOD and VA to jointly modernize their electronic health 

record systems ◐ 34

19. VA and DOD need to control drug costs and increase joint contracting

wherever it is cost-effective ◐ 35

20. HHS needs an overall strategy to better integrate nationwide public health 

information systems ○ 37

Homeland security/ 

Law enforcement 

21. Strategic oversight mechanisms could help integrate fragmented interagency 

efforts to defend against biological threats ◐ 38

22. DHS oversight could help eliminate potential duplicating efforts of interagency 

forums in securing the northern border ○ 39

23. The Department of Justice plans actions to reduce overlap in explosives 

investigations, but monitoring is needed to ensure successful implementation ● 40

24. TSA’s security assessments on commercial trucking companies overlap with 

those of another agency, but efforts are under way to address the overlap ◐ 41

25. DHS could streamline mechanisms for sharing security-related information

with public transit agencies to help address overlapping information ◐ 42

26. FEMA needs to improve its oversight of grants and establish a framework for 

assessing capabilities to identify gaps and prioritize investments ◐ 43

 
Page 9 GAO-12-453SP Follow-up on 2011 Report 

Mission Areas identified Assessment Page

International affairs 27. Lack of information sharing could create the potential for duplication of efforts 

between U.S. agencies involved in development efforts in Afghanistan ◐ 46

28. Despite restructuring, overlapping roles and functions still exist at State’s Arms 

Control and Nonproliferation Bureaus ● 47

Social services 29. Actions needed to reduce administrative overlap among domestic food 

assistance programs ○ 48

30. Better coordination of federal homelessness programs may minimize 

fragmentation and overlap ◐ 49

31. Further steps needed to improve cost-effectiveness and enhance services for 

transportation-disadvantaged persons ◐ 50

Training, employment, 

and education 

32. Multiple employment and training programs: providing information on colocating 

services and consolidating administrative structures could promote efficiencies ◐ 51

33. Teacher quality: proliferation of programs complicates federal efforts to invest 

dollars effectively ◐ 53

 34. Fragmentation of financial literacy efforts makes coordination essential ◐ 54

Legend: 

● = Addressed, meaning all actions needed in that area were addressed. 

◐= Partially addressed, meaning at least one action needed in that area showed some 

progress toward implementation, but not all actions were addressed. 

○ = Not addressed, meaning none of the actions needed in that area were addressed. 

Source: GAO analysis. 

As noted above, table 2 presents GAO’s assessment of the overall progress 

made in addressing the 47 cost-saving and revenue-enhancing areas. 
Page 10 GAO-12-453SP Follow-up on 2011 Report 

Table 2: Overall Progress Made to Address GAO Identified Cost-Saving and Revenue-Enhancing Areas, as of February 10, 

2012 

Mission Areas identified Assessment Page

Agriculture 35. Reducing some farm program payments could result in savings from 

$800 million over 10 years to up to $5 billion annually ○ 56

Defense 

36. DOD should assess costs and benefits of overseas military presence options 

before committing to costly personnel realignments and construction plans, 

thereby possibly saving billions of dollars 

◐ 57

37. Total compensation approach is needed to manage significant growth in military 

personnel costs ◐ 58

38. Employing best management practices could help DOD save money on its 

weapon systems acquisition programs ◐ 59

39. More efficient management could limit future costs of DOD’s spare parts

inventory ◐ 60

40. More comprehensive and complete cost data can help DOD improve the costeffectiveness of sustaining weapon systems ◐ 61

41. Improved corrosion prevention and control practices could help DOD avoid 

billions in unnecessary costs over time ◐ 63

Economic 

development 42. Revising the essential air service program could improve efficiency ◐ 64

43. Improved design and management of the universal service fund as it expands 

to support broadband could help avoid cost increases for consumers ◐ 66

44. The Corps of Engineers should provide Congress with project-level information 

on unobligated balances ◐ 67

Energy 45. Improved management of federal oil and gas resources could result in 

approximately $1.8 billion over 10 yearsa

◐ 68

General government 46. Efforts to address governmentwide improper payments could result in 

significant cost savings ◐ 70

47. Promoting competition for the over $500 billion in federal contracts could 

potentially save billions of dollars over time ◐ 71

48. Applying strategic sourcing best practices throughout the federal procurement 

system could saves billions of dollars annually ◐ 72

49. Adherence to new guidance on award fee contracts could improve agencies’ 

use of award fees to produce savings ◐ 73

50. Agencies could realize cost savings of at least $3 billion by continued disposal of 

unneeded federal real property ◐ 74

51. Improved cost analyses used for making federal facility ownership and leasing

decisions could save tens of millions of dollars ◐ 75

52. The Office of Management and Budget’s IT Dashboard reportedly has already 

resulted in $3 billion in savings and can further help identify opportunities to 

invest more efficiently in information technology 

◐ 76

53. Increasing electronic filing of individual income tax returns could reduce IRS’s 

processing costs and increase revenues by hundreds of millions of dollars ◐ 77

54. Using return on investment information to better target IRS enforcement could 

reduce the tax gap; for example, a 1 percent reduction would increase tax 

revenues by $3 billionb ◐ 78
Page 11 GAO-12-453SP Follow-up on 2011 Report 

Mission Areas identified Assessment Page

55. Better management of tax debt collection may resolve cases faster with lower 

IRS costs and increase debt collected ◐ 79

56. Broadening IRS’s authority to correct simple tax return errors could facilitate 

correct tax payments and help IRS avoid costly, burdensome audits ○ 80

57. Enhancing mortgage interest information reporting could improve tax 

compliance ○ 81

58. More information on the types and uses of canceled debt could help IRS limit 

revenue losses of forgiven mortgage debt ◐ 82

59. Better information and outreach could help increase revenues by tens or 

hundreds of millions of dollars annually by addressing overstated real estate tax 

deductions

◐ 83

60. Revisions to content and use of Form 1098-T could help IRS enforce higher 

education requirements and increase revenues ◐ 84

61. Many options could improve the tax compliance of sole proprietors and begin to 

reduce their $68 billion portion of the tax gap ○ 85

62. IRS could find additional businesses not filing tax returns by using third-party 

data, which show such businesses have billions of dollars in sales ◐ 86

63. Congress and IRS can help S corporations and their shareholders be more tax 

compliant, potentially increasing tax revenues by hundreds of millions of dollars 

each year 

◐ 87

64. IRS needs an agencywide approach for addressing tax evasion among the at 

least 1 million networks of businesses and related entities ◐ 88

65. Opportunities exist to improve the targeting of the $6 billion research tax credit

and reduce forgone revenue ○ 89

66. Converting the new markets tax credit to a grant program may increase 

program efficiency and significantly reduce the $3.8 billion 5-year revenue cost of 

the program ○ 90

67. Limiting the tax-exempt status of certain governmental bonds could yield 

revenue ○ 91

68. Adjusting civil tax penalties for inflation potentially could increase revenues by 

tens of millions of dollars per year, not counting any revenues that may result 

from maintaining the penalties’ deterrent effect 

◐ 92

69. IRS may be able to systematically identify nonresident aliens reporting 

unallowed tax deductions or credits ● 93

70. Tracking undisbursed balances in expired grant accounts could facilitate the 

reallocation of scarce resources or the return of funding to the Treasury ○ 94

Health 71. Preventing billions in Medicaid improper payments requires sustained attention 

and action by CMS ◐ 95

72. Federal oversight over Medicaid supplemental payments needs improvement, 

which could lead to substantial cost savings ○ 96

73. Better targeting of Medicare’s claims review could reduce improper payments ◐ 97

74. Potential savings in Medicare’s payment for health care ◐ 98
Page 12 GAO-12-453SP Follow-up on 2011 Report 

Mission Areas identified Assessment Page

Homeland security/ 

Law enforcement 

75. DHS’s management of acquisitions could be strengthened to reduce cost 

overruns and schedule and performance shortfalls ◐ 100

76. Improvements in managing research and development could help reduce 

inefficiencies and costs for homeland security ◐ 102

77. Validation of TSA’s behavior-based screening program is needed to justify 

funding or expansion ◐ 104

78. More efficient baggage screening systems could result in about $470 million in 

reduced TSA personnel costs over the next 5 years ◐ 106

79. Clarifying availability of certain customs fee collections could produce a onetime savings of $640 million ◐ 107

Income security 

80. Social Security needs data on pensions from noncovered earnings to better 

enforce offsets and ensure benefit fairness, estimated to result in $2.4-$2.9 

billion savings over 10 years ○ 108

International affairs 81. Congress could pursue several options to improve collection of antidumping and 

countervailing duties. ○ 109

Legend: 

● = Addressed, meaning all actions needed in that area were addressed. 

◐= Partially addressed, meaning at least one action needed in that area showed some 

progress toward implementation, but not all actions were addressed. 

○ = Not addressed, meaning none of the actions needed in that area were addressed. 

Source: GAO analysis. 

a

The Department of the Interior, Bureau of Land Management, updated the anticipated revenues from 

$1.75 billion to $1.8 billion in its fiscal year 2012 budget justification. 

b

The net tax gap was updated in 2012 and estimated to be $385 billion for the 2006 tax year. Thus, a 

1 percent reduction would increase tax revenues by $3.8 billion. 
Page 13 GAO-12-453SP Follow-up on 2011 Report 

Enclosure II: Progress Update for Each of the 

176 Actions Needed within the 81 Areas 
Page 14 GAO-12-453SP Follow-up on 2011 Report 

Agriculture 

1. Fragmented food safety system has caused 

inconsistent oversight, ineffective coordination, and 

inefficient use of resources 

Action 1 progress 

OMB participates in the President’s Food Safety Working Group, created in 

March 2009, to coordinate federal efforts and set food safety goals to make food 

safer. OMB and the federal agencies that have food safety responsibilities have 

not developed a plan to improve coordination and provide a comprehensive 

picture of, or performance measures for, the federal government’s food safety 

efforts. However, governmentwide coordination may be fostered by the 

provisions of the FDA Food Safety Modernization Act that require interagency 

coordination, including the preparation of certain reports and plans.1

 For 

example, in April 2011, the Department of Health and Human Services (HHS) 

issued its first annual report on interagency coordination and cooperation on 

food safety inspections, as required by the act. In addition, in December 2011 

the Food Safety Working Group released a report describing the steps it has 

taken over the past 2 years to improve food safety, its plans for the next year, 

and how the agencies are coordinating on these efforts. Taken together, these 

reports by HHS and the Food Safety Working Group are first steps that may help 

address interagency coordination on food safety and inform a governmentwide 

plan. 

Action 2 progress 

No legislative action identified. 

 

Action 3 progress 

The FDA Food Safety Modernization Act, which was signed into law in January 

2011, is intended to strengthen a major part of the food safety system, but does 

not apply to the entire federal food safety system or create a new risk-based 

food safety structure. The law does, however, include several sections that 

require interagency coordination on food safety oversight in areas such as 

inspections, seafood safety, and food imports. 

 

1

Pub. L. No. 111-353 (2011).

Overall assessment

◐

Action 1 

The Office of Management and Budget 

(OMB) in consultation with the relevant 

agencies should develop a 

governmentwide performance plan for 

food safety that includes resultsoriented goals and performance 

measures and a discussion of 

strategies and resources. 

Partially addressed ◐ 

Action 2 

Congress should consider 

commissioning the National Academy 

of Sciences or a blue ribbon panel to 

conduct a detailed analysis of 

alternative food safety organizational 

structures. 

Not addressed ○

Action 3 

Congress should consider enacting 

comprehensive risk-based food safety 

legislation. 

Not addressed ○

For more information, contact Lisa Shames at 

(202) 512-3841 or shamesl@gao.gov.

See GAO-11-318SP Actions Needed
Page 15 GAO-12-453SP Follow-up on 2011 Report 

Defense 

2. Realigning DOD’s military medical command 

structures and consolidating common functions could 

increase efficiency and result in projected savings ranging 

from $281 million to $460 million annually2

Action 1 progress 

In June 2011, the Deputy Secretary of Defense commissioned a task force to 

provide a report that includes an assessment of the governance of the military 

health system as a whole and in multi-service medical markets. This review was 

completed in September 2011, but the final report, with recommendations, has 

not been officially released. According to senior DOD officials, this report will be 

used as the basis for a report required by the National Defense Authorization Act 

for Fiscal Year 2012;3

 however, the act did not establish a completion date for 

the report. Specifically, the act requires the Secretary of Defense to submit to 

Congress a report that includes, among other things, a description of options 

developed and considered for the military health system’s governance model, 

analysis of the strengths and weaknesses of each option, and estimated costs 

savings of each option, if any. The act also mandated that the Comptroller 

General conduct a detailed review of those governance options, and report on 

that review to Congress not later than 180 days after the submission of the 

Secretary of Defense’s report. The act restricts the ability of the Secretary of 

Defense to restructure or reorganize the military health system until 120 days 

after the Comptroller General’s report is submitted. 

 

2

CNA’s Center for Naval Analyses developed the savings estimates, and GAO adjusted 

the estimates from 2005 to 2010 dollars.

3

Pub. L. No. 112-81, § 716 (2011).

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

could take action to further assess 

alternatives for restructuring the 

governance structure of the military 

health care system. 

Partially addressed ◐

For more information, contact Brenda S. 

Farrell at (202) 512-3604 or 

FarrellB@gao.gov. 

See GAO-11-318SP Actions Needed 
Page 16 GAO-12-453SP Follow-up on 2011 Report 

Defense 

3. Opportunities exist for consolidation and increased 

efficiencies to maximize response to warfighter urgent 

needs 

Action 1 progress 

In March 2011, DOD began an evaluation of the department’s processes for the 

rapid fielding of capabilities in response to urgent operational needs, as required 

by the Ike Skelton National Defense Authorization Act for Fiscal Year 2011;4

however, the department has not yet completed its evaluation. According to the 

department, this evaluation, which was due in January 2012, will be delivered 

later in 2012 and will examine areas of duplication identified by GAO, evaluate 

the potential for consolidations, and describe specific policy actions implemented 

to improve the department's overall urgent needs processes. DOD officials also 

noted other actions it has taken, including the establishment of a senior-level 

working group in June 2011 to provide oversight of DOD-wide efforts to fulfill 

urgent needs. Also, DOD issued guidance in January 2012, in part to 

standardize the definition of an urgent operational need. 

 

4

See Pub. L. No. 111-383, § 804(a) (2011) (10 U.S.C. § 2302 note).

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

needs to perform its own analysis of 

options aimed at potential 

consolidations and increased 

efficiencies in streamlining its urgent 

needs entities and processes. This 

analysis should carefully weigh the 

advantages and disadvantages of the 

options identified to determine the 

optimal course of action. 

Partially addressed ◐

For more information, contact Cary Russell at 

(404) 679-1808 or russellc@gao.gov. 

See GAO-11-318SP Actions Needed
Page 17 GAO-12-453SP Follow-up on 2011 Report 

Defense 

4. Opportunities exist to avoid unnecessary redundancies 

and improve the coordination of counter-improvised 

explosive device efforts 

Action 1 progress 

JIEDDO is currently developing a new information technology architecture, and 

plans to develop a database for counter-IED efforts across DOD as part of this 

new architecture. However, this effort is in the conceptualization stage, and DOD 

officials do not anticipate completion before the end of fiscal year 2012. Further, 

according to JIEDDO, in early 2012 DOD plans to revise the directive 

establishing JIEDDO to require the services and DOD agencies to report 

counter-IED initiatives to JIEDDO. 

Overall assessment

◐

Action 1 

The Department of Defense’s (DOD) 

senior leadership, to include the 

Deputy Secretary of Defense, should 

consider what actions the department 

can take to assure that the Joint 

Improvised Explosive Device Defeat 

Organization (JIEDDO) can centrally 

collect information and coordinate 

efforts, and whether it should enhance 

its tools to ensure all information on 

departmentwide counter-improvised 

explosive device (IED) programs is 

centrally collected and evaluated to 

limit unnecessary duplication, overlap, 

and fragmentation. 

Partially addressed ◐

For more information, contact Cary Russell at 

(404) 679-1808 or russellc@gao.gov.

See GAO-11-318SP Actions Needed
Page 18 GAO-12-453SP Follow-up on 2011 Report 

Defense 

5. Opportunities exist to avoid unnecessary redundancies 

and maximize the efficient use of intelligence, 

surveillance, and reconnaissance capabilities 

Action 1 progress 

DOD is designing an intelligence, surveillance, and reconnaissance architecture, 

called the “Defense Intelligence Information Enterprise,” to provide a common 

framework of tools for security and intelligence sharing. DOD plans to begin 

implementing the Defense Intelligence Information Enterprise framework in fiscal 

year 2013 and intends to revise its departmentwide strategic goals in its next 

intelligence, surveillance, and reconnaissance strategic plan. 

Action 2 progress 

DOD continues to explore collaborative portfolio management tools that capture 

operational needs and consider the measured or projected performance of 

intelligence, surveillance, and reconnaissance systems. The Office of the Under 

Secretary of Defense for Intelligence is collaborating with the Joint Staff to 

enhance their developmental decision support tool to address operational 

requirements and inform investment decisions across its intelligence enterprise. 

DOD has not yet completed development of this tool. In addition, DOD plans to 

develop and include performance metrics in its 2012 strategic plan. 

Action 3 progress 

Recent agreements between the Director of National Intelligence and the Under 

Secretary of Defense (Intelligence) have resulted in the creation of the 

Consolidated Intelligence Guidance, which is expected to help synchronize 

investments between the Director of National Intelligence and DOD. According 

to DOD, this guidance, issued for fiscal year 2012, is goal-based and is 

designed to improve effectiveness in managing the shorter-term decisions in 

future defense budgets, acquisition plans, and investment decisions. DOD 

officials stated that this guidance has resulted in better alignment of investments 

with strategic goals. DOD plans to explicitly address the linkages between 

strategic goals and planned investments in the next intelligence, surveillance, 

and reconnaissance strategic plan scheduled for release in spring 2012. 

Action 4 progress 

DOD stated that it is developing new methodologies for intelligence information 

sharing, such as the Distributed Common Ground/Surface System, to facilitate 

integration of intelligence capabilities, provide tools and systems that can work 

together to fulfill mission requirements, and share information among war 

fighting and coalition partners. DOD officials stated that the department plans to 

include standards for information sharing and timelines for information sharing in 

its new Defense Intelligence Information Enterprise framework. 

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

could develop an integrated 

intelligence, surveillance, and 

reconnaissance architecture, including 

manned and unmanned systems, to 

align departmentwide strategic goals. 

Partially addressed ◐

Action 2 

DOD could continue to develop tools—

such as the Joint Staff’s decision 

support tool—and performance 

measures to inform investment 

decisions. 

Partially addressed ◐

Action 3 

DOD could establish linkages between 

intelligence, surveillance, and 

reconnaissance acquisition plans and 

strategic goals to better inform 

investment decisions. 

Partially addressed ◐

Action 4 

DOD could develop and enforce 

commonality and interoperability 

standards for sharing of intelligence, 

surveillance, and reconnaissance data 

and establish timelines for 

implementation. 

Partially addressed ◐

For more information, contact Brian Lepore at 

(202) 512-4523 or leporeb@gao.gov.

See GAO-11-318SP Actions Needed
Page 19 GAO-12-453SP Follow-up on 2011 Report 

Defense 

6. A departmentwide acquisition strategy could reduce 

DOD’s risk of costly duplication in purchasing Tactical 

Wheeled Vehicles 

Action 1 progress 

DOD has taken steps to begin implementing this action; however, the 

department has not completed a tactical wheeled vehicle strategy or conducted 

a cost-benefit analysis for the acquisition and support costs of various programs. 

The Office of the Under Secretary of Defense for Acquisition, Technology, and 

Logistics has initiated a Ground Vehicle Portfolio Review, through which it plans 

to develop a unified, comprehensive, long-term tactical wheeled vehicle strategy 

that describes to key stakeholders how DOD plans to acquire and sustain an 

operationally relevant fleet. According to DOD officials, the portfolio review is 

planned to be continuous; outputs will support relevant program milestone 

decisions and annual program reviews, and will be closely coordinated with the 

service strategies. Phase 1 of the portfolio review, which is intended to build a 

comprehensive description of the current Tactical Wheeled Vehicle and Ground 

Combat Vehicle fleets, is under way. Milestones for subsequent phases will be 

established during Phase 1. Subsequent phases of the portfolio review should 

benefit from the knowledge resulting from planned near-term decisions, 

including budget decisions, regarding Joint Light Tactical Vehicle capabilities, 

High Mobility Multipurpose Wheeled Vehicle recapitalization, sustainment of the 

Mine Resistant Ambush Protected family of vehicles, and budgeted acquisition 

and support costs associated with those vehicles. In addition, the Army and 

Marine Corps updated their individual tactical wheeled vehicle strategies in 

January 2011 and June 2011, respectively. 

Additionally, in March 2011, as directed by the Senate Armed Services 

Committee, both services provided congressional defense committees with 

acquisition strategies and plans for recapitalizing their respective High Mobility 

Multipurpose Wheeled Vehicle fleets. These plans are currently under review in 

light of the department’s ongoing work to align strategic priorities and its budget. 

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

needs to complete its planned 

departmentwide tactical wheeled 

vehicle strategy to determine (1) what 

capabilities the Joint Light Tactical 

Vehicle will have, (2) the scope and 

cost of any recapitalization of other 

vehicles or production effort, and (3) 

the sustainment cost of placing the 

Mine Resistant Ambush Protected 

family of vehicles in its force structures. 

DOD should include in the strategy a 

cost-benefit analysis that could 

minimize the collective acquisition and 

support costs of the various tactical 

wheeled vehicle programs and reduce 

the risk of unplanned overlap or 

duplication. 

Partially addressed ◐

For more information, contact Belva Martin at 

(202) 512-4841 or martinb@gao.gov.

See GAO-11-318SP Actions Needed
Page 20 GAO-12-453SP Follow-up on 2011 Report 

Defense 

7. Improved joint oversight of DOD’s prepositioning 

programs for equipment and supplies may reduce 

unnecessary duplication 

Action 1 progress 

DOD has taken some actions to strengthen joint oversight of prepositioned 

stocks. For example, DOD broadened membership of its Global Prepositioning 

Materiel Capabilities Working Group to include a core member from the Office of 

the Under Secretary of Defense for Policy, the office responsible for developing 

related departmentwide prepositioned stocks strategy. DOD has also added joint 

staff representatives to this group. However, additional action is needed to codify 

lines of authority and reporting between the working group and DOD 

components. 

Action 2 progress 

DOD officials have stated that the department is examining opportunities to 

synchronize DOD prepositioning efforts as part of two ongoing departmentwide 

studies to determine how to manage prepositioned stocks. One study was 

planned for completion in the fall of 2011, but has not yet been released. 

According to a DOD official, the other study is projected for completion in 2012. 

However, DOD has not yet completed updating its requirements or identifying 

specific ways that prepositioned assets can be managed more efficiently. 

Action 3 progress 

No executive action taken. 

Overall assessment

◐

Action 1 

The Secretary of Defense should direct 

the Under Secretary of Defense for 

Acquisition, Technology, and Logistics, 

in coordination with the Chairman of 

the Joint Chiefs of Staff, to strengthen 

the Department of Defense’s (DOD) 

joint oversight of its prepositioned 

stocks through such actions as 

clarifying lines of authority and 

reporting between the joint 

prepositioning working group and other 

components within DOD. 

Partially addressed ◐

Action 2 

The Secretary of Defense should direct 

the Chairman of the Joint Chiefs of 

Staff and the Secretaries of the military 

services to synchronize at a 

departmentwide level, as appropriate, 

the services’ prepositioning programs 

so that they include updated 

requirements and maximize efficiency 

in managing prepositioned assets and 

activities across the department to 

reduce unnecessary duplication.

Partially addressed ◐

Action 3 

The Secretary of Defense should direct 

the Office of the Under Secretary of 

Defense for Policy to develop strategic 

guidance that includes planning and 

resource priorities, linking the 

department’s current and future needs 

for prepositioned stocks to evolving 

national defense objectives. 

Not addressed ○

For more information, contact Cary Russell at 

(404) 679-1808 or russellc@gao.gov.

See GAO-11-318SP Actions Needed
Page 21 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

DOD continues to release updates to its corporate enterprise architecture, but 

the architecture has yet to be federated through development of aligned 

subordinate architectures for each of the military departments. In this regard, 

each of the military departments has made progress in managing its respective 

architecture program. For example, each department has established or is in the 

process of establishing an executive committee with responsibility and 

accountability for the enterprise architecture. However, there are still limitations 

in the scope and completeness, as well as the maturity of the military 

department architecture programs. For example, no military department has fully 

developed an enterprise architecture methodology or a well-defined business 

enterprise architecture and transition plan to guide and constrain business 

transformation initiatives. 

In April 2011, DOD’s Deputy Chief Management Officer issued a memorandum 

that requires integration of end-to-end business models and use of common 

standards for the development of the Business Enterprise Architecture and all 

subordinate architectures that federate or assert compliance with the Business 

Enterprise Architecture. While DOD recently drafted a technical transition plan 

that describes a vision for how standards will benefit the implementation of and 

ensure compliance with the Business Enterprise Architecture, the department 

has yet to finalize this plan or provide additional details for the plan’s execution 

with associated timelines and metrics. 

Action 2 progress 

DOD has taken minimal steps to avoid duplicative investments, and it has yet to 

develop a well-defined federated architecture along with well-defined investment 

management policies and procedures that it could use to manage the thousands 

of business systems in a consistent, repeatable, and effective manner and that, 

among other things, maximizes mission performance while minimizing or 

eliminating system overlap and duplication. DOD officials have stated that 

operational activities identified by programs in its systems repository can be 

compared by the investment review boards to identify those activities that are 

100 percent identical. However, this process depends on self-reported data from 

the programs, and there is little validation or verification of the information. DOD 

officials have also stated that they are working on selecting tools that, along with 

their adoption of common business process modeling standards, will allow them 

to compare activities proposed in a new investment to activities and services 

defined in the architecture. However, success of this type of tool depends on the 

amount of activities and services defined in the architecture, and the department 

has more work to do in this area. For example, DOD has identified 15 business 

processes to be defined in the Business Enterprise Architecture; however, only 2 

of these processes will be fully defined by the end of fiscal year 2012. 

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

needs to develop supporting 

component architectures and align 

them with its corporate architecture to 

complete the federated business 

enterprise architecture. 

Partially addressed ◐

Action 2 

DOD should leverage its federated 

architecture to avoid investments that 

provide similar but duplicative 

functionality in support of common 

DOD activities. 

Not addressed ○

Defense 

8. DOD’s business systems modernization: opportunities 

exist for optimizing business operations and systems 
Page 22 GAO-12-453SP Follow-up on 2011 Report 

Action 3 progress 

DOD continues to establish investment management processes, but neither 

department-level organizations nor the military departments have 

institutionalized the full range of project-level and portfolio-based information 

technology investment management policies and procedures that are necessary 

to meet the investment selection and control provisions of the Clinger-Cohen Act 

of 1996.5

 Specifically, GAO found that the DOD enterprise, Air Force, and Navy 

have yet to fully define 56 percent of the project-level practices, and Army has 

yet to do so for 78 percent of the practices.6

 With regard to the portfolio-level 

practices, DOD enterprise, Air Force, and Navy have yet to fully define 80 

percent, and Army has yet to do so for any of the practices. For example, while 

DOD and the military departments have a process that calls for investments to 

be, among other things, compliant with DOD’s Business Enterprise Architecture 

and economically justified, this process does not specify how the investment 

review boards are to use the full range of cost, schedule, and benefit data in 

making selection (i.e., certification) decisions. 

Action 4 progress 

DOD has taken steps to increase acquisition oversight for some business 

system modernization investments, but ensuring that effective system 

acquisition and management controls are implemented on each business 

system investment continues to remain a formidable challenge. GAO continues 

to identify weaknesses in such areas as architectural alignment, informed 

investment decision making, earned value management, economic justification, 

risk management, requirements management, and test management.7

 In 

February 2011, the milestone decision authority for major business systems 

(except for logistics) was delegated to the Deputy Chief Management Officer, 

who was also given authority to assign an overarching integrated product team 

lead to coordinate preparation for acquisition decisions. This change in policy 

should provide the Deputy Chief Management Officer with increased acquisition 

insight and control for several of the largest business systems modernization 

investments, which include key enterprise resource programs that account for 

billions of dollars of development funding intended to transform DOD's business 

operations. Further, in June 2011, the Under Secretary of Defense for 

Acquisition, Technology, and Logistics established a policy requiring the use of 

the Business Capabilities Lifecycle as the acquisition process for defense 

business systems modernizations with a total cost of over $1 million. While the 

Business Capabilities Lifecycle is intended to divide system development into 

discrete, fully-funded, and manageable increments to facilitate development and 

implementation, it is too early to determine the extent to which this new process 

will improve acquisition management controls. An independent risk assessment 

for major investments was developed to provide information to milestone 

decision authorities before major milestone decisions. According to officials, four 

such reviews have occurred in the last 2 years. However, DOD has not fully 

demonstrated how these risk assessments have influenced investment decision 

makers. 

 

5

40 U.S.C. §§ 11311-11313.

6

GAO, Department of Defense: Further Actions Needed to Institutionalize Key Business 

System Modernization Management Controls, GAO-11-684 (Washington, D.C.: June 29, 

2011).

7

GAO-11-684 and GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: 

February 2011).

Action 3 

DOD should work to institutionalize its 

business systems investment process 

at all levels of the organization. 

Partially addressed ◐

Action 4 

DOD must ensure that effective system 

acquisition management controls are 

implemented on each business system 

investment. 

Partially addressed ◐

For more information, contact Valerie C. 

Melvin at (202) 512-6304 or 

melvinv@gao.gov.

See GAO-11-318SP Actions Needed

Defense 

8. DOD’s business systems modernization (continued) 
Page 23 GAO-12-453SP Follow-up on 2011 Report 

Economic Development 

9. The efficiency and effectiveness of fragmented 

economic development programs are unclear

Action 1 progress 

Three of the four agencies have taken initial steps to implement at least one of 

the collaborative practices that GAO has previously identified to administer their 

economic development programs.8

 For example, in April 2010 the U.S. 

Department of Agriculture (USDA) and the Small Business Administration (SBA) 

signed a memorandum of understanding (MOU) in response to GAO’s 

recommendation that defined and articulated a common outcome focused on 

improving service delivery to small businesses in underserved rural areas. 

Under the MOU, USDA and SBA agreed that their field offices would advise 

potential borrowers of the other agency’s programs that may meet their small 

business financing needs and coordinate the referral of small business 

applicants to one another where appropriate, work to make each agency’s 

programs more complementary by minimizing differences in program fees and 

processing and closing procedures, and develop joint training seminars on each 

agency’s programs. In addition, USDA and SBA agreed to measure progress 

under the MOU. USDA’s April 2011 survey of state directors indicates progress 

under the MOU in several areas, including field offices advising borrowers of 

SBA’s programs, referring borrowers to SBA and its resource partners, and 

exploring ways to make USDA and SBA programs more complementary. The 

Department of Commerce (Commerce) also provided information on its 

collaborative efforts with other federal agencies. For example, according to 

Economic Development Administration (EDA) officials, the agency has led an 

interagency effort called the i6 Challenge, which leverages resources from 

multiple federal agencies, with the common goal of spurring commercialization 

and manufacturing. The Department of Housing and Urban Development (HUD) 

has not taken similar steps to define and articulate common outcomes with other 

federal agencies. Moreover, HUD, USDA, and SBA have provided limited 

evidence that they have taken steps to develop compatible policies or 

procedures with other federal agencies, or to search for opportunities to 

leverage physical and administrative resources with their federal partners.

Action 2 progress 

The four agencies have made minimal progress to collect more accurate and 

complete data on the outcomes for each of their economic development 

programs and to use the information to assess the effectiveness of each 

program. However, each agency has recently provided information on its plans 

to address this action. For example, EDA is developing a new performance 

management logic model to help EDA understand how various inputs, activities, 

outputs, and outcomes lead the agency to its desired vision of economic growth 

and prosperity. In addition, HUD officials told us that the department has plans 

for improving the quality of data for its Community Development Block Grant 

(CDBG) programs. In fiscal year 2012, HUD plans to fund improvements to its 

Integrated Disbursement and Information System; these improvements are 

intended to improve HUD’s ability to track the progress of CDBG grantees in 

implementing activities and gather improved performance data. Similarly, 

according to USDA officials, the Rural Business Program office is in the process 

of updating its policies, procedures, and program guidelines in an effort to 

improve the accuracy and reliability of its program data. Finally, according to 

SBA officials, its Offices of International Trade and Entrepreneurial Development 

are implementing processes to capture outcomes for their respective programs. 

 

8

GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save Tax 

Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 2, 2011). 

Overall assessment

◐

Action 1 

The Departments of Commerce, 

Housing and Urban Development, and 

Agriculture, and the Small Business 

Administration need to further utilize 

promising practices for enhanced 

collaboration. The actions that the four 

agencies should consider include 

seeking more opportunities for 

resource-sharing across economic 

development programs with shared 

outcomes, and identifying ways to 

leverage each program’s strengths to 

improve their existing collaborative 

efforts. 

Partially addressed ◐

Action 2 

The Departments of Commerce, 

Housing and Urban Development, and 

Agriculture, and the Small Business 

Administration need to collect accurate 

and complete data on program 

outcomes and use the information to 

assess each program’s effectiveness. 

Not addressed ○
Page 24 GAO-12-453SP Follow-up on 2011 Report 

Economic Development 

9. Economic development programs (continued)

Action 3 progress 

No executive action taken. 

Action 3 

Additional work to assess progress in 

collaboration and evaluation could 

identify areas for improvement, 

consolidation, or elimination. More 

analysis is needed by the Departments 

of Commerce, Housing and Urban 

Development, and Agriculture, and the 

Small Business Administration and the 

Office of Management and Budget to 

determine the actual amount of 

duplicative spending in programs that 

are designed to target similar 

economic development activities, 

locations, and applicants. 

Not addressed ○

For more information, contact William B. 

Shear at (202) 512-8678 or shearw@gao.gov.

See GAO-11-318SP Actions Needed
Page 25 GAO-12-453SP Follow-up on 2011 Report 

Economic Development 

10. The federal approach to surface transportation is 

fragmented, lacks clear goals, and is not accountable for 

results 

Action 1 progress 

Comprehensive legislative action has not been taken to fundamentally reexamine the nation’s surface transportation policies. However, several 

congressional committees have approved bills to reauthorize and reform surface 

transportation programs. For example, the Senate Environment and Public 

Works Committee approved a bill on November 9, 2011, reauthorizing the 

highway portion of the surface transportation program.9

 This bill contains 

measures to increase accountability for results by entities receiving federal funds 

and consolidate federal programs. In addition, the House Transportation and 

Infrastructure Committee approved a bill on February 2, 2012, that includes 

consolidating or eliminating a number of programs.10 When GAO completed its 

work for this report, floor action was pending in the Senate. GAO is evaluating 

the extent to which ongoing legislative actions better define federal roles and 

goals, incorporate accountability for results, emphasize return on federal 

investment, and ensure fiscal sustainability. 

 

9

S. 1813, 112th Cong. (2011). 

10H.R. 7, 112th Cong. (2012).

Overall assessment

◐

Action 1 

A fundamental re-examination and 

reform of the nation's surface 

transportation policies is needed. 

GAO has identified a number of 

principles that can help guide 

Congress in re-examining and 

reforming the nation’s surface 

transportation policies. These 

principles include ensuring the federal 

role is defined based on identified 

areas of national interest and goals, 

incorporating accountability for results 

by entities receiving federal funds, 

employing the best tools and 

approaches to emphasize return on 

targeted federal investment, and 

ensuring fiscal sustainability. Applying 

these principles to a re-examination 

and reform of surface transportation 

programs would potentially result in a 

more clearly defined federal role in 

relation to other levels of government 

and thus a more targeted federal role 

focused around evident national 

interests. 

Partially addressed ◐

For more information, contact Susan Fleming 

at (202) 512-2834 or FlemingS@gao.gov.

See GAO-11-318SP Actions Needed
Page 26 GAO-12-453SP Follow-up on 2011 Report 

Economic Development 

11. Fragmented federal efforts to meet water needs in 

the U.S.-Mexico border region have resulted in an 

administrative burden, redundant activities, and an overall 

inefficient use of resources 

Action 1 progress 

No legislative action identified. 

In January 2012, officials from several of the federal agencies11 said they are 

working to coordinate their efforts in the border region within the current 

statutory authorities that exist; however, GAO continues to believe that a task 

force would allow the agencies to better coordinate. GAO notes that the 

administration has established the White House Rural Council to coordinate 

federal funding provided to rural communities, which may provide the 

opportunity to coordinate agencies’ infrastructure funding in the border region. 

 

11These federal agencies include the Environmental Protection Agency, the Department 

of Agriculture, the Department of Housing and Urban Development, the U.S. Army Corps 

of Engineers, the Department of Health and Human Service’s Indian Health Service, the 

Department of Commerce’s Economic Development Administration, and the Department 

of the Interior’s Bureau of Reclamation.

Overall assessment

○

Action 1 

Congress may wish to consider 

requiring federal agencies to establish 

an interagency mechanism or process, 

such as a task force on water and 

wastewater infrastructure, in the border 

region. Congress could direct a group 

or task force to conduct certain 

activities. Specifically, GAO suggested 

that a task force, in partnership with 

state and local officials, should 

leverage collective resources to 

identify needs within the border region 

and establish compatible and 

coordinated polices across relevant 

agencies, such as a coordinated 

process for the selection of projects, 

and standardize applications, 

environmental review requirements, 

and engineering requirements to the 

extent possible. 

Not addressed ○

For more information, contact David C. 

Trimble at (202) 512-3841 or 

trimbled@gao.gov.

See GAO-11-318SP Actions Needed 
Page 27 GAO-12-453SP Follow-up on 2011 Report 

Energy 

12. Resolving conflicting requirements could more 

effectively achieve federal fleet energy goals 

Action 1 progress 

No legislative action identified. 

However, there has been related executive branch action. In May 2011, the 

President issued additional directives for federal fleet managers in his 

Presidential Memorandum on Federal Fleet Performance. Among other 

activities, this memorandum directs that by the end of 2015, all light-duty federal 

fleet vehicle acquisitions must be alternative-fueled vehicles. According to 

Department of Energy officials, this order does not reconcile conflicting 

requirements that federal fleets increase use of alternative fuels, reduce 

petroleum use, and reduce greenhouse gas emissions or provide additional 

flexibility to fleet managers, but the order does require activities that will help 

meet existing requirements. 

Overall assessment

○

Action 1 

Changes in existing laws could 

streamline the requirements and 

provide fleet managers with more 

flexibility in meeting goals. 

Not addressed ○

For more information, contact Susan Fleming 

at (202) 512-2834 or flemings@gao.gov.

See GAO-11-318SP Actions Needed
Page 28 GAO-12-453SP Follow-up on 2011 Report 

Energy 

13. Addressing duplicative federal efforts directed at 

increasing domestic ethanol production could reduce 

revenue losses by more than $5.7 billion annually 

Action 1 progress 

Congress allowed the VEETC to expire at the end of 2011. The most recent 

extension of the credit—set at 45-cents-per-gallon in the Tax Relief, 

Unemployment Insurance Reauthorization, and Job Creation Act of 201012—

expired on December 31, 2011. Fuel blenders that purchase and blend ethanol 

with gasoline no longer receive the credit. 

 

12Pub. L. No. 111-312 (2010).

Overall assessment

●

Action 1 

Congress may wish to consider 

whether revisions to the ethanol tax 

credit are needed. Options could 

include the following: 

 Maintain the volumetric ethanol 

excise tax credit (VEETC) at 

current levels. 

 Allow the VEETC to expire at the 

end of 2011. 

 Reduce the VEETC as Congress 

did in the 2008 Farm Bill, when the 

ethanol tax credit was reduced 

from 51 cents to 45 cents per 

gallon. 

 Phase out the VEETC over a 

number of years. 

 Modify the VEETC to counteract 

fluctuations in other commodities 

that can influence ethanol 

production, such as changes in 

crude oil prices. For instance, the 

ethanol tax credit could increase 

when crude oil prices are low and 

decrease when crude oil prices are 

high. 

Addressed ●

For more information, contact Frank Rusco at 

(202) 512-3841 or ruscof@gao.gov

See GAO-11-318SP Actions Needed
Page 29 GAO-12-453SP Follow-up on 2011 Report 

General Government 

14. Enterprise architectures: key mechanisms for 

identifying potential overlap and duplication 

Action 1 progress 

The majority of the enterprise architecture efforts of the 27 agencies GAO 

reviewed can still be viewed as a work in progress, with much remaining to be 

accomplished. Since we reported in March 2011 that the Department of the 

Interior demonstrated that it had used enterprise architecture to avoid costs, an 

additional 4 agencies have measured and reported financial benefits from their 

respective enterprise architecture programs: 

 Department of Agriculture expects to save $27 million over 5 years (2011 

through 2015) by moving 120,000 e-mail users to a cloud-based solution. 

 Department of Defense, Office of the Secretary, described in its April 2011 

Congressional Report on Defense Business Operations about $179 million 

in financial savings between fiscal years 2008 and 2010 by streamlining 

Navy business operations, retiring legacy systems, and moving toward a 

real-time paperless business environment that reduces time and costs for 

processing vendor payments. 

 Nuclear Regulatory Commission achieved an estimated $1.3 million cost 

avoidance in 2011 by eliminating duplicative staff planning systems. 

 Department of Health and Human Services saved about $21 million while 

sustaining increased network usage in fiscal year 2011 by moving to a new 

telecommunications contract, which was facilitated by its enterprise 

architecture program. 

Twelve agencies reported financial benefits; however, they did not reliably 

measure them (i.e., they did not provide supporting documentation): 

 Department of Commerce; 

 Department of Education; 

 Department of Energy; 

 Department of Homeland Security; 

 Department of Justice; 

 Department of Transportation; 

 Office of Personnel Management; 

 General Services Administration; 

 Small Business Administration; 

 Social Security Administration; 

 Department of the Army; and 

 Department of State. 

An additional 10 agencies did not report financial benefits, although 8 of these 

agencies reported that they have established or expect to establish a process to 

measure benefits in the future: 

 Department of the Air Force; 

 Department of Housing and Urban 

Development; 

 Department of Labor; 

 Department of the Navy; 

 Department of the Treasury; 

 Department of Veterans Affairs; 

 Environmental Protection Agency; 

 National Aeronautics and Space 

Administration; 

 National Science Foundation; and 

 U.S. Agency for International 

Development.

Overall assessment

◐

Action 1 

Agencies should measure and report 

enterprise architecture results and 

outcomes (e.g., costs avoided through 

eliminating duplicative information 

technology investments). 

 Partially addressed ◐

For more information, contact David A. 

Powner at (202) 512-9286 or 

pownerd@gao.gov.

See GAO-11-318SP Actions Needed
Page 30 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

The administration’s Implementation Plan to Reform Information Technology, 

dated December 2010, identifies steps and milestones to (1) consolidate at least 

800 federal data centers by 2015, and (2) establish a governmentwide 

marketplace for data center availability in 2012. 

In July 2011, OMB required the 24 federal agencies participating in the Federal 

Data Center Consolidation Initiative to complete their consolidation plans. 

Beginning in October 2011, all of the agencies posted their updated plans 

online. GAO has ongoing work assessing the completeness of these plans. A 

preliminary analysis shows that not all agency plans have been updated to 

include all required information. 

In December 2011, the Federal Chief Information Officer (CIO) announced that 

the definition of a data center had been expanded from facilities over 500 square 

feet to one that includes data centers of all sizes. This change resulted in an 

expanded data center baseline of 3,133 centers, an increase from the 2,094 

centers originally reported by agencies. The Federal CIO reported that agencies 

planned to close 525 of these centers by the end of calendar year 2012 and 

1,080 by the end of 2015. The Federal CIO also announced a further goal of 

closing 40 percent, or at least 1,200, of the 3,133 centers. 

Action 2 progress 

The Analytical Perspectives for the President’s budget for fiscal year 2012 also 

addresses data center consolidation. It notes the importance of the federal data 

center consolidation effort and identifies for each of the 24 participating 

agencies, the number of data centers in 2010, as well as the agencies’ 2015 

consolidation targets. 

As noted above, in July 2011, OMB required the 24 federal agencies 

participating in the Federal Data Center Consolidation Initiative to complete their 

consolidation plans, including required information on consolidation savings and 

goals. Beginning in October 2011, all of the agencies posted their updated plans 

online. GAO has ongoing work assessing the extent to which agencies have 

updated this required information. A preliminary analysis shows that not all 

agency plans have been updated to include all required information. GAO also 

has ongoing work assessing OMB’s continuing oversight of the consolidation 

initiative. 

OMB also has a planned initiative to look for consolidation opportunities across 

agencies. Specifically, it plans to develop a governmentwide marketplace for 

data center availability in 2012. Further, OMB has developed a cost model for 

agencies to use to estimate consolidation cost savings. 

OMB’s continued oversight of agencies’ data center consolidation efforts will 

help better ensure that the federal consolidation initiative meets its cost savings 

and data center reduction targets. 

Overall assessment

◐

Action 1 

It will be important for individual 

agencies to move quickly to correct 

any missing items in their plans, 

establish sound baselines so that 

progress and efficiencies can be 

measured, begin their consolidation 

efforts, track their progress, and report 

to the Office of Management and 

Budget (OMB) on their progress over 

time. 

Partially addressed ◐

Action 2 

OMB should work with agencies to 

establish goals and targets for 

consolidation (both in terms of cost 

savings and reduced data centers), 

maintain strong oversight of the 

agencies’ efforts, and look for 

consolidation opportunities across 

agencies. 

Partially addressed ◐

For more information, contact David Powner at 

(202) 512-9286 or pownerd@gao.gov.

See GAO-11-318SP Actions Needed

General Government 

15. Consolidating federal data centers provides 

opportunity to improve government efficiency 
Page 31 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

OMB is working with agencies to improve data on interagency contracting, and 

some actions are in the early stages of implementation. OMB notes that 

continued investment in centralized procurement data systems is required in 

order to sustain improvements in the collection and use of procurement data, 

including data on interagency contracts, and that the first phase of a centralized 

data system, called the System for Award Management, is scheduled to be 

launched in May 2012. OMB’s Office of Federal Procurement Policy (OFPP) 

provided an update describing actions it is taking to address identified 

shortcomings in the management of interagency contracting. In particular, OFPP 

noted that it is working with agencies to update current data on interagency 

contracts. OFPP also noted that it may not be necessary to create a new 

database on interagency contracts because much of this information is already 

available. OFPP plans to notify agencies of a new page on OMB’s budget 

information Web site with links to information on existing interagency contract 

vehicles, new multiagency contracts, and new multiagency blanket purchase 

agreements. OFPP still needs to decide on the need to create a centralized 

database containing this information.

Action 2 progress 

GSA has prepared an action plan that addresses identified shortcomings in the 

management of interagency contracting, but the action plan has not yet been 

fully implemented. GSA has completed a high-level analysis of options for 

collecting transactional data on orders through the Multiple Award Schedule 

program and plans to implement and evaluate a pilot program for collecting this 

information. 

Action 3 progress 

OFPP has worked with agencies to ensure that data in the Federal Procurement 

Data System are accurate and complete, including a random sampling of fiscal 

year 2010 contract actions, which reflected a 96.5 percent accuracy rate. OFPP 

also established an interagency procurement data quality working group to 

review various efforts agencies are employing to improve data quality and 

leverage successful efforts across the acquisition community. 

Action 4 progress 

On September 29, 2011, the Administrator of OFPP issued a memorandum that 

provided guidance for development of a business case analysis for certain 

interagency contracts, including new multiagency contracts. 13 In addition, on 

January 3, 2012, a final rule was issued amending the Federal Acquisition 

Regulation to require a business case analysis to support the creation of certain 

of these contracts.14 

 

13OFPP Memorandum, “Development, Review and Approval of Business Cases for 

Certain Interagency and Agency-Specific Acquisitions” (Sept. 29, 2011). 1477 Fed. Reg. 183 (Jan. 3, 2012).

Overall assessment

◐

Action 1 

The Office of Management and Budget 

(OMB) will need to fully implement the 

steps it is taking to address identified 

shortcomings in the management of 

interagency contracting. 

Partially addressed ◐

Action 2 

The General Services Administration 

(GSA) will need to fully implement the 

steps it is taking to address identified 

shortcomings in the management of 

interagency contracting. 

Partially addressed ◐

Action 3 

Improvements are still needed 

regarding the accuracy of the federal 

contracts database in order to 

determine whether the contracts are 

being used in an efficient and effective 

manner. 

Addressed ●

Action 4 

Require business case analyses for 

new multiagency contracts. 

Addressed ●

For more information, contact William T. 

Woods at (202) 512-4841 or 

WoodsW@gao.gov.

See GAO-11-318SP Actions Needed

General Government 

16. Collecting improved data on interagency contracting

to minimize duplication could help the government 

leverage its vast buying power 
Page 32 GAO-12-453SP Follow-up on 2011 Report 

General Government 

17. Periodic reviews could help identify ineffective tax 

expenditures and redundancies in related tax and 

spending programs, potentially reducing revenue losses 

by billions of dollars 

Action 1 progress 

No executive action taken. OMB did not agree with this recommendation and 

favors reporting tax expenditures separately from the rest of the budget. 

Although OMB had begun presenting tax expenditure sums alongside outlays 

and credit activity for each budget function in the federal budget from fiscal year 

1998 through fiscal year 2002, OMB discontinued the practice. Tax expenditures 

were not integrated in the President’s fiscal year 2012 budget. 

 

Action 2 progress 

The Director of OMB has not developed a framework for reviewing tax 

expenditure performance. The President’s fiscal year 2012 budget stated that 

developing an evaluation framework is a significant challenge and that the 

administration’s focus is on addressing challenges with data availability and 

analytical constraints so that the administration can work towards crosscutting 

analyses examining tax expenditures alongside related spending programs; 

however, no timetable or specifics were included. In January 2012, OMB 

officials stated that the President’s fiscal year 2012 budget proposed numerous 

reforms to tax expenditures, which it estimated would save billions in total; 

published evaluations supporting the proposals were not available. 

Action 3 progress 

OMB guidance has not explicitly addressed how agencies should incorporate tax 

expenditures in strategic plans and annual performance plans and reports. 

Moving forward, the GPRA Modernization Act of 2010 (GPRAMA)15 calls for a 

more coordinated approach to focus on results and improve government 

performance. OMB, in coordination with agencies, is to develop a limited number 

of outcome-oriented, crosscutting policy goals and indicates that it will identify 

the relevant agencies and federal activities—including tax expenditures—that 

contribute to each crosscutting goal. OMB has issued some guidance to help 

agencies implement GPRAMA, and OMB plans to address tax expenditures in 

guidance forthcoming in 2012. 

 

15Pub. L. No. 111-352 (2011).

Overall assessment

○

Action 1 

The Director of the Office of 

Management and Budget (OMB) in 

consultation with the Secretary of the 

Treasury should present tax 

expenditures in the budget together 

with related outlay programs. 

Not addressed ○ 

Action 2 

The Director of OMB in consultation 

with the Secretary of the Treasury 

should develop and implement a 

framework for conducting performance 

reviews of tax expenditures. This 

includes (1) outlining leadership 

responsibilities and coordination 

among agencies with related 

responsibilities; (2) setting a review 

schedule; (3) identifying review 

methods and ways to address the lack 

of credible tax expenditure 

performance information; and (4) 

identifying resources needed for tax 

expenditure reviews. 

Not addressed ○

Action 3 

The Director of OMB in consultation 

with the Secretary of the Treasury 

should develop guidance on 

incorporating tax expenditures in 

agencies’ strategic plans and 

performance reports. 

Not addressed ○
Page 33 GAO-12-453SP Follow-up on 2011 Report 

General Government 

17. Tax expenditures (continued) 

Action 4 progress 

OMB has not made progress on systematically including tax expenditures along 

with related outlay programs in the Executive Branch’s budget and performance 

review processes. The President’s fiscal year 2012 budget stated that the 

Administration will be working towards examining the objectives and effects of 

the wide range of tax expenditures in the budget, though no timetable or 

specifics were provided. 

Effective GPRAMA implementation could help inform reexamination or 

restructuring efforts and lead to more efficient and economical service delivery in 

overlapping program areas by identifying the various agencies and federal 

activities—including tax expenditures—that contribute to crosscutting outcomes. 

As noted above, OMB has stated that forthcoming OMB GPRAMA guidance will 

address tax expenditures. 

Action 4 

The Director of OMB in consultation 

with the Secretary of the Treasury 

should require that tax expenditures be 

included in Executive Branch budget 

and performance review processes. 

Not addressed ○

For more information, contact Michael Brostek 

at (202) 512-9110 or brostekm@gao.gov.

See GAO-11-318SP Actions Needed
Page 34 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

The Departments of Defense (DOD) and Veterans Affairs (VA) have taken steps 

to discuss and improve their electronic health record system capabilities, but 

they have not yet revised their joint strategic plan to include these efforts or 

indicate how they will address common health care business needs. The 

Secretaries of DOD and VA have met to discuss their respective departments’ 

efforts to pursue joint development and acquisition of integrated electronic health 

record (iEHR) capabilities. Among other things, the Secretaries have established 

the departments’ interagency program office as the single point of accountability 

for the development and implementation of the iEHR, while also improving their 

efforts to further implement joint health information technology (IT) capabilities at 

DOD and VA’s first fully integrated health care center in North Chicago, Illinois. 

The departments plan further action to address this area. Specifically, DOD and 

VA intend to issue an addendum to their joint strategic plan for fiscal years 2011 

through 2013 that is to include objectives and goals related to the departments’ 

iEHR efforts. 

Action 2 progress 

The DOD and VA have taken steps toward developing a joint health 

architecture, but the architecture is not sufficiently mature and the departments 

have not defined how they intend to transition from their current architecture to a 

planned future state. The Secretaries of DOD and VA agreed in May 2011 that 

the departments would implement a common architecture for the iEHR. The 

departments have since developed, and the Secretaries have approved, a highlevel representation of the “to be” architecture for the iEHR. In addition, the 

interagency program office is to facilitate further development and maintenance 

of the iEHR architecture in conjunction with the departments’ Health Executive 

Council and the recently established Health Architecture Review Board. 

Nevertheless, DOD and VA have not yet fully developed a joint health 

architecture that includes a plan for transitioning from their current state to the 

next generation of electronic health record capabilities. 

Action 3 progress 

The Secretaries of DOD and VA have agreed to develop a process for 

identifying and selecting joint IT investments; however, the departments have 

not yet implemented this process. Specifically, both Secretaries have agreed to 

develop and implement the iEHR and they have approved a governance 

structure that defines how they intend to accomplish this effort. This structure 

includes the departments themselves, which have responsibility for establishing 

their respective health care requirements; joint forums such as the Health 

Executive Council, which is to collaborate with the interagency program office to 

collect the requirements; and the program office itself, which is to identify the IT 

investments to meet the requirements. However, the departments have not yet 

implemented this process. 

Overall assessment

◐

Action 1 

The Secretaries of Defense and 

Veterans Affairs should revise the 

departments’ joint strategic plan to 

include information discussing their 

electronic health record system 

modernization efforts and how those 

efforts will address the departments’ 

common health care business needs. 

Partially addressed ◐

Action 2 

The Secretaries of Defense and 

Veterans Affairs should further develop 

the departments’ joint health 

architecture to include their planned 

future state and transition plan from 

their current state to the next 

generation of electronic health record 

capabilities. 

Partially addressed ◐ 

Action 3 

The Secretaries of Defense and 

Veterans Affairs should define and 

implement a process, including criteria 

that considers costs, benefits, 

schedule, and risks, for identifying and 

selecting joint IT investments to meet 

the departments’ common health care 

business needs. 

Partially addressed ◐

For more information, contact Valerie C. 

Melvin at (202) 512-6304 or 

melvinv@gao.gov. 

See GAO-11-318SP Actions Needed

Health

18. Opportunities exist for DOD and VA to jointly 

modernize their electronic health record systems
Page 35 GAO-12-453SP Follow-up on 2011 Report 

Health 

19. VA and DOD need to control drug costs and increase 

joint contracting wherever it is cost-effective 

Action 1 progress 

Neither DOD nor VA indicated that either agency intended to analyze whether it 

would be cost-effective to resume joint contracting for brand name drugs. 

However, in January 2012, the agencies indicated that they are coordinating on 

joint contracting opportunities for brand name drugs through the Contracting 

Subcommittee of the VA Federal Pharmacy Executive Steering Committee, 

whose purpose is to coordinate federal pharmacy activities across federal 

agencies. For example, in November 2011, VA and DOD entered into a joint 

contract for a brand name drug, and VA reported that it would continue its 

practice of coordinating with DOD on opportunities for contracts for brand name 

drugs. However, according to DOD officials, there was evidence from VA and 

DOD’s joint contracting experience that joint contracting does not necessarily 

result in lower prices for either or both agencies. DOD cited past experiences in 

which the agencies did not receive a single bid in response to some large joint 

generic drug contract solicitations. DOD also noted that differences in the design 

of VA’s and DOD’s pharmacy benefits programs make cost-effective 

opportunities, as currently designed, for brand-name drug joint contracts less 

common than they were prior to DOD’s fiscal year 2005 implementation of its 

uniform formulary process. 

Action 2 progress 

DOD reported that a number of initiatives to control retail pharmacy costs had 

been identified and implemented, and that it continues to monitor its cost control 

efforts. 

 As a result of applying federal pricing arrangements—which generally result 

in prices lower than retail prices—to drugs dispensed at retail pharmacies, 

DOD reported that as of July 31, 2011, DOD had received $2.7 billion in 

manufacturer refunds for fiscal years 2009, 2010, and 2011. 

 DOD reported that its uniform formulary process has ensured use of the 

most clinically- and cost-effective agents at all three points of pharmacy 

service through the use of formulary management tools such as step 

therapy. For example, DOD reported that step therapy for cholesterol 

lowering agents implemented in May 2010 enabled DOD to save 

approximately $82.8 million in the first year after implementation. The 3-year 

cost avoidance projection for this class of drugs is $141.6 million. 

 Also, in January 2010, DOD implemented an in-depth communications plan 

to promote the use of a less costly pharmacy option. DOD officials told GAO 

that this effort has resulted in higher use of the less-expensive TRICARE 

Mail Order Pharmacy venue and savings to the government, which they 

estimate to be over $30 million in 2010. Additionally, DOD reports that an 

adjustment to prescription drug copayments, effective October 1, 2011, will 

further encourage the use of the TRICARE Mail Order Pharmacy and should 

result in additional savings. 

Overall assessment

◐

Action 1 

The Department of Veterans Affairs 

(VA) and the Department of Defense 

(DOD) should analyze whether greater 

cost savings could be achieved 

through joint contracting for brand 

name drugs than are currently 

achieved through their independent 

strategies, and determine whether it 

would be cost-effective to take steps to 

resume joint contracting for brand 

name drugs. 

 Partially addressed ◐ 

 

Action 2 

DOD should identify, implement, and 

monitor efforts to control retail 

pharmacy spending, an area for which 

drug spending is increasing and cannot 

be controlled through joint contracting 

efforts. 

Addressed ●

 
Page 36 GAO-12-453SP Follow-up on 2011 Report 

Health 

19. VA and DOD drug costs and joint contracting 

(continued) 

Action 3 progress 

VA continues to collaborate with DOD to identify opportunities for joint 

contracting for generic drugs through the Federal Pharmacy Executive Steering 

Committee. Additionally, DOD noted in January 2012 that joint contracts had 

been awarded for several generic drugs that had previously been “blockbuster” 

brand name drugs, and additional joint contract negotiations were under way. 

Action 3 

VA and DOD should continue their 

efforts to jointly contract for generic 

drugs, and look for opportunities to 

increase joint contracting efforts as 

generic versions of existing brand 

name drugs become available. 

Addressed ●

For more information, contact Randall B. 

Williamson at (202) 512-7114 or 

williamsonr@gao.gov.

See GAO-11-318SP Actions Needed
Page 37 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

HHS has not finalized a strategic plan for establishing an electronic nationwide 

public health situational awareness network. HHS officials with the Office of the 

Assistant Secretary for Preparedness and Response stated that they intend to 

release an Implementation Plan for the National Health Security Strategy. This 

plan is to incorporate a strategy for integrating the goals and objectives of the 

various offices’ disparate plans to implement information systems in support of 

the nationwide public health situational awareness network capabilities required 

by section 202 of the Pandemic and All-Hazards Preparedness Act.16 Although 

HHS intended to release the Implementation Plan in early 2011, it has not yet 

done so. Department officials stated that they now expect to release the plan in 

early 2012. 

 

1642 U.S.C. § 247d–4(d). The act requires that a strategic plan be submitted to 

congressional committees no later than June 18, 2007, and that the electronic nationwide 

public health situational awareness network be established no later than December 19, 

2008. 

Overall assessment

○

Action 1 

The Secretary of Health and Human 

Services should develop and 

implement a strategic plan that defines 

goals, objectives, and priorities for 

establishing an electronic public health 

situational awareness network. Such a 

plan should include performance 

measures for evaluating capabilities of 

existing and planned information 

systems. The strategic plan should 

integrate related strategies and 

information technology initiatives within 

the Department of Health and Human 

Services (HHS) for sharing information 

among federal, state, local, and tribal 

entities. 

Not addressed ○

For more information, contact Valerie C. 

Melvin at (202) 512-6304 or 

melvinv@gao.gov.

See GAO-11-318SP Actions Needed

Health

20. HHS needs an overall strategy to better integrate 

nationwide public health information systems 
Page 38 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

In August 2011, the National Security Staff (NSS), which supports the Homeland 

Security Council, stated that two of its directorates serve as focal points to 

coordinate federal biodefense activities, as suggested in GAO’s March 2011 

report. However, the NSS did not provide any details about how these 

directorates will provide the strategic and integrated oversight of the entire 

biodefense enterprise, which GAO reported was lacking. 

Action 2 progress 

NSS officials stated that they are overseeing the development of a national 

strategy for biosurveillance, but that strategy has not yet been developed and 

does not cover the full biodefense enterprise. In August 2011, the NSS indicated 

that two of its directorates are overseeing the development of the strategy. 

However, the NSS did not provide a timeline for completing these actions. The 

strategy also would not address the overarching biodefense enterprise, as GAO 

previously recommended. 

Overall assessment

◐

Action 1 

The Homeland Security Council should 

consider establishing a focal point to 

coordinate federal biodefense 

activities, including biosurveillance. 

Partially addressed ◐

Action 2 

The overarching biodefense enterprise 

would benefit from strategic oversight 

mechanisms, including a national 

strategy, to ensure efficient, effective, 

and accountable results. 

Not addressed ○

For more information, contact William O. 

Jenkins, Jr., at (202) 512-8777 or 

jenkinswo@gao.gov.

See GAO-11-318SP Actions Needed

Homeland Security / Law Enforcement 

21. Strategic oversight mechanisms could help integrate 

fragmented interagency efforts to defend against 

biological threats
Page 39 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

22. DHS oversight could help eliminate potential 

duplicating efforts of interagency forums in securing the 

northern border 

Action 1 progress 

No executive branch action has been taken. 

Draft legislation has been introduced in Congress that would require DHS to 

consider whether the establishment of a new interagency forum would duplicate 

an existing forum’s effort; the bill, however, has yet to be enacted and does not 

address duplication among existing interagency forums. On March 3, 2011, the 

Jaime Zapata Border Enforcement Security Task Force Act was introduced in 

Congress.17 This draft bill would provide authorization of appropriations to 

establish and operate a BEST program in areas designated by the Secretary of 

Homeland Security. The House Homeland Security Committee approved the 

bill, as amended, by voice vote on September 21, 2011, and the bill was officially 

reported out of committee on November 4, 2011. The bill, as amended, requires 

the Secretary to consider whether an IBET already exists in an area under 

consideration for establishment of a BEST unit. However, the bill does not 

specifically discuss addressing areas of overlap or duplication among existing 

IBETs and BEST units. 

Action 2 progress 

No executive action taken. 

 

17H.R. 915, 112th Cong. (as reported by H.R. Comm. on Homeland Security, Nov. 4, 

2011).

Overall assessment

○ 

Action 1 

The Department of Homeland Security 

(DHS) should provide guidance and 

oversight for interagency forums—

which include both Integrated Border 

Enforcement Team (IBET) and Border 

Enforcement Security Task Force 

(BEST) interagency forums—to help 

prevent duplication of effort and help 

efficiently utilize personnel resources 

to strengthen DHS’s coordination 

efforts along the northern border. 

Not addressed ○

Action 2 

As DHS establishes a mechanism for 

determining the benefits of 

participating in the IBET and BEST 

interagency forums, DHS could lead 

efforts to develop a framework for 

identifying the costs incurred by all 

partners participating in each forum. 

Not addressed ○

For more information, contact Rebecca 

Gambler at (202) 512-6912 or 

GamblerR@gao.gov.

See GAO-11-318SP Actions Needed
Page 40 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

23. The Department of Justice plans actions to reduce 

overlap in explosives investigations, but monitoring is 

needed to ensure successful implementation 

Action 1 progress 

Executive branch action has been taken in each of the four identified areas 

where duplication and redundant efforts needed to be addressed. 

Jurisdiction: To address jurisdictional disputes in explosives investigations, as of 

May 2011, Justice created a National Explosives Task Force where ATF and 

FBI are collocated in headquarters. This task force monitors explosives 

investigations, may determine the lead agency in investigations when there is 

uncertainty among field agents, and ensures that ATF and FBI are coordinating. 

Training: To address fragmentation in the explosives training provided by ATF 

and FBI, the two agencies created a joint curriculum for their post-blast training 

as of May 2011. According to ATF and FBI, the new curriculum has resulted in 

both agencies providing consistent information to the agents and state and local 

bomb squads whom they train. They are also considering creating other joint 

curricula in areas such as homemade explosives. 

Explosive database: To ensure that both agencies are aware of explosives 

incidents, ATF released a more user friendly version of the Bomb and Arson 

Tracking System—an explosives incident reporting system—in May 2011. Both 

ATF and FBI have issued new protocols requiring agents to enter explosives 

incidents into the Bomb and Arson Tracking System. In addition, both the ATF 

and FBI are requiring that all explosives incidents be reported to their respective 

Strategic Information Operation Centers (SIOC). The SIOCs will notify each 

other when an incident is reported. In addition, explosives incidents are also 

reported to the National Explosives Task Force. According to ATF and FBI, 

these multiple reporting mechanisms ensure that both ATF and FBI are aware of 

all explosives incidents and that the incidents are entered in the Bomb and 

Arson Tracking System. 

Explosive laboratories: To better leverage their explosives forensic capabilities, 

according to officials, ATF and FBI laboratories meet on a regular basis to 

discuss options where coordination can be increased. According to ATF and 

FBI officials, both laboratories are at capacity, but they have agreed to utilize a 

joint lab information management system and joint training of laboratory staff. 

DOJ plans to lay out implementation steps during fiscal year 2012.

Additionally, according to ATF and FBI officials, the Office of the Deputy 

Attorney General meets regularly with ATF and FBI to monitor their progress 

and address any potential concerns. This coordination is important to help 

ensure that the above improvements are sustained. 

Overall assessment

●

Action 1 

Continually monitoring the actions 

planned by the Department of Justice 

(Justice); the Bureau of Alcohol, 

Tobacco, Firearms, and Explosives 

(ATF); and the Federal Bureau of 

Investigation (FBI) in four areas of 

explosives investigations—including 

jurisdiction, explosives training, shared 

explosives databases, and 

laboratories—could help Justice 

ensure the successful implementation 

of those actions to reduce duplication 

and overlap and to improve 

coordination. 

Addressed ●

For more information, contact Eileen Larence 

at (202) 512-6510 or LarenceE@gao.gov .

See GAO-11-318SP Actions Needed
Page 41 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

24. TSA’s security assessments on commercial trucking 

companies overlap with those of another agency, but 

efforts are under way to address the overlap 

Action 1 progress 

In August 2011, TSA reported that the agency had discontinued conducting 

security reviews on trucking companies that are covered by the FMCSA 

program. Discontinuing such reviews should eliminate the short-term overlap 

between TSA and FMCSA’s reviews of hazardous material trucking companies. 

 

Action 2 progress 

No executive action taken. In January 2012, TSA reported that due, in part, to 

data subscription costs, the agency had decided to discontinue access to 

FMCSA’s data for hazardous material trucking companies until TSA has full 

regulatory oversight in this area. TSA officials had previously reported that the 

agency would have little use for FMCSA data until TSA assumes such regulatory 

responsibility, and said the data are limited to FMCSA-related regulations and do 

not provide information about a carrier’s overall security preparedness. TSA 

officials also reported that they are confident that FMCSA would provide TSA 

with security review results for individual motor carriers if security conditions 

warrant such a request. However, GAO continues to believe that utilization of 

FMCSA’s security information in the DOT Web portal could benefit TSA because 

a considerable amount of the data in FMCSA’s review is the same or similar to 

the data TSA was previously collecting. In addition, FMCSA conducts 

approximately 1,800 security reviews per year. TSA officials said that they were 

not in a position to estimate when the regulations will be issued and thus did not 

know when TSA would assume full regulatory responsibility from FMCSA. 

Action 3 progress 

In October 2011, TSA reported that the agency had drafted proposed 

regulations for hazardous material trucking security, which would give TSA 

regulatory responsibility for this area, and that the proposed regulations were 

undergoing TSA review. TSA officials did not have an estimate for when the 

regulations would be issued and thus did not know when TSA would assume full 

regulatory responsibility from FMCSA. 

Overall assessment

◐

Action 1 

The Transportation Security 

Administration (TSA) and the Federal 

Motor Carrier Safety Administration 

(FMCSA) could improve interagency 

coordination by sharing each other’s 

schedules for conducting future 

security reviews, and avoid scheduling 

reviews on hazardous material trucking 

companies that have recently received, 

or are scheduled to receive, a review 

from the other agency. TSA could also 

discontinue conducting voluntary 

security reviews on hazardous material 

trucking companies, thereby enabling 

TSA to increase its security efforts in 

other areas. 

Addressed ●

Action 2 

TSA could request that the full results 

of past FMCSA security reviews of 

trucking companies be provided 

through an existing Department of 

Transportation (DOT) Web portal. 

Doing so would require cooperation 

from FMCSA. 

Not addressed ○

Action 3 

TSA and FMCSA should continue 

efforts toward the long-term goal of 

TSA assuming full regulatory 

responsibility from FMCSA for 

commercial trucking security, thereby 

reducing fragmentation. 

Partially addressed ◐

For more information, contact Steve Lord at 

(202) 512-4379 or lords@gao.gov.

See GAO-11-318SP Actions Needed
Page 42 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

25. DHS could streamline mechanisms for sharing 

security-related information with public transit 

agencies to help address overlapping information 

Action 1 progress 

TSA helped launch a new report that streamlines and shares security-related 

information among public transit agencies, but security-related information has 

yet to be fully incorporated from all three mechanisms that GAO identified as 

potentially duplicative. In February 2011, TSA, in coordination with federal and 

industry stakeholders through an information-sharing working group, launched 

the Transit and Rail Intelligence Awareness Daily (TRIAD) Report. The overall 

intent of the TRIAD is to streamline the analysis, share, and exchange 

intelligence and security information, and help public transit stakeholders more 

efficiently share information by reducing the number of e-mails that stakeholders 

receive, and the number of persons sending those e-mails. However, the 

TRIAD does not yet reference specific information from the DHS information 

network or TSA’s portal on the network, although the working group has 

discussed doing so. 

TSA officials reported that maintaining different information-sharing mechanisms 

is necessary at this time to ensure that the diversity of information is covered. 

However, GAO continues to believe that maintaining separate systems to 

provide similar information to similar user groups is not efficient and that this 

potential overlap could overwhelm public transit agencies with similar 

information. Until the information-sharing working group completes its efforts to 

filter security-related information obtained from all three mechanisms through the 

TRIAD, public transit agencies will continue to receive information from multiple 

sources, making it difficult for them to discern relevant security-related 

information. 

Action 2 progress 

No executive action taken. 

Overall assessment

◐

Action 1 

The Department of Homeland Security 

(DHS) and Transportation Security 

Administration (TSA) could identify and 

implement ways to more efficiently 

share security-related information by 

assessing the various mechanisms 

available to public transit agencies—

including DHS’s information network, 

TSA’s portal on the network, and the 

public transit analysis center—as well 

as the information they provide, and 

identify opportunities to streamline 

these mechanisms. 

Partially addressed ◐

Action 2 

DHS could develop and track verifiable 

cost data specific to each of its 

information-sharing mechanisms, as 

part of TSA’s streamlining and financial 

management efforts. Developing such 

baseline cost data could assist TSA in 

identifying potential cost savings 

resulting from the consolidation of 

these mechanisms and provide 

opportunities for the agency to better 

allocate its information-sharing 

resources. 

Not addressed ○

For more information, contact Steve Lord at 

(202) 512-4379 or LordS@gao.gov.

See GAO-11-318SP Actions Needed
Page 43 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

26. FEMA needs to improve its oversight of grants and 

establish a framework for assessing capabilities to 

identify gaps and prioritize investments 

Action 1 progress 

The Department of Homeland Security (DHS) has sought to consolidate several 

of FEMA’s smaller grant programs within larger grant programs, but FEMA has 

not coordinated application reviews of grant projects across four of the largest 

preparedness grant programs, which have similar goals, fund similar types of 

projects, and are awarded in many of the same urban areas. DHS’s fiscal year 

2012 budget request, similar to its 2011 request, proposed the elimination of six 

stove-piped and duplicative stand-alone grant programs, consolidating them into 

broader grants awarded to states and localities based on risk. This approach 

would provide greater flexibility for state and local officials to fill critical homeland 

security capability gaps and would significantly streamline the application 

process. Specifically, the President’s fiscal year 2012 budget proposed to 

incorporate some of the smaller grant programs as allowable expenses within 

the larger programs. For instance, investments previously funded under the 

Driver’s License Security Grant Program, the Citizen Corps Grant Program, and 

the former Interoperable Emergency Communications Grant Program would be 

treated as allowable expenses under the State Homeland Security Grant 

Program. The consolidated appropriations act for fiscal year 2012 appropriated a 

lump sum of $1.35 billion for FEMA preparedness grant programs, allowing DHS 

to determine the distribution among the various grant programs.18 However, four 

of the largest preparedness grant programs, which have similar allowable costs, 

are being reviewed by two separate divisions, and FEMA has not yet developed 

a mechanism to coordinate the review of grant project applications internally to 

identify unwarranted overlap and mitigate the potential for unnecessary 

duplication across grant applications. According to FEMA officials, the agency 

plans to phase in a new grants management system, which is scheduled for 

completion by fiscal year 2014, to help, among other things, eliminate 

redundancies in its grants programs. However, it is not clear to what extent this 

new system will provide FEMA with the means to coordinate application reviews 

of its grant programs. 

Additionally, The Amateur Radio Emergency Communications Enhancement Act 

of 2011, as reported out by the Senate Committee on Homeland Security and 

Governmental Affairs in June 2011, would require the DHS Inspector General to 

determine whether and to what degree FEMA grant programs provide 

duplicative or overlapping assistance, and make recommendations for the 

consolidation and elimination of grant programs to reduce duplication of 

assistance.19 

 

18H.R. Rep. No. 112-331, at 175-77 (2011) (Conf. Rep.). 19S. 191, 112th Cong. (2011).

Overall assessment

◐

Action 1 

The Federal Emergency Management 

Agency (FEMA) could benefit from 

examining its grant programs and 

coordinating its application process to 

eliminate or reduce redundancy among 

grant recipients and program 

purposes. 

Partially addressed ◐
Page 44 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

26. FEMA grants (continued) 

Action 2 progress 

In the continuing appropriations act for fiscal year 2011, Congress appropriated 

$875 million less for FEMA preparedness grants than the amount requested in 

the President’s fiscal year 2011 budget.20 Similarly, the consolidated 

appropriations act for fiscal year 2012 appropriated $1.7 billion for FEMA 

preparedness grants, $1.28 billion less than requested.21 The Senate Committee 

report accompanying the DHS appropriations bill for fiscal year 2012 directs 

FEMA to develop guidance for grantees on best practices to manage current 

funding to ensure the most necessary capabilities are sustained. The report 

encourages FEMA to provide flexibility in grant expenditures to ensure the least 

amount of degradation to current capabilities occurs and directs the agency to 

brief the Committee quarterly on the specific processes being put in place to 

manage the grant programs in a way that promotes sustainability of current 

capacity.22

In December 2011, DHS officials said that they had not yet completed the 

development and implementation of the preparedness system (additional 

discussion of this issue is included below). However, in the interim, FEMA 

officials stated that FEMA has clarified grant guidance and reporting to support 

maintenance needed to sustain current capabilities in response to grantee 

concerns regarding allowable uses of grant funds. 

Action 3 progress 

DHS has announced plans to develop and implement a national preparedness 

system that would enable it to assess these capability gaps, but the system 

remains under development. Therefore, actions on the assessment of capability 

gaps have not yet begun. In its May 2011, Implementation Plan for Presidential 

Policy Directive 8: National Preparedness, DHS announced plans to develop 

and implement a national preparedness system to provide an integrated 

approach to preparedness that can be implemented and measured at all levels 

of government to link together programs and requirements into a comprehensive 

system, driving rational decision making and allowing for a direct and defensible 

assessment of progress against clearly defined objectives. According to the 

plan, the national preparedness system will be based on a consistent 

methodology for assessing the threats and hazards that drive planning, including 

resource requirements, existing capabilities and capability gaps, and 

investments to close those gaps. FEMA officials described efforts they have 

underway, which are aimed at assessing state-level capabilities, that they said 

would provide a new baseline to meet or exceed several aspects of this action. 

However, FEMA has not yet begun to develop and implement a system to 

assess capability gaps on a national level. 

 

20Pub. L. No. 112-10, § 1632 (2011). 21This total includes all grant programs in the state and local programs account and the 

Emergency Management Performance Grant program but does not include funding 

appropriated for firefighter assistance grant programs.

22S. Rep. No. 112-74, at 124 (2011).

Action 2 

Congress may wish to consider limiting 

preparedness grant funding to 

maintaining existing capabilities (as 

determined by FEMA) until FEMA 

completes a national preparedness 

assessment of capability gaps at each 

level based on tiered, capabilityspecific performance objectives to 

enable prioritization of grant funding. 

Partially Addressed ◐

Action 3 

FEMA should complete a national 

preparedness assessment of capability 

gaps at each level based on tiered, 

capability-specific performance 

objectives to enable prioritization of 

grant funding, and FEMA could identify 

the potential costs for establishing and 

maintaining those capabilities at each 

level and determine what capabilities 

federal agencies should provide. 

. 

Not addressed ○
Page 45 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

26. FEMA grants (continued) 

Action 4 progress 

Because FEMA has not yet completed its assessment, this suggested action 

cannot yet be considered by Congress. 

Action 4 

Once FEMA has completed its 

assessment, Congress may wish to 

consider limiting the use of federal 

preparedness grant programs to fund 

only projects that support the 

development of identified, validated, 

and documented capability gaps that 

may (or may not) include maintaining 

existing capabilities developed. 

Not addressed ○

For more information, contact William O. 

Jenkins, Jr. at (202) 512-8757 or 

jenkinswo@gao.gov.

See GAO-11-318SP Actions Needed
Page 46 GAO-12-453SP Follow-up on 2011 Report 

International Affairs 

27. Lack of information sharing could create the potential 

for duplication of efforts between U.S. agencies involved 

in development efforts in Afghanistan 

Action 1 progress 

The Afghan Info database has been designated as the centralized database for 

U.S. development efforts in Afghanistan, but it does not readily capture relevant 

DOD data. On October 2, 2011, the Deputy Ambassador, U.S. Embassy Kabul, 

signed a memo requiring that all Embassy agencies and sections utilizing 

foreign assistance funds report information on their programs and projects into 

Afghan Info. Additionally, a November 2011 U.S. Status Report: Afghanistan and 

Pakistan Civilian Engagement issued by the Office of the Special Representative 

for Afghanistan and Pakistan and signed by the Secretary of State noted that 

Embassy Kabul is taking steps to utilize the Afghan Info database to capture all 

foreign assistance activities being implemented by U.S. government agencies. 

However, DOD’s Commander’s Emergency Response Program data is still not 

in the Afghan Info database. USAID has started discussions with DOD about 

how to get Commander’s Emergency Response Program data into the database 

because, according to USAID, the Ambassador only has direct authority over 

Chief of Mission offices and agencies. USAID officials said that Afghan Info is in 

the process of being transitioned, by late February 2012, to an internet-based 

system that will allow all agencies access. 

Overall assessment

◐

Action 1

The U.S. Agency for International 

Development (USAID), in consultation 

with the Department of Defense (DOD) 

and other relevant U.S. agencies, 

should consider designating Afghan 

Info or some other database as the 

centralized U.S. government database 

for U.S. development efforts in 

Afghanistan. This database should, 

among other things, ensure that the 

information in the database (1) 

captures all agency development 

efforts and (2) is accessible to all U.S. 

government agencies involved in U.S.-

funded development projects in 

Afghanistan. 

Partially addressed ◐

For more information, contact Charles 

Johnson at (202) 512-7331 or 

johnsoncm@gao.gov.

See GAO-11-318SP Actions Needed
Page 47 GAO-12-453SP Follow-up on 2011 Report 

International Affairs 

28. Despite restructuring, overlapping roles and functions 

still exist at State’s Arms Control and Nonproliferation 

Bureaus 

Action 1 progress 

State updated the FAM in February and April 2011 to formally delineate the roles 

of the Bureau of Arms Control, Verification and Compliance and the Bureau of 

International Security and Nonproliferation. By making these improvements, 

State could reduce personnel and other overhead costs by helping address the 

multiple mission redundancies identified among the offices and functions of the 

new International Security and Nonproliferation and Arms Control, Verification, 

and Compliance bureaus. 

Action 2 progress 

State updated the FAM in May 2011 to direct that, to the extent practicable, 

major reorganizations of bureaus or offices at State should follow GAO’s key 

transformation practices. Such key practices include ensuring that top leadership 

drives the transformation and establishing a coherent mission and integrated 

strategic goals to guide the transformation. 

. 

Overall assessment

● 

Action 1 

The Department of State (State) 

should implement GAO’s 

recommendations to formally delineate 

in the Foreign Affairs Manual (FAM) 

the roles of the two new bureaus.

Addressed ●

Action 2 

State should implement GAO’s 

recommendations to direct that key 

transformation practices and steps be 

incorporated into the FAM. 

Addressed ●

For more information, contact Thomas Melito 

at (202) 512-9601 or melitot@gao.gov. 

See GAO-11-318SP Actions Needed
Page 48 GAO-12-453SP Follow-up on 2011 Report 

Social Services 

29. Actions needed to reduce administrative overlap 

among domestic food assistance programs 

Action 1 progress 

No executive action taken. 

Action 2 progress 

No executive action taken. 

Overall assessment

○

Action 1 

The U.S. Department of Agriculture 

(USDA) should identify and develop 

methods for addressing potential 

inefficiencies and reducing 

unnecessary overlap among its smaller 

food assistance programs while 

ensuring that those who are eligible 

receive the assistance they need. 

These methods could include 

conducting a study as a first step; 

convening a group of experts; 

identifying which of the lesser-studied 

programs need further research and 

taking steps to fill the research gap; or 

identifying and piloting proposed 

changes. 

Not addressed ○

Action 2 

USDA could broaden its efforts to 

simplify, streamline, or better align 

eligibility procedures and criteria 

across programs to the extent that it is 

permitted by law. Options such as 

consolidating or eliminating 

overlapping programs also have the 

potential to reduce administrative costs 

but may not reduce spending on 

benefits unless fewer individuals are 

served as a result. 

Not addressed ○

For more information, contact Kay E. Brown at 

(202) 512-7215 or brownke@gao.gov.

See GAO-11-318SP Actions Needed
Page 49 GAO-12-453SP Follow-up on 2011 Report 

Social Services 

30. Better coordination of federal homelessness

programs may minimize fragmentation and overlap 

Action 1 progress 

While not all members of the U.S. Interagency Council on Homelessness 

(USICH) are expected to do so, the three key member agencies—the 

Departments of Health and Human Services (HHS), Housing and Urban 

Development (HUD), and Veterans Affairs (VA)—have either adopted or aligned 

their strategic plans with the Federal Strategic Plan, which was developed in 

2010. GAO has ongoing audit work to determine the extent to which council 

member agencies have implementation plans in place and the extent to which 

those plans incorporate the recommended elements. 

Action 2 progress 

Better collaboration is part of the mission of the USICH and one of the objectives 

of the Federal Strategic Plan. Collaborative steps have been taken by some 

agencies as they address the issue of homelessness, but not all agencies are as 

far along in the process. For example, HHS and VA have been working with 

HUD to better coordinate collection, analysis, and reporting of homelessness 

data within those three agencies. In addition, during fiscal year 2012, the USICH 

is facilitating discussions among and between agencies about the feasibility of 

creating a common data standard regarding housing stability across relevant 

federal programs. If adopted, such a common data standard would also allow for 

greater collaboration among agencies. Agencies have also stated that 

increased collaboration has occurred between both targeted and mainstream 

federal homelessness programs. For instance, Department of Agriculture 

officials stated that as a result of their involvement with USICH, they have begun 

to plan strategies with another agency to increase access to mainstream 

programs. However, providers GAO spoke with stated that greater collaboration 

of homelessness efforts is still needed among agencies, especially those that 

provide housing and health services. Providers acknowledged that coordination 

can be difficult because agencies are not set up to work together and 

coordination efforts take time and resources to be successfully implemented. 

Therefore, while agency actions to improve collaboration are in process, 

additional collaboration is still needed to further coordinate the federal response 

to homelessness. GAO is currently assessing agency efforts to improve 

collaboration and will report on this later this year. 

Overall assessment

◐

Action 1 

It will be important for the federal 

agencies that have adopted the 

Federal Strategic Plan to Prevent and 

End Homelessness (the Federal 

Strategic Plan) to develop 

implementation plans that include but 

are not limited to a project schedule, 

resource allocation, outreach 

measures, and a performance 

measurement strategy to evaluate their 

progress. 

Partially addressed ◐

Action 2 

Agencies need to improve 

collaborative efforts as outlined in the 

U.S. Interagency Council on 

Homelessness’s (USICH) Federal 

Strategic Plan. 

Partially addressed ◐

For more information, contact Alicia Puente 

Cackley at (202) 512-8678 or 

cackleya@gao.gov

See GAO-11-318SP Actions Needed
Page 50 GAO-12-453SP Follow-up on 2011 Report 

Social Services 

31. Further steps needed to improve cost-effectiveness 

and enhance services for transportation-disadvantaged

persons 

Action 1 progress 

The Department of Transportation, which is the head of the Coordinating 

Council, maintains a comprehensive inventory of its programs, but most 

participating federal departments do not have an inventory of existing programs 

or related expenditure information for transportation services and have not been 

actively working with other departments to identify potential opportunities for 

additional coordination. One of seven Coordinating Council working groups in 

fiscal year 2011, however, has identified a new opportunity to coordinate certain 

services for a targeted group of transportation-disadvantaged persons. As part 

of the Coordinating Council’s Veteran’s Affairs working group, the Departments 

of Health and Human Services, Labor, Transportation, and Veterans Affairs 

recently worked together to develop a Veteran’s Transportation & Community 

Living Initiative, launched in July 2011. Through this initiative, the Federal 

Transit Administration has made over $34 million in Bus and Bus Facilities grant 

funding available to local governmental agencies to finance the capital costs of 

implementing, expanding, or increasing access to local One-Call/One-Click 

Transportation Resource Centers. In addition, a Web site exists (the 

Coordinating Council’s United We Ride Web site) to collect and share program 

information, but the information provided does not comprehensively address all 

relevant transportation programs for transportation-disadvantaged persons. 

Action 2 progress 

Most federal departments on the Coordinating Council have not disseminated 

policies and grantee guidance for coordinating transportation services since 

March 2011. One of eight federal departments we reviewed, however, recently 

disseminated guidance for their grantees for coordinating transportation 

services. The Department of Labor’s Employment and Training Administration 

and Office of Disability Employment Policy jointly issued a Training and 

Employment Notice on January 3, 2012 for the public workforce system on 

meeting employment-related transportation needs of businesses and job 

seekers. This guidance provides strategies for connecting individuals, including 

those with disabilities and other challenges, to employment with transportation to 

jobs and training. 

Overall assessment

◐

Action 1 

Federal departments on the 

Interagency Transportation 

Coordinating Council on Access and 

Mobility (Coordinating Council), 

including the Departments of 

Agriculture, Education, Health and 

Human Services, Housing and Urban 

Development, Interior, Labor, 

Transportation, and Veterans Affairs, 

should identify and assess their 

transportation programs and related 

expenditures and work with other 

departments to identify potential 

opportunities for additional 

coordination. The Coordinating 

Council should develop the means for 

collecting and sharing this information 

by establishing agency roles and 

responsibilities and developing a 

strategy to reinforce cooperation. 

Partially addressed ◐ 

Action 2 

Federal departments on the 

Coordinating Council should develop 

and disseminate policies and grantee 

guidance for coordinating 

transportation services. 

Partially addressed ◐ 

For more information, contact David Wise at 

(202) 512-2834 or WiseD@gao.gov.

See GAO-11-318SP Actions Needed
Page 51 GAO-12-453SP Follow-up on 2011 Report 

Training, Employment, and Education 

32. Multiple employment and training programs: 

providing information on collocating services and 

consolidating administrative structures could promote 

efficiencies 

Action 1 progress 

According to department officials, the Departments of Labor (Labor) and Health 

and Human Services (HHS) are collaboratively pursuing efforts which may 

increase administrative efficiencies. These efforts include testing innovative 

strategies, developing technical assistance, and conducting joint evaluation 

activities. Department officials cited the following: 

 Labor will be awarding competitive grants intended to improve services 

and job seeker and employer outcomes and lower costs or reduce 

program overlap and administrative cost; 

 HHS and Labor have jointly developed and disseminated information 

through technical assistance to cross-agency teams to support the 

improvement of employment, training, and education outcomes for lowskilled adults; and 

 HHS is collaborating with Labor to conduct an evaluation to better 

understand policies, practices, and service delivery strategies that lead 

to better alignment of the Workforce Investment Act and Temporary 

Assistance for Needy Families (TANF), including promising state and 

local practices for successful coordination between these programs. 

As part of its proposed changes to the Workforce Investment Act, the 

President’s fiscal year 2012 budget request proposed consolidating the 

Vocational Rehabilitation (VR) States Grants program, Supported Employment 

State Grants, Projects with Industry, Migrant and Seasonal Farmworkers, and 

the in-service training portion of VR Training program. The administration also 

proposed consolidating Education’s Career and Technical Education-Basic 

Grants to States and Tech Prep Education programs, at the same time reducing 

program funding. According to an official at the Department of Education, the 

fiscal year 2012 appropriations23 did not consolidate these programs. However, 

the fiscal year 2012 appropriation provided no funds for the Projects with 

Industry; provided funds to pay only the continuation costs of the Migrant and 

Seasonal Farmworkers program’s current projects; and the fiscal year 2011 

appropriation eliminated funding for Tech Prep, according to the official.

In addition, the administration proposed transferring the Senior Community 

Service Employment Program from Labor to HHS, while reducing the program’s 

funding. According to a Labor official, the fiscal year 2012 appropriation did not 

transfer the program to HHS. There was a small reduction in funding relative to 

the fiscal year 2011 appropriation. 

 

23 Pub. L. No. 112-74 (2011). 

Overall assessment

◐

Action 1 

The Secretaries of Labor and Health 

and Human Services should work 

together to develop and disseminate 

information that could inform efforts by 

states and localities in increasing 

administrative efficiencies in 

employment and training programs, 

including initiatives to consolidate 

program administrative structures and 

collocate new partners at one-stop 

centers. 

Partially addressed ◐
Page 52 GAO-12-453SP Follow-up on 2011 Report 

Training, Employment, and Education 

32. Employment and training programs (continued) 

Action 2 progress 

Labor reported that it will be awarding competitive grants to encourage states to 

(1) achieve outcomes for lower cost; (2) reduce program overlap and 

administrative costs; and (3) strengthen coordination and alignment across 

programs and funding streams. Part of this grant money will be made available 

through a pilot program that pays for services only after defined outcomes are 

achieved through effective, promising strategies, according to department 

officials. In addition, officials reported that Labor and HHS, along with other 

federal agencies, have been meeting to identify opportunities for promoting joint 

strategic planning across programs. Officials said the departments will be 

examining incentives for states and localities to undertake strategic planning 

across programs as a way to increase administrative efficiencies and alignment 

of core public workforce, as well as partner programs such as Temporary 

Assistance for Needy Families. 

Action 2 

Labor and HHS should examine the 

incentives for states and localities to 

undertake initiatives in increasing 

administrative efficiencies in 

employment and training programs 

and, as warranted, identify options for 

increasing such incentives. 

 Partially addressed ◐

For more information, contact Andrew Sherrill 

at (202) 512-7252 or sherrilla@gao.gov. 

See GAO-11-318SP Actions Needed
Page 53 GAO-12-453SP Follow-up on 2011 Report 

Training, Employment, and Education 

33. Teacher quality: proliferation of programs 

complicates federal efforts to invest dollars effectively 

Action 1 progress 

No executive action taken. The Department of Education noted barriers to 

program alignment, such as programs with differing definitions for similar 

populations of grantees, which create an impediment to coordination. 

Action 2 progress 

Two proposed bills currently pending before Congress would, in part, repeal 

provisions of the ESEA, as amended. The Setting New Priorities in Education 

Spending Act was introduced in the House on May 13, 2011, with the intended 

purpose of repealing ineffective or unnecessary education programs.24

According to the committee reporting the bill, it would repeal the authorization for 

more than 40 education programs, some of which are related to teacher quality. 

In addition, the Senate Committee on Health, Education, Labor and Pensions 

reported an original bill, the Elementary and Secondary Education 

Reauthorization Act of 2011, on October 20, 2011, which would also repeal 

various ESEA provisions that may impact teacher quality programs.

25

Action 3 progress 

No legislative action identified. 

 

24H.R. 1891, 112th Cong. (2011). 25Although this original bill has been reported out of the committee, as of January 27, 

2012, it had not yet been introduced in the Senate and therefore does not have a bill 

number. For the text of the original bill, refer to 

http://www.help.senate.gov/hearings/hearing/?id=b4d24a56-5056-9502-5d73-

a45a120b096b. 

Overall assessment

◐

Action 1 

The Secretary of Education should 

work with other agencies as 

appropriate to develop a coordinated 

approach for routinely and 

systematically sharing information that 

can assist federal programs, states, 

and local providers in achieving 

efficient service delivery. 

Not addressed ○

Action 2 

Congress could help eliminate some of 

the barriers to program alignment 

through legislation, particularly through 

the pending reauthorization of the 

Elementary and Secondary Education 

Act of 1965 (ESEA) and other key 

education bills. Specifically, Congress 

may choose either to eliminate 

programs that are too small to evaluate 

cost-effectively or combine programs 

serving similar target groups into a 

larger program. 

Partially addressed ◐

Action 3 

Congress might also include legislative 

provisions to help the Department of 

Education reduce fragmentation, such 

as by giving broader discretion to the 

agency to move resources away from 

certain programs. Congress could 

provide the department guidelines for 

selecting these programs. To the 

extent that overlapping programs 

continue to be authorized, they could 

be better aligned with each other in a 

way that allows for comparison and 

evaluation to ensure they are 

complementary rather than duplicative. 

Not addressed ○

For more information, contact George A. Scott 

at (202) 512-7215 or scottG@gao.gov. 

See GAO-11-318SP Actions Needed
Page 54 GAO-12-453SP Follow-up on 2011 Report 

Economic Development 

34. Fragmentation of financial literacy efforts makes 

coordination essential 

Action 1 progress 

If implemented, the Financial Literacy and Education Commission’s 2011 

National Strategy will address GAO’s suggestion to strengthen the 

Commission’s coordination and clearinghouse efforts. The strategy identifies 

coordination as one of five action areas and sets a goal of establishing a 

clearinghouse of federal research, best practices, and other information related 

to financial literacy. According to Commission staff, their goal is to initiate the 

clearinghouse in early 2012. 

Action 2 progress 

As the new Bureau of Consumer Financial Protection has been hiring staff and 

planning its financial education activities, it has been in regular communication 

with the Department of the Treasury. Department officials told us that the two 

agencies meet about once a month in an effort to coordinate their respective 

roles and activities. These coordination efforts are ongoing and not enough time 

has passed to assess their results.

Action 3 progress 

The Financial Literacy and Education Commission’s 2011 National Strategy and 

accompanying implementation plan discuss strategies for involving and working 

with nonfederal entities in achieving the commission’s goals, but not enough 

time has passed to assess the execution of the National Strategy. 

Overall assessment

◐

Action 1 

The Financial Literacy and Education 

Commission should enhance its efforts 

to coordinate federal activities, such as 

by exploring further opportunities to 

strengthen its role as a central 

clearinghouse for federal financial 

literacy resources. 

Partially addressed ◐

Action 2 

The Office of Financial Education, 

within the Bureau of Consumer 

Financial Protection, and the Office of 

Financial Education and Financial 

Access, within the Department of the 

Treasury, will need to coordinate their 

roles and activities closely to avoid 

unnecessary overlap and make the 

most productive use of their respective 

resources. 

Partially addressed ◐

Action 3 

The Financial Literacy and Education 

Commission should build on progress 

it has made in recent years in 

promoting partnerships among the 

federal, state, local, nonprofit, and 

private sectors. 

Partially addressed ◐
Page 55 GAO-12-453SP Follow-up on 2011 Report 

Economic Development 

34. Financial literacy (continued) 

Action 4 progress 

The 2011 National Strategy for Financial Literacy sets goals for encouraging 

evidence-based research and outcome-based program evaluation, although 

evaluation tools have yet to be completed and disseminated to federal agencies. 

The Financial Literacy and Education Commission’s 2011 implementation plan 

includes developing a federal action plan for these goals and the Departments of 

the Treasury and Education have plans to share lessons learned from existing 

research with other federal agencies. However, the National Strategy does not 

make recommendations for allocating federal resources accordingly. 

Action 4 

Federal agencies should measure the 

outcomes of their financial literacy 

efforts and federal financial literacy 

resources should be focused on those 

agencies and programs with the most 

expertise and best track records. The 

Financial Literacy and Education 

Commission and the Bureau of 

Consumer Financial Protection could 

potentially play a role in developing or 

disseminating a standard set of 

evaluation tools or benchmarks that 

would help assess which federal 

initiatives have the most effective 

outcomes. 

Partially addressed ◐

For more information, contact Alicia Puente 

Cackley at (202) 512-8678 or 

cackleya@gao.gov.

See GAO-11-318SP Actions Needed
Page 56 GAO-12-453SP Follow-up on 2011 Report 

Agriculture 

35. Reducing some farm program payments could result 

in savings from $800 million over 10 years to up to $5 

billion annually 

Action 1 progress 

No legislative action identified. 

Overall assessment

○

Action 1 

Congress may wish to consider 

reducing or eliminating fixed annual 

payments to farmers, called direct 

payments, by (1) lowering payment or 

income eligibility limits; (2) reducing the 

portion of a farm’s acres eligible for the 

payments; or (3) terminating or 

phasing out direct payments. 

Not addressed ○

For more information, contact Lisa Shames at 

(202) 512-3841or shamesl@gao.gov.

See GAO-11-318SP Actions Needed
Page 57 GAO-12-453SP Follow-up on 2011 Report 

Defense 

36. DOD should assess costs and benefits of overseas 

military presence options before committing to costly 

personnel realignments and construction plans, thereby 

possibly saving billions of dollars 

Action 1 progress 

DOD has taken some steps that would facilitate such a reassessment, but has 

not completed a comprehensive reassessment of its overseas presence that 

includes the costs and benefits of alternatives. For example, DOD has instituted 

a global posture prioritization panel wherein the combatant commands, the 

services, the Office of the Secretary of Defense, and other relevant DOD 

organizations prioritize global posture initiatives collectively and do so in time for 

those initiatives that are selected to be included in each service’s budget plan. In 

addition, DOD has issued guidance that requires combatant commands to report 

costs associated with planned projects in their respective posture plans but has 

not finalized the instruction that would implement this guidance. 

Additionally, in the report accompanying the Senate bill for the National Defense 

Authorization Act for Fiscal Year 2012, the Senate Armed Services Committee 

discussed the importance of using an objective and transparent methodology to 

capture the full current cost and estimate the future cost of military overseas 

presence.26 For example, the committee directed DOD to provide an update on 

its plans to implement GAO recommendations to more accurately and 

comprehensively account for costs related to overseas posture plans. 

Action 2 progress 

In January 2012, the administration announced that the Army will remove two 

brigade combat teams from Europe, but did not specify when this would occur. 

Also, DOD is considering increasing its naval presence overseas to meet 

ballistic missile defense requirements for the region. At present, DOD is 

assessing the cost and benefits of stationing naval forces in Spain to meet the 

requirement. According to DOD officials, the Department will provide an 

overview of planned changes to posture in Europe in its annual report to 

Congress on global defense posture in spring 2012. 

Action 3 progress 

DOD is taking steps to determine the future task force’s presence in Djibouti and 

how it will be funded and sustained, but has not yet developed specific plans 

and funding estimates. DOD officials told GAO that U.S. Africa Command has 

assessed the need for the task force and determined the task force to be integral 

to the U.S. presence in East Africa through at least 2017, and that final decisions 

about specific needs will be made later in 2012 as part of the department’s 

review of worldwide posture plans. 

In a committee report, the Senate Appropriations Committee directed the 

Secretary of the Navy to submit a master plan that would include information on 

the planned facilities for Camp Lemonier in Djibouti. An annual update to the 

master plan is to be submitted to the defense committees with the budget 

submission,27 which usually occurs in February each year. According to DOD 

officials, the Navy is currently conducting a facilities-planning effort and the 

department will submit the master plan to Congress in August 2012.

 

26See S. Rep. No. 112-26, at 191 (2011). 27See S. Rep. No. 112-29, at 12-13 (2011).

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

should conduct a comprehensive 

reassessment of its overseas 

presence, including the costs and 

benefits of various alternatives. 

Partially addressed ◐

Action 2 

To address specific regional issues in 

Europe, DOD should reassess plans in 

Europe, including the costs and 

benefits of keeping Army brigades in 

Germany and the appropriateness of 

building a new Army headquarters 

given the potential changes in force 

structure. 

 Partially addressed ◐

Action 3 

To address specific regional issues in 

Africa, DOD should reassess missions 

of the combined joint task force in 

Djibouti as well as identifying the 

projected costs for the task force and, 

in concert with DOD or the Navy, 

developing a realistic funding plan for 

the task force’s sustainability. 

Partially addressed ◐

For more information, contact John Pendleton 

at (202) 512-3489 or pendletonj@gao.gov.

See GAO-11-318SP Actions Needed
Page 58 GAO-12-453SP Follow-up on 2011 Report 

Defense 

37. Total compensation approach is needed to manage 

significant growth in military personnel costs 

Action 1 progress 

DOD has taken some steps to determine the effectiveness of select special and 

incentive pays. For example, DOD employed a contractor to help develop a 

compensation analysis model for selected officer communities and anticipates 

using it, once completed, to help set effective compensation for those officer 

communities. In August 2011, DOD hired the RAND Corporation to develop and 

apply a model to analyze the effect of special and incentive pays on the staff of 

selected officer communities to ensure that staffing goals of the officer 

community can be met and that compensation is efficient. DOD officials 

anticipate that this analysis will be used to help the department and the services 

more efficiently use and set rates for special and incentive pay compensation to 

influence a member’s retention decision. The study, entitled Officer Special and 

Incentive Pay Analysis, is ongoing and expected to be completed in August 

2012. 

To achieve additional progress on this action, DOD should continue analyzing 

special and incentive pays to determine the most efficient amount to offer to 

meet staffing goals, including expanding this study to include the enlisted 

servicemember population. While DOD’s efforts to assess officers’ special and 

incentive pays shows progress, special and incentive pays are one of many 

compensation tools that DOD uses to recruit and retain its active duty personnel. 

Further, special and incentive pays represented less than 5 percent of DOD’s 

compensation costs for active duty personnel. To completely address GAO’s 

action needed, DOD should assess the extent its other pays and benefits 

contribute to its recruiting and retention goals, and use this information to 

formulate a clear compensation strategy that includes performance measures. 

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

could recognize long-term cost 

avoidance by addressing in a 

compensation strategy what types of 

compensation are effective, and not 

incurring costs for compensation that 

may not be effective, in helping the 

department achieve its recruiting and 

retention goals. 

Partially addressed ◐

For more information, contact Brenda S. 

Farrell at (202) 512-3604 or farrellb@gao.gov.

See GAO-11-318SP Actions Needed
Page 59 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

DOD has made some progress in implementing several best practices on 

weapon system acquisition programs, but not all best practices are being 

applied by all acquisition programs and more consistent implementation is 

needed. For example, in March 2011, GAO reported that almost all of the 14 

planned major defense acquisition programs reviewed intended to conduct early 

systems engineering reviews before starting development, but fewer are taking 

other actions, such as developing early prototypes, that could improve their 

chances of success.28 GAO also reported in July 2011 that the military 

departments held configuration steering board meetings—a key mechanism for 

managing changes in system requirements—for 74 of 96 major defense 

acquisition programs they managed in 2010.29 GAO made several 

recommendations to ensure that DOD holds configuration steering boards for all 

programs, and the department is planning to take action to address them. 

Action 2 progress 

DOD has started to address the affordability of its weapon programs on an 

individual basis, but not as a whole. DOD has started to implement its 

September 2010 guidance that requires “should cost” estimates and affordability 

targets be set for each new weapon system acquisition program.30 However, in 

June 2011, GAO reported that DOD’s process for validating new weapon system 

requirements still does not take into account a requirement’s affordability or set 

priorities in a way that can be used to help manage DOD’s overall weapon 

system investments.31 In January 2012, DOD revised its requirements process 

to include joint prioritization, which should be a useful input for balancing 

weapon system investments. 

Action 3 progress 

DOD has made some progress in implementing, but has not yet fully adhered to, 

knowledge-based acquisition approaches. In March 2011, GAO reported that 

newer weapon programs are demonstrating higher levels of knowledge at key 

decision points, but most are still not fully adhering to a knowledge-based 

acquisition approach.32 

 

28GAO, Defense Acquisitions: Assessments of Selected Weapon Programs, 

GAO-11-233SP (Washington, D.C.; Mar. 29, 2011). 29GAO, Defense Acquisitions: DOD Can Improve Its Management of Configuration 

Steering Boards, GAO-11-640 (Washington, D.C.: July 7, 2011). 30“Should-cost” estimates are based on bottoms-up assessments of what programs 

should cost, if reasonable efficiency and productivity enhancements are undertaken. 

They can be used as a basis for contract negotiation and incentives.

31GAO, DOD Weapon Systems: Missed Trade-off Opportunities During Requirements 

Reviews, GAO-11-502 (Washington, D.C.: June 16, 2011). 32GAO, Defense Acquisitions: Assessments of Selected Weapon Programs, 

GAO-11-233SP (Washington, D.C.; Mar. 29, 2011).

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

could achieve significant cost savings 

by employing best management 

practices at all phases of its weapon 

system acquisition process—including 

early systems engineering, analyzing 

alternatives, managing changes in 

system requirements, and more 

prototyping early in programs 

development testing. 

Partially addressed ◐

Action 2 

DOD has started the process of 

reviewing the potential cost of 

individual weapon system programs to 

meet warfighters’ most pressing needs, 

but the department must still address 

the overall affordability of its major 

weapon system investment portfolio. 

Partially addressed ◐

Action 3 

DOD needs to do a better job planning 

and executing programs on a day-today basis to achieve better outcomes. 

Critical to achieving successful 

outcomes is establishing and 

sustaining knowledge-based, realistic 

program baselines. 

Partially addressed ◐

For more information, contact Michael J. 

Sullivan at (202) 512-4841 or 

sullivanm@gao.gov.

See GAO-11-318SP Actions Needed

Defense

38. Employing best management practices could help DOD 

save money on its weapon systems acquisition 

programs
Page 60 GAO-12-453SP Follow-up on 2011 Report 

Defense 

39. More efficient management could limit future costs of 

DOD’s spare parts inventory 

Action 1 progress 

DOD is in the process of implementing its November 2010 Comprehensive 

Inventory Management Improvement Plan (the Plan). In 2011, GAO found that 

DOD’s Plan, which was required by the National Defense Authorization Act for 

Fiscal Year 2010 (Pub. L. No. 111-84, § 328), provides a comprehensive plan 

for improving inventory management systems of the military departments and 

the Defense Logistics Agency.33 One of two goals in the Plan is to reduce the 

amount of on-order excess inventory34 from 8.5 percent of on-order dollars 

above the approved acquisition objective across DOD for fiscal year 2009 to 

6 percent in fiscal year 2014 and 4 percent in fiscal year 2016. Additionally, DOD 

and its components are in the process of reviewing and strengthening its 

approval and reporting procedures for on-order excess, which may result in 

needed updates to DOD and component policy and regulations. Implementation 

of the Plan is ongoing, and DOD does not expect to complete the related action 

items until fiscal year 2015. In May 2012, GAO will report on its assessment of 

DOD’s implementation of the Plan. 

Action 2 progress 

DOD continues to implement its November 2010 Plan, which is, in part, focused 

on improving demand forecasting practices and tracking the efficiency of 

inventory processes. One of the Plan’s nine subplans directly addresses 

demand forecasting weaknesses, including (1) identifying improved methods 

and techniques for demand forecasting, (2) identifying and implementing 

standard metrics to assess forecasting accuracy and bias, (3) expanding and 

refining a departmentwide structure for collaborative forecasting, (4) modifying 

approaches to setting of inventory levels for low-demand items, and (5) 

examining how investment risk for new consumable items can be reduced 

between the Defense Logistics Agency and the military departments. Efforts to 

address these weaknesses are scheduled to occur into fiscal year 2015; 

therefore, it is too early to assess DOD’s progress in improving demand 

forecasting. Additionally, the Plan includes an action to establish 

departmentwide metrics to track and monitor the efficiency of DOD inventory 

operations; however, these efforts are ongoing and have not been finalized. 

 

33GAO, DOD’s 2010 Comprehensive Inventory Management Improvement Plan 

Addressed Statutory Requirements, But Faces Implementation Challenges, 

GAO-11-240R (Washington, D.C.: Jan. 7, 2011). 34Inventory that is not in DOD’s possession but for which a contract has been awarded or 

funds have been obligated is considered to be on-order. 

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

could limit future costs by focusing its 

efforts on better managing on-order 

inventory. Specifically, DOD should 

focus on reducing on-order inventory 

levels that are not needed for current 

needs or projected demand. 

Partially addressed ◐

Action 2 

DOD should address systemic 

weaknesses in demand forecasting, 

revise management practices to 

incorporate flexibility needed to 

minimize the impact of demand 

fluctuations, and track the cost 

efficiency of its inventory management 

processes. 

Partially addressed ◐

For more information, contact Zina Merritt at 

(202) 512-4300 or merrittz@gao.gov. 

See GAO-11-318SP Actions Needed
Page 61 GAO-12-453SP Follow-up on 2011 Report 

Defense 

40. More comprehensive and complete cost data can help 

DOD improve the cost-effectiveness of sustaining 

weapon systems 

Action 1 progress 

According to DOD officials, DOD is revising its acquisition and cost-estimating 

policies to include this requirement. These policies are expected to be issued in 

2012. 

Additionally, the National Defense Authorization Act for Fiscal Year 2012 

requires the Secretary of Defense to issue guidance regarding O&S costs for 

major weapon systems, including requiring the military departments to retain 

each estimate of O&S costs that is developed at any time during the life-cycle of 

a major weapon system, together with supporting documentation used to 

develop the estimate.35 The guidance was due not later than 180 days after the 

date of the enactment of the act, which was on December 31, 2011. As of 

February 10, 2012, the guidance had not been issued. 

Action 2 progress 

According to DOD officials, DOD has studied potential improvements to the 

services’ O&S cost visibility data systems and is in the process of revising 

guidance. 

The Secretary of Defense was also required under the above act to issue 

guidance to establish standard requirements for the collection of data on O&S 

costs for major weapon systems and require the military departments to revise 

their cost visibility data systems to ensure that they collect complete and 

accurate data and make such data available in a timely manner.36 This guidance 

has not yet been issued. 

Action 3 progress 

According to DOD officials, DOD is revising its acquisition policy to include this 

requirement. The revised acquisition policy is expected to be issued in 2012. 

The Secretary of Defense was also required under the act to issue guidance to 

require the military departments to update estimates of O&S costs periodically 

throughout the life-cycle of a major weapon system, to determine whether 

preliminary information and assumptions remain relevant and accurate, and to 

identify and record reasons for variances.37 Guidance in this area has not yet 

been issued. 

 

35See Pub. L. No. 112-81, § 832(a), (b)(2) (2011). 36See § 832(b)(4). 37See § 832(b)(3).

Overall assessment

◐

Action 1 

The Department of Defense (DOD) 

should revise guidance to specifically 

require the retention of life-cycle 

operating and support (O&S) cost 

estimates for major weapon systems, 

as well as the supporting 

documentation used to develop these 

estimates. 

Partially addressed ◐

Action 2 

DOD should identify the cost elements 

needed to track and assess actual 

O&S costs for effective cost analysis 

and program management for major 

weapon systems, and require the 

collection of these elements in the 

services’ O&S cost visibility data 

systems. 

Partially addressed ◐

Action 3 

DOD should require the services to 

periodically update life-cycle O&S cost 

estimates for major weapon systems 

after these systems are acquired, 

which would enhance DOD’s ability to 

compare actual performance to 

planned or expected results. 

Partially addressed ◐
Page 62 GAO-12-453SP Follow-up on 2011 Report 

Defense 

40. Sustaining weapon systems (continued) 

Action 4 progress 

DOD has been evaluating alternatives to improve contractor cost reporting. On 

the basis of their evaluation, DOD officials expect to make policy revisions in 

2012. 

Additionally, the National Defense Authorization Act for Fiscal Year 2012 

requires the Secretary of Defense to issue guidance to establish standard 

requirements for the collection and reporting of data on O&S costs for major 

weapon systems by contractors performing weapon system sustainment 

functions in an appropriate format, and develop contract clauses to ensure that 

contractors comply with such requirements.38 As noted above, guidance has not 

yet been issued. 

 

Action 5 progress 

According to DOD officials, DOD is in the process of revising its acquisition 

policy to include this requirement. Further, an interim directive, valid through 

December 2012, was issued that requires the periodic revalidation of business 

case analyses for major defense acquisition programs and major weapon 

system programs. However, DOD has not yet formally revised its acquisition 

policy. 

Action 6 progress 

In April 2011, DOD issued a Product Support Business Case Analysis 

Guidebook that provides additional details regarding the elements of a business 

case analysis. The updated guidebook also indicates that program offices will 

revalidate the previous product support strategy business case analysis every 

5 years or prior to a change in the weapon system’s product support strategy, as 

required of product support managers by a provision in the National Defense 

Authorization Act for Fiscal Year 2010.39

 

38See § 832(b)(5). 39See Pub. L. No. 111-84, § 805(b)(2)(F) (2009).

Action 4 

DOD should require program offices to 

collect and report detailed support cost 

data for their performance-based 

logistics arrangements. 

Partially addressed ◐

Action 5 

DOD should revise guidance to require 

the development of performancebased logistics business case analyses 

to better support the decision-making 

process on the use of these 

arrangements. 

Partially addressed ◐

Action 6 

DOD should define the elements to be 

included in these performance-based 

logistics business case analyses so 

they are comprehensive and sound. 

Addressed●

For more information, contact Cary B. Russell 

at (404) 679-1808 or russellc@gao.gov.

See GAO-11-318SP Actions Needed
Page 63 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

According to DOD officials, DOD has begun to validate the return on 

investments on corrosion projects that have been completed to demonstrate the 

costs and benefits of the projects. DOD’s Corrosion Prevention and Mitigation 

Strategic Plan suggests that for corrosion projects that have completed research 

and development, transitioned to service use, and been in use for 2 years, a 

project review will be done to validate the overall impact and return on 

investment.40 According to DOD officials, the department has completed 

validating returns on investment on 33 out of 112 projects that were identified in 

fiscal years 2005 through 2008. However, DOD needs to effectively implement 

the ongoing process to validate projects’ return on investments. According to 

DOD officials, the department plans to validate all the completed projects. 

 

40Department of Defense, Corrosion Policy and Oversight Office, Corrosion Prevention 

and Mitigation Strategic Plan, (February 2011).

Overall assessment

◐

Action 1 

If the Corrosion Office wishes to 

convince the Department of Defense 

(DOD) and congressional decision 

makers that more fully funding its 

corrosion prevention programs could 

provide significant return on 

investment, the Corrosion Office needs 

to complete the validation of return on 

investment estimates in order to 

demonstrate the costs and benefits of 

its corrosion prevention and control 

projects. 

Partially addressed ◐

For more information, contact Zina Merritt at 

(202) 512-4300 or merrittz@gao.gov.

See GAO-11-318SP Actions Needed

Defense 

41. Improved corrosion prevention and control practices 

could help DOD avoid billions in unnecessary costs over 

time 
Page 64 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

As of February 6, 2012, the House and Senate had adopted a conference report 

on the FAA Modernization and Reform Act of 2012, but the legislation had not 

been signed by the President at the time our work was completed on February 

10, 2012. 

The conference report updates eligibility criteria and limits program eligibility, 

including the following changes: 

 Only locations that have at least 10 enplanements per day during the 

most recent fiscal year beginning after September 30, 2012, except for 

locations beyond 175 miles of a large- or medium-hub airport, are 

considered eligible under the Essential Air Service (EAS) program, but 

the Secretary of Transportation is allowed to restore eligibility if certain 

conditions are met. Alaska and Hawaii are exempted from this change. 

 For communities in the 48 contiguous United States, eligibility is limited 

to communities that, at any time between September 30, 2010 and 

September 30, 2011 (1) received Essential Air Service, or (2) received a 

90-day notice of intent to terminate air service from an air carrier and the 

Secretary of Transportation required the air carrier to continue service.41

Action 2 progress 

The Consolidated and Further Continuing Appropriations Act, 2012 eliminated 

the requirement that aircraft providing service under the program have a 

minimum 15-seat passenger capacity for fiscal year 2012.42 However, changes 

to other operating requirements, such as flexibility in the number of flights 

provided or regionalization of air service, are possible. 

Action 3 progress 

No legislative action identified. 

 

41H.R. Rep. 112-381, accompanying the FAA Modernization and Reform Act of 2012, 

H.R. 658, 112th Cong. (2012), as reported out on Feb. 1, 2012. 42Pub L. No. 112-55 (2011).

Overall assessment

◐

Action 1 

Congress may wish to consider 

updating eligibility criteria and targeting 

service, including terminating service 

at airports that are less remote from 

medium- or large-hub airports as well 

as changing other program criteria to 

consolidate subsidized air service. 

Addressed ●

Action 2 

Congress may wish to consider 

revising the program’s operating 

requirements for providing air service 

to communities to improve efficiency 

and to better match capacity with 

community use. 

Partially addressed ◐

Action 3 

Congress may wish to consider 

assessing multimodal solutions, such 

as more cost-effective bus service to 

hub airports or air taxi service, to 

provide communities alternatives to 

Essential Air Service. 

Not addressed ○

Economic Development

42. Revising the Essential Air Service program could 

improve efficiency 
Page 65 GAO-12-453SP Follow-up on 2011 Report 

Action 4 progress 

In responding to this report, Department of Transportation officials stated that 

the department is prepared to consider multimodal or surface solutions should 

communities choose to apply to participate in the “Alternative EAS” program 

authorized by the Vision 100—Century of Aviation Reauthorization. 

Action 4 

The Department of Transportation may 

wish to consider assessing multimodal 

solutions, such as more cost-effective 

bus service to hub airports or air taxi 

service, to provide communities 

alternatives to Essential Air Service. 

Addressed ●

For more information, contact Gerald 

Dillingham at (202) 512-2834 or 

dillinghamg@gao.gov.

See GAO-11-318SP Actions Needed

Economic Development

42. Essential Air Service (continued) 
Page 66 GAO-12-453SP Follow-up on 2011 Report 

Economic Development 

43. Improved design and management of the universal 

service fund as it expands to support broadband could 

help avoid cost increases for consumers 

Action 1 progress 

FCC has taken action to reform two of the four Universal Service Fund 

programs. FCC adopted an order in October 2011 to comprehensively reform 

and modernize the Universal Service Fund high-cost support mechanisms.43 

This was a significant step by FCC to restructure the high-cost program—the 

largest of the four Universal Service Fund programs. The design of the 

restructured program is intended to better target funding to bring broadband 

services to unserved areas. In June 2011, FCC adopted changes to the lowincome program to detect and prevent duplicative claims from the same 

consumer44 and, on January 31, 2012, adopted an order containing additional 

low-income program reforms.45 According to FCC, these reforms will modernize 

the program and further reduce waste, fraud, and abuse by program 

participants. However, FCC is still considering some proposed changes to the 

rural health care program and has not undertaken any comprehensive reforms 

of the E-rate program.

Action 2 progress 

FCC has taken action to address some of GAO’s recommendations for the four 

Universal Service Fund programs. FCC adopted an order in October 2011 to 

comprehensively reform and modernize the Universal Service Fund high-cost 

support mechanisms. The order adopts some goals and performance measures 

for the restructured high-cost program, establishes a budget—although not a 

price cap—for the program, and reforms some of the accountability and 

oversight procedures governing the companies that participate in the program. 

FCC also established some goals and performance measures for the lowincome program in its January 2012 order. In addition, FCC has taken action to 

improve internal controls over the Universal Service Fund programs, including 

conducting risk assessments of the E-rate and low income programs. FCC will 

still need to conduct performance evaluations to determine if its reforms are 

working and should conduct needs assessments to inform changes to and the 

establishment of goals and performance measures for the E-rate and rural 

health care programs. 

 

 

43Connect America Fund et al., FCC 11-161, Report and Order and Further Notice of 

Proposed Rulemaking (rel. Nov. 18, 2011). 

44Lifeline and Link Up Reform and Modernization et al., FCC 11-97, Report and Order, 26 

FCC Rcd 9022 (rel. June 21, 2011). 

45Lifeline and Link Up Reform and Modernization et al., FCC 12-11, Report and Order 

and Further Notice of Proposed Rulemaking (rel. Feb. 6, 2012).

Overall assessment

◐

Action 1 

The Federal Communications 

Commission (FCC) needs to undertake 

a broader rethinking of the vision, size, 

structure, and goals of the Universal 

Service Fund. 

Partially addressed ◐

Action 2 

FCC needs to improve its management 

of the Universal Service Fund 

programs to address a number of GAO 

recommendations, including that FCC 

establish clear performance goals and 

measures for the programs. 

Partially addressed ◐

For more information, contact Mark Goldstein 

at (202) 512-2834 or goldsteinm@gao.gov. 

See GAO-11-318SP Actions Needed
Page 67 GAO-12-453SP Follow-up on 2011 Report 

Economic Development 

44. The Corps of Engineers should provide Congress 

with project-level information on unobligated balances 

Action 1 progress 

According to the Corps, it has taken action to compile information on projectlevel unobligated balances and plans to include this information in its fiscal year 

2013 budget presentation, which should be released in mid-February 2012. 

Overall assessment

◐

Action 1 

The U.S. Army Corps of Engineers (the 

Corps) should provide Congress with 

information on estimated project-level 

unobligated balances as a supplement 

to its budget presentation. 

Partially addressed ◐

For more information, contact Anu K. Mittal at 

(202) 512-3841, mittala@gao.gov or Melissa 

Emrey-Arras at (202) 512-6806, 

emreyarrasm@gao.gov. 

See GAO-11-318SP Actions Needed
Page 68 GAO-12-453SP Follow-up on 2011 Report 

Energy 

45. Improved management of federal oil and gas 

resources could result in approximately $1.8 billion46

over 10 years 

Action 1 progress 

Nonfederal oil and gas resource owners are employing a range of policies to 

encourage diligent development of oil and gas leases, including increasing rental 

rates, offering shorter lease terms, and escalating royalty rates.47 Interior is, to 

some extent, taking similar steps. Specifically, for a recent lease sale Interior 

increased the base rental rate from $6.25/acre to $7.00/acre in water depths of 

less than 200 meters and from $9.50/acre to $11/acre for leases in 200 meters 

or deeper. Interior estimates the additional nominal rental revenue received by 

the federal government over the life of leases issued from this sale is $27 million 

over the term of the leases. 

Additionally, to encourage diligent development of federal oil and gas leases, 

both onshore and offshore, Interior sought authority to charge a $4.00/acre 

annual fee on nonproducing federal oil and gas leases in the fiscal year 2011 

and 2012 budget requests, which would become effective upon congressional 

action. However, the fiscal year 2012 appropriations bill for Interior did not 

provide the department with such authority. 

Action 2 progress 

No legislative action identified. 

Action 3 progress 

In order to examine whether current U.S. royalty rates produce a fair return for 

the government overall, Interior contracted for a study to examine the total 

federal revenues that result from development of oil and gas resources on 

federal lands and waters. The study was completed in late 2011 and released 

publicly in 2012. Interior officials have not indicated how the information will 

affect royalty or other policies. 

In addition, Interior has taken steps to examine royalty rates for onshore leases. 

Interior’s Bureau of Land Management (BLM) has completed benefit-cost and 

economic impact analyses on adjusting onshore royalty rates. According to 

BLM, it is now in the process of finalizing a proposed rule to adjust royalty rates. 

The proposed rule is under review by Interior officials, after which it will go to 

OMB for review. BLM expects to publish the proposed rule in the Federal 

Register in early 2012. 

 

46The Department of the Interior, Bureau of Land Management, updated the anticipated 

revenues from $1.75 billion to $1.8 billion in its fiscal year 2012 budget justification. 47GAO, Oil and Gas Leasing: Interior Could Do More To Encourage Diligent 

Development, GAO-09-74 (Washington, D.C.: October 3, 2008).

Overall assessment

◐

Action 1 

The Department of the Interior 

(Interior) should take steps to increase 

the diligent development of federal 

lands and waters leased for oil and gas 

exploration and production. 

Partially addressed ◐

Action 2 

Congress may need to take action to 

authorize or encourage Interior to 

revise its rental fee structure in ways 

that are beyond what is specifically 

authorized to increase rental payments 

for nonproducing leases. 

Not addressed ○

Action 3 

Interior should complete its study 

examining how other oil and gas 

resource owners select fiscal 

parameters for leasing and adjusting 

oil and gas royalty rates and use that 

information to adjust, as appropriate, 

its royalty rates to a level that ensures 

the government a fair return. In doing 

so, it should ensure opportunities for 

substantive, two-way communication 

with program stakeholders. 

Partially addressed ◐
Page 69 GAO-12-453SP Follow-up on 2011 Report 

Energy 

45. Oil and gas resources (continued) 

Action 4 progress 

No legislative action identified. 

Action 5 progress 

GAO has documented that Interior has taken action to implement 5 of the 19 

recommendations GAO made in its March 2010 report to improve oversight of oil 

and gas measurement and improve confidence that the federal government is 

receiving its fair share of oil and gas produced from federal lands. 48 However, 

14 recommendations remain open.

 

48GAO, Oil and Gas Management: Interior’s Oil and Gas Production Verification Efforts 

Do Not Provide Reasonable Assurance of Accurate Measurement of Production 

Volumes, GAO-10-313 (Washington, D.C.: Mar. 15, 2010). 

Action 4 

Depending on the results of the study, 

Congress may wish to provide 

additional guidance or take additional 

actions to enable Interior to change 

how it oversees federal lands and 

waters and the revenues derived from 

production of oil and gas there. 

Not addressed ○

Action 5 

Interior should implement GAO’s 

recommendations from prior reports 

addressing a variety of oil and gas 

measurement factors. 

Partially addressed ◐

For more information, contact Frank Rusco at 

(202) 512-3841 or ruscof@gao.gov.

See GAO-11-318SP Actions Needed
Page 70 GAO-12-453SP Follow-up on 2011 Report 

General Government 

46. Efforts to address governmentwide improper 

payments could result in significant cost savings

Action 1 progress 

Federal entities reported estimates of improper payment amounts that totaled 

$115.3 billion in fiscal year 2011, a decrease from the prior year revised 

estimate of $120.6 billion. Included were improper payment estimates for nine 

additional programs in fiscal year 2011 that did not report an estimate in fiscal 

year 2010, with the Department of Health and Human Services (HHS) Medicare 

Part D program having the highest estimate of the additional reporting programs. 

Nevertheless, the federal government continues to face challenges in 

determining the full extent of improper payments. For example, another three 

programs providing estimates for the first time were not included in the 

governmentwide totals because those programs were still developing their 

estimating methodologies. Also, three federal entities did not report fiscal year 

2011 estimated improper payment amounts for four risk-susceptible programs, 

including HHS’s Children’s Health Insurance Program and Temporary 

Assistance for Needy Families. Audits of federal agencies also continue to 

identify internal control deficiencies over financial reporting, such as financial 

system limitations and information system control weaknesses, which 

significantly increase the risk that improper payments may occur and then may 

not be detected promptly. 

Action 2 progress 

In April 2011, the Office of Management and Budget (OMB) issued guidance on 

agency implementation of IPERA requirements for, among other things, 

reporting recovery auditing results, which are conducted to identify and reclaim 

overpayments. Accordingly, agencies reported recoveries of contractor and 

vendor overpayments of $1.2 billion during fiscal year 2011. Implementation of 

IPERA requirements is a step in the right direction toward providing additional 

transparency and helping to improve oversight and accountability, but continued 

agency top management attention is needed to further reduce the federal 

government’s vulnerability to improper payments. Under OMB implementation 

guidance for Executive Order 13520, fiscal year 2011 was the first year that 

agencies were required to identify and report their improper payments in three 

distinct error categories. This additional information should be useful in 

identifying the causes of improper payments and developing corrective actions, 

and could assist in OMB’s plans to enhance agencies’ deployment of forensic 

technologies to help prevent fraud and error. 

Additionally, the Senate Committee on Appropriations increased oversight of 

Department of Veterans Affairs’ improper payments by directing the department 

to report to the Committees on Appropriations of both chambers of Congress on 

what steps have been taken to adopt recovery audits as a means of reducing 

and recovering improper payments.49

 

49S. Rep. No. 112-29 (2011).

Overall assessment

◐

Action 1 

Until the federal government has 

implemented effective processes to 

determine the full extent to which 

improper payments occur and to 

reasonably assure that appropriate 

actions are taken across entities and 

programs to effectively recover and 

reduce improper payments, the federal 

government will not have reasonable 

assurance that the use of taxpayer 

funds is adequately safeguarded. 

Partially addressed ◐

Action 2 

The level of importance the agencies 

and the administration place on the 

efforts to implement the requirements 

established by the Improper Payments 

Elimination and Recovery Act of 2010 

(IPERA); Executive Order 13520, 

Reducing Improper Payments; and 

other guidance will be a key factor in 

determining their overall effectiveness 

in reducing improper payments and 

ensuring that federal funds are used 

efficiently and for their intended 

purposes. 

Partially addressed ◐

For more information, contact Susan Ragland 

at (202) 512-9500 or raglands@gao.gov.

See GAO-11-318SP Actions Needed
Page 71 GAO-12-453SP Follow-up on 2011 Report 

General Government 

47. Promoting competition for the over $500 billion in 

federal contracts could potentially save billions of 

dollars over time 

Action 1 progress 

OMB has made progress in promoting competition, but needs to continue this 

effort. Specifically, OMB has called for agencies to reduce obligations under 

new, high-risk contract actions, including contracts awarded noncompetitively, 

by 10 percent in fiscal year 2010, but the extent to which agencies met this goal 

is unclear. In November 2011, GAO made a number of recommendations, 

including that OMB continue to focus on its savings initiative and clarify how it 

aligns with other new initiatives, clarify guidance on how agencies’ initiatives are 

defined and reported, and expand the initiative to include all high-risk actions.50

GAO also recommended that OMB report on the results of the initiative through 

fiscal year 2011. The agency agreed to adopt, where appropriate, GAO’s 

recommendations regarding methodological and data concerns. 

Action 2 progress 

The largest federal contracting agency, the Department of Defense (DOD), has 

taken some actions to promote competition, specifically focusing on maximizing 

competition in situations where only one offer is received in a procurement 

utilizing competitive procedures. An April 2011 memorandum directs that if a 

solicitation was advertised for less than 30 days and only one offer is received, 

the contracting officer shall cancel and re-solicit for an additional 30 days, unless 

an exception or waiver is granted. Other guidance further directs that if the 

solicitation was open for at least 30 days, or has been re-advertised and still only 

one offer is received, the contracting officer shall conduct negotiations with the 

offeror, unless a waiver is granted, but in no event should the negotiated price 

exceed the price originally offered. If this guidance is implemented effectively, 

DOD should realize the benefits of enhanced competition. We will continue to 

monitor progress in promoting competition by DOD and by civilian agencies as 

well. 

 

50GAO, Federal Contracting: OMB's Acquisition Savings Initiative Had Results, 

but Improvements Needed, GAO-12-57 (Washington, D.C.: Nov. 15, 2011). 

Overall assessment

◐

Action 1 

The Office of Management and Budget 

(OMB) needs to continue to focus on 

reducing obligations under high-risk 

contracts, including those awarded 

noncompetitively. 

Partially addressed ◐

Action 2 

Program and contracting officials need 

to actively promote competition. 

Partially addressed ◐

For more information, contact John P. Hutton 

at (202) 512-4841 or huttonj@gao.gov.

See GAO-11-318SP Actions Needed
Page 72 GAO-12-453SP Follow-up on 2011 Report 

General Government 

48. Applying strategic sourcing best practices 

throughout the federal procurement system could save 

billions of dollars annually 

Action 1 progress 

Federal agencies made progress using strategic sourcing approaches to 

achieve cost savings and other efficiencies, but some agencies, such as the 

Department of Defense (DOD), have not fully collected information on the use of 

strategic sourcing. In November 2011, GAO reported that almost all of the 24 

largest federal agencies reported some savings in fiscal year 2010 associated 

with the use of strategic sourcing.51 For example, after conducting a spend 

analysis of its air ambulatory services, the Bureau of Prisons reported savings of 

30 percent, or about $1.5 million, from negotiating a nationwide agreement 

rather than relying on locally competed contracts. The Department of Homeland 

Security (DHS) established a departmentwide strategic sourcing program office, 

which reported saving about $347 million in fiscal year 2010 through a portfolio 

of more than 300 departmentwide contracts and by participating in the General 

Service Administration’s Federal Strategic Sourcing Initiative. The office reported 

that DHS components leveraged their buying power to save more than $60 

million by using volume software license agreements, $1.3 million on purchases 

of body armor, and about $2.8 million on office supplies. Several 

governmentwide federal strategic sourcing initiatives are in place and, according 

to officials from the Office of Management and Budget (OMB), have produced 

savings in areas such as domestic delivery services and wireless 

telecommunications. For example, OMB officials estimated the savings for fiscal 

year 2011 from governmentwide Federal Strategic Sourcing Initiatives for 

domestic delivery services to be approximately $31 million, and approximately 

$5.3 million on wireless telecommunications expense management services. 

GAO has not independently verified these estimates. In addition, GAO reported 

in December 2011 that one of these initiatives for office supplies produced an 

estimated savings of $16 million from June 2010 through August 2011.52

However, further efforts are needed to more fully embrace strategic sourcing 

initiatives. For example, DOD, the government’s largest purchaser, has not fully 

collected and assessed cost savings and other information from strategic 

sourcing initiatives. 

 

51GAO, Federal Contracting: OMB’s Acquisition Savings Initiative Had Results, but 

Improvements Needed, GAO-12-57 (Washington D.C.: Nov. 15, 2011). 52GAO, Strategic Sourcing: Office Supplies Study Had Limitations, but New Initiative 

Shows Potential for Savings, GAO-12-178 (Washington D.C.: Dec. 20, 2011).

Overall assessment

◐

Action 1 

Acquisition leaders across the 

government need to more fully 

embrace the strategic sourcing 

initiative, beginning with collecting, 

maintaining, and analyzing data on 

current procurement spending. Then, 

agencies have to conduct 

assessments of acquisition and supply 

chain functions to initiate 

enterprisewide transformations. 

Partially addressed ◐

For more information, contact Cristina 

Chaplain at (202) 512-4841 or 

chaplainc@gao.gov.

See GAO-11-318SP Actions Needed
Page 73 GAO-12-453SP Follow-up on 2011 Report 

General Government 

49. Adherence to new guidance on award fee contracts

could improve agencies’ use of award fees and produce 

savings 

Action 1 progress 

The five contracting agencies GAO reviewed in 2009 are working to develop and 

refine ways to implement and manage the use of award fees in accordance with 

the Federal Acquisition Regulation; however, it is too soon to determine the full 

impact of these actions. From August 2009 to February 2011, the National 

Aeronautics and Space Administration and the Departments of Defense, Energy, 

Homeland Security, and Health and Human Services, which comprised more 

than 95 percent of spending using award fees in 2008, took action by issuing 

policy guidance or updating agency regulation or guidance to be more consistent 

with the Federal Acquisition Regulation or in response to GAO's 

recommendations. These actions were aimed at improving award fee 

contracting, such as ensuring that all award fee plans include criteria related to 

cost, schedule, and performance and that award fees are only earned for 

successful outcomes. Improving agency guidance, while an important step, will 

need to be consistently implemented over time to achieve the desired effect of 

motivating excellent contractor performance. GAO will be evaluating the 

agencies’ implementation of this action. 

 

53Rollover of unearned award fee is where unearned award fees are transferred from one 

evaluation period to a subsequent period, thus allowing contractors additional 

opportunities to earn previously unearned fees.

Overall assessment

◐

Action 1 

Sustained progress in the use of award 

fees will require that contracting 

agencies adhere to the recent changes 

to the Federal Acquisition Regulation, 

which in 2009 prohibited the practices 

of rollover of unearned award fees and 

awarding fees to contractors that have 

performed unsatisfactorily.53 Further 

efforts are needed by agencies to 

identify methods to evaluate the 

effectiveness of award fees as a tool 

for improving contractor performance. 

Partially addressed ◐

For more information, contact John P. Hutton 

at (202) 512-4841 or huttonj@gao.gov.

See GAO-11-318SP Actions Needed
Page 74 GAO-12-453SP Follow-up on 2011 Report 

General Government 

50. Agencies aim to save at least $3 billion by continued 

disposal of unneeded federal real property 

Action 1 progress 

OMB did not develop the recommended action plan. However, OMB is 

coordinating with federal agencies to finalize the governmentwide cost savings 

plans that it projects will exceed the $3 billion target by half a billion dollars, 

according to OMB officials. Further, OMB officials reported that as of the end of 

2011, agencies have achieved in total $1.5 billion dollars of the $3 billion goal. 

GAO has not independently verified these estimates. In addition, the Civilian 

Real Property Realignment Act (CPRA), included in the President’s fiscal year 

2012 budget proposal, would streamline the real property disposal process by 

establishing an independent board to assist agencies in identifying unneeded 

real property. The proposed independent board partially responds to the 

challenges GAO has identified. It could address stakeholder influences by 

recommending federal properties for disposal or consolidation after receiving 

recommendations from civilian landholding agencies and independently 

reviewing the agencies’ recommendations. CPRA would also establish an Asset 

Proceeds and Space Management Fund that could be used to reimburse 

agencies for necessary disposal costs. 

A version of CPRA similar to the President’s proposal was introduced in the 

House on May 4, 2011.54 The bill was reported out of the House Transportation 

and Infrastructure Committee and passed the House of Representatives on 

February 7, 2012. In the Senate, CPRA was introduced on August 2, 2011.55

 

54H.R. 1734, 112th Cong. (2011).

55S. 1503, 112th Cong. (2011).

Overall assessment

◐

Action 1 

The Office of Management and Budget 

(OMB) could assist agencies in 

meeting a June 2010 Presidential 

Memorandum target of $3 billion in 

savings related to property disposals 

and other methods by developing an 

action plan to address key problems 

associated with disposing of unneeded 

real property, including reducing the 

effect of competing stakeholder 

interests on real property decisions. 

Partially addressed ◐

For more information, contact David Wise at 

(202) 512-2834 or wised@gao.gov.

See GAO-11-318SP Actions Needed
Page 75 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

OMB has not directly addressed leasing issues by developing the recommended 

strategy. OMB, however, indicated that lease savings will account for some of 

the targeted $3 billion savings from property disposals and other methods. The 

Civilian Real Property Realignment Act (CPRA), included in the President’s 

fiscal year 2012 budget proposal, did not explicitly address the government’s 

overreliance on leasing, but could help do so by facilitating consolidated 

operations where appropriate. 

A similar legislative version of CPRA was introduced on May 4, 2011, which 

stated that one of the purposes of the act was to “reduce the reliance on costly 

leased space.”56 The bill was reported out of the House Transportation and 

Infrastructure Committee and passed the House of Representatives on February 

7, 2012. In the Senate, CPRA was introduced on August 2, 2011, and also 

stated that one of its purposes was to “reduce the reliance on costly leased 

space.”57

 

56H.R. 1734, 112th Cong. (2011). 

57S. 1503, 112th Cong. (2011).

 Overall assessment

◐

Action 1 

The Office of Management and Budget 

(OMB) should develop a strategy to 

reduce agencies’ reliance on costly 

leasing where ownership would result 

in long-term savings. Such a strategy 

could identify the conditions under 

which leasing is an acceptable 

alternative, include an analysis of real 

property budget scoring issues, and 

provide an assessment of viable 

alternatives. 

Partially addressed ◐

For more information, contact David Wise at 

(202) 512-2834 or wised@gao.gov.

See GAO-11-318SP Actions Needed

General Government 

51. Improved cost analyses used for making federal 

facility ownership and leasing decisions could save 

millions of dollars 
Page 76 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

OMB has begun implementing its planned improvements to its IT Dashboard. 

For example, in September 2011, OMB officials stated that work is under way to 

change the Dashboard’s cost and schedule ratings calculations to improve 

insight into current performance. Specifically, officials said that the new 

calculations will emphasize ongoing work and reflect only development efforts, 

not operations and maintenance activities. In addition, in July 2011, OMB issued 

guidance requiring agencies to report investment work activities in increments of 

6 months or less. OMB officials stated that this revised reporting process and the 

updated rating calculations will be reflected in a new version of the Dashboard, 

which is to be publicly deployed upon release of the President's Budget for fiscal 

year 2013. Once fully implemented by OMB, these changes could be significant 

steps toward improving insight into current investment performance on the 

Dashboard. GAO plans to evaluate the new version of the Dashboard once it is 

publicly available in 2012. 

Action 2 progress 

In 2011, congressional committees requested that GAO further review the 

accuracy of the data on the IT Dashboard and inform Congress on the costs and 

schedule performance of IT investments to help improve congressional oversight 

efforts. A congressional committee also recently asked GAO to utilize the 

Dashboard to conduct performance trend analyses of agencies' IT investments 

to determine if they are improving over time, and to report to Congress on the 

results of the review. 

Overall assessment

◐

Action 1 

Office of Management and Budget 

(OMB) should complete planned 

improvements to its IT Dashboard, as 

well as implementation of GAO’s 

recommendations. 

Partially addressed ◐

Action 2 

Additional opportunities for potential 

cost savings exist with the continued 

use of the Dashboard by congressional 

committees to support critical oversight 

efforts. 

Addressed ●

For more information, contact David A. 

Powner at (202) 512-9286 or 

pownerd@gao.gov.

See GAO-11-318SP Actions Needed

General Government

52. The Office of Management and Budget’s IT Dashboard

reportedly has already resulted in savings and can further 

help identify opportunities to invest more efficiently in 

information technology 
Page 77 GAO-12-453SP Follow-up on 2011 Report 

General Government 

53. Increasing electronic filing of individual income tax 

returns could reduce IRS’s processing costs and increase 

revenues by hundreds of millions of dollars 

Action 1 progress 

IRS updated its publication to require all tax preparation software firms to print an 

identifier on paper returns created with their tax preparation software. 

Action 2 progress 

IRS developed a reject prevention strategy that engaged stakeholders and has 

helped provide clearer reject descriptions. 

 

Action 3 progress 

IRS’s 2012 revenue proposals included a legislative proposal that would require 

all taxpayers who prepare their returns electronically but print and file them on 

paper to print the returns with a 2-D barcode. There has been no action on this 

legislative proposal. 

Action 4 progress 

No executive action taken. IRS updated its Advanced E-file report in December 

2010, which identified options to increase electronic filing, but it has yet to define 

an overall strategy. 

Overall assessment

◐

Action 1 

If the Internal Revenue Service (IRS) 

were to collect more information via 

expanded software identification 

numbers on tax returns, such 

information could support research into 

how software affects electronic filing. 

Addressed ● 

Action 2 

IRS needs to develop a tax return 

reject prevention strategy, include 

external stakeholders in its reject 

working group, develop an action plan 

for that group, and provide clearer 

descriptions of why returns are being 

rejected. 

Addressed ●

Action 3 

IRS should determine actions needed 

to require software vendors to include 

bar codes on printed individual income 

tax returns and the cost of those 

actions. GAO continues to believe that 

bar coding of printed returns has the 

potential to reduce processing costs, 

facilitate access to taxpayer 

information, and improve compliance. 

Partially addressed ◐

Action 4 

IRS should develop an overall strategy 

for increasing electronic filing. 

Not addressed ○

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 78 GAO-12-453SP Follow-up on 2011 Report 

General Government 

54. Using return on investment information to better 

target IRS enforcement could reduce the tax gap; for 

example, a 1 percent reduction would increase tax 

revenues by $3.8 billion58

 

Action 1 progress 

While IRS officials have reported that ROI is one of many useful management 

tools, IRS has not moved to extend ROI to existing enforcement programs. 

 

Action 2 progress 

IRS has developed a preliminary means of determining actual revenue collected 

from enforcement initiatives proposed in the fiscal year 2009 budget justification. 

However, actual cost information, particularly a process for determining indirect 

costs, is still under development. IRS cannot make comparisons without actual 

ROI. 

 

 

Action 3 progress 

For its fiscal year 2012 budget justification, IRS worked with the Department of 

the Treasury to determine which legislative proposals would be included in the 

budget, and then IRS provided aggregate cost information for all legislative 

proposals formulated in time to develop a cost estimate. As a result, Congress 

and other stakeholders obtained preliminary cost information to use when 

weighing the proposals. 

 

58The net tax gap was updated in 2012 and estimated to be $385 billion for the 2006 tax 

year. Thus, a 1 percent reduction would increase tax revenues by $3.8 billion. 

Overall assessment

◐

Action 1 

The Internal Revenue Service (IRS) 

should continue to increase its use of 

return on investment (ROI) information. 

This will require additional research to 

identify the impacts of specific 

programs, including the effect on 

voluntary compliance by taxpayers. 

Not addressed ○

Action 2 

Once actual ROI statistics are 

developed for programs, and 

supplemented with compliance cost 

information, IRS could compare 

 - results across programs and 

 - actual ROI to projected ROI to 

 determine if anticipated results 

 were actually achieved. 

Partially addressed ◐

Action 3 

IRS should coordinate with the 

Department of the Treasury to provide 

Congress with preliminary cost 

estimates or descriptions of resource 

needs for legislative proposals in future 

budget justifications. 

Addressed ●

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 79 GAO-12-453SP Follow-up on 2011 Report 

General Government 

55. Better management of tax debt collection may 

resolve cases faster with lower IRS costs and increase 

debt collected 

Action 1 progress 

IRS established objectives and performance measures for the notice phase—the 

first phase of IRS’s three-phase process for resolving individuals’ unpaid tax 

debts—in February 2011. In addition, IRS has tasked the Office of Taxpayer 

Correspondence with responsibility for overseeing improvements to IRS 

correspondence, including collection notices. Although IRS has planned for its 

Collection Governance Council to be responsible for an annual management 

review of how well the notice phase of the collection process performed, IRS has 

not yet completed the needed review. 

 

Action 2 progress 

IRS better documented the business rules and their rationales by preparing 

notice effectiveness reports for the three highest-volume collection notices, 

including detailed descriptions of the notices and rationales for business rules. 

IRS also planned an annual evaluation of the business rules. However, IRS has 

not yet fully implemented the plan or completed the first annual evaluation. IRS 

officials expect to finalize the evaluation by April 2012. 

Overall assessment

◐

Action 1 

The Internal Revenue Service (IRS) 

needs to establish objectives and 

performance measures for the notice 

phase of its collection process for 

individual taxpayers as well as 

management responsibility for 

reviewing the performance of the 

notice phase. 

Partially addressed ◐

Action 2 

IRS needs to better document the 

business rules and their rationales, and 

periodically evaluate how well they are 

working. 

Partially addressed ◐

For more information, contact Michael Brostek 

at (202) 512-9110 or brostekm@gao.gov.

See GAO-11-318SP Actions Needed
Page 80 GAO-12-453SP Follow-up on 2011 Report 

General Government 

56. Broadening IRS’s authority to correct simple tax 

return errors could facilitate correct tax payments and 

help IRS avoid costly, burdensome audits 

Action 1 progress 

No legislative action identified. 

Overall assessment

○

Action 1 

Congress many want to consider 

granting the Internal Revenue Service 

(IRS) broader math error authority, with 

appropriate safeguards against misuse 

of that authority, to correct errors 

during tax return processing. 

Not addressed ○

For more information, contact Michael Brostek 

or James R. White at (202) 512-9110 or 

brostekm@gao.gov or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 81 GAO-12-453SP Follow-up on 2011 Report 

General Government 

57. Enhancing mortgage interest information reporting 

could improve tax compliance 

Action 1 progress 

IRS indicated that its research staff would study changing Form 1098 to include 

additional information but does not have sufficient data on the volume and 

magnitude of noncompliance to make any changes yet. 

Action 2 progress 

IRS disagreed with this recommendation after performing a benefits and impact 

analysis on making the change, and said that its existing enforcement programs 

identify and address noncompliance. IRS officials also said that the incremental 

benefits of the recommendation are outweighed by the additional burden that 

would be imposed on third-party records. GAO maintains that adding address 

information would be helpful for achieving greater compliance. 

Overall assessment

○

Action 1 

The Internal Revenue Service (IRS) 

should revise Form 1098, the 

Mortgage Interest Statement, to 

include information on the address of a 

property securing a mortgage, 

mortgage balances, and an indicator of 

whether the mortgage is for a current 

year refinancing. 

Not addressed ○ 

Action 2 

IRS should require mortgage-secured 

property addresses to be reported on 

other forms to help IRS detect 

taxpayers who fail to pay taxes on 

certain forgiven mortgage debt. 

Not addressed ○

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 82 GAO-12-453SP Follow-up on 2011 Report 

General Government 

58. More information on the types and uses of canceled 

debt could help IRS limit revenue losses of forgiven 

mortgage debt 

Action 1 progress 

IRS agreed that third-party data would be useful in identifying whether the debt 

being excluded is for a principal residence, and IRS began using these data 

sources in the examination process. 

IRS also agreed to consider modifying some, but not all, of the forms associated 

with forgiven mortgage debts. Some of the modifications will enable IRS to 

collect more information from lenders about the types of debt being forgiven. 

However, the IRS has not yet implemented all of these form changes. 

 

Overall assessment

◐

Action 1 

The Internal Revenue Service (IRS) 

could determine how much additional 

revenue could be gained by refocusing 

mortgage debt enforcement efforts by 

taking some relatively low-cost steps, 

including revising the associated 

forms, collecting more information from 

taxpayers and lenders, and using thirdparty data to determine whether 

taxpayers are correctly excluding 

mortgage debt from taxable income. 

Partially addressed ◐

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 83 GAO-12-453SP Follow-up on 2011 Report 

General Government 

59. Better information and outreach could help increase 

revenues by tens or hundreds of millions of dollars 

annually by addressing overstated real estate tax 

deductions

Action 1 progress 

No executive action taken. 

Action 2 progress 

IRS took steps to develop a cost-effective means of identifying local 

governments with potentially large nondeductible charges on their real estate tax 

bills, but determined that no cost-effective means was available. As a result, IRS 

has not been able to use such information to perform targeted outreach to 

improve compliance as GAO recommended. However, to meet the spirit of 

GAO’s recommendation, IRS in 2010 distributed guidance to local jurisdictions 

that provided examples of what is and is not deductible and suggested that local 

governments consider modifying their tax bills to alert taxpayers that certain 

items are not allowable as deductions on their federal income tax returns. 

Overall assessment

◐

Action 1 

To improve the Internal Revenue 

Service (IRS) examinations of the real 

estate tax deduction, examination 

guidance needs to clarify the type of 

evidence for verifying deductibility and 

to require examiners to ask taxpayers 

to substantiate deductions that appear 

to include nondeductible charges that 

are large, unusual, or questionable. 

Not addressed ○

Action 2 

IRS needs to develop a cost-effective 

means of identifying local governments 

with potentially large nondeductible 

charges on their real estate tax bills, 

which will support targeted efforts to 

improve compliance. IRS then should 

work with these local governments to 

identify charges that are nondeductible 

and work with the localities and other 

third parties to help taxpayers correctly 

claim the deduction by clarifying for 

them what they can and cannot 

deduct. IRS should also use the 

information to target examinations 

covering the real estate tax deduction. 

Addressed ●

For more information, contact Michael Brostek 

at (202) 512-9110 or brostekm@gao.gov.

See GAO-11-318SP Actions Needed
Page 84 GAO-12-453SP Follow-up on 2011 Report 

General Government 

60. Revisions to content and use of Form 1098-T could 

help IRS enforce higher education requirements and 

increase revenues 

Action 1 progress 

IRS is evaluating the feasibility of using current information reported on the Form 

1098-T, which educational institutions use to report information about qualifying 

education expenses to taxpayers and IRS, in its compliance programs. For 

example, IRS has begun testing compliance initiatives that involve making better 

use of Form 1098-T information. 

Action 2 progress 

IRS is taking steps to address possible changes to the Form 1098-T. However, 

before making changes to the form, IRS plans to address issues identified with 

the accuracy of data on Form 1098-T through outreach efforts to educational 

institutions.

Overall assessment

◐

Action 1 

The Internal Revenue Service (IRS) 

should determine the feasibility of 

using current information reported on 

Form 1098-T in its compliance 

computer matching systems. 

Partially addressed ◐

Action 2 

IRS should revise Form 1098-T to 

improve the usefulness of information 

on qualifying education expenses. 

Partially addressed ◐

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 85 GAO-12-453SP Follow-up on 2011 Report 

General Government 

61. Many options could improve the tax compliance of 

sole proprietors and begin to reduce their $68 billion 

portion of the tax gap 

Action 1 progress 

No executive action taken. 

 

Action 2 progress 

IRS has made minimal progress, as much is left to be done to better understand 

sole proprietor noncompliance, such as the improper claiming of losses. IRS 

has started to collect some nongeneralizable data on certain types of claimed 

losses during examinations of sole proprietor tax returns. IRS also is planning a 

research effort on tax noncompliance that is to include sole proprietors, but that 

research will not start until 2015. 

Overall assessment

○

Action 1 

The Department of the Treasury’s tax 

gap strategy should cover sole 

proprietor compliance in detail while 

coordinating it with broader tax gap 

reduction efforts. Such a strategy could 

include a mix of numerous options. 

Not addressed ○

Action 2 

The Internal Revenue Service (IRS) 

should use its ongoing research efforts 

to develop a better understanding of 

the nature of sole proprietor 

noncompliance, including sole 

proprietors improperly claiming 

business losses. 

Not addressed ○

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 86 GAO-12-453SP Follow-up on 2011 Report 

General Government 

62. IRS could find additional businesses not filing tax 

returns by using third-party data, which show such 

businesses have billions of dollars in sales 

Action 1 progress 

IRS does not plan to develop a partial estimate of the business nonfiler rate, and 

funding to do so using operational data would likely not be available. IRS 

believes its existing operational data on business nonfilers are sufficient. 

However, a more comprehensive estimate could give IRS information that would 

be useful in its strategic planning and determining what priority it should place on 

this type of noncompliance. 

Action 2 progress 

IRS has determined that it does not have the necessary data that could be used 

to measure its business nonfiler efforts across IRS. IRS believes that 

developing such data would be prohibitively costly and plans to continue to use 

data at the operating division level. 

Action 3 progress 

IRS has identified ways to monitor and evaluate its codes for selecting nonfiler 

cases on a regular basis, but does not yet have a formal evaluation plan to guide 

this effort. 

Action 4 progress 

IRS has disseminated training material on using selection codes to verify 

taxpayer statements. IRS has updated the Internal Revenue Manual on the 

codes’ use for some collections staff. 

Action 5 progress 

IRS has requested additional unpublished data from GAO’s analysis to help it 

explore the feasibility of third-party data use. In addition, IRS is seeking access 

to the Central Contractor Registry file, which contains self-reported revenue and 

employment data on businesses that register annually to be awarded federal 

contracts. Collecting these data is an initial step in studying the use of the data. 

Overall assessment

◐

Action 1 

The Internal Revenue Service (IRS) 

should develop at least a partial 

estimate for the business nonfiler rate 

based on its existing inventory of 

cases. 

Not addressed ○

Action 2 

IRS should set a deadline for 

developing performance data on its 

business nonfiler efforts. 

Not addressed ○

Action 3 

IRS should develop a plan for 

evaluating its new initiative, including 

codes for selecting nonfiler cases to 

pursue. 

Partially addressed ◐

Action 4 

IRS should better use income data and 

selection codes in verifying taxpayer 

statements about their filing 

requirements. 

Addressed ●

Action 5 

IRS should study the feasibility and 

cost-effectiveness of using non-IRS, 

private data to verify taxpayer 

statements. 

Partially addressed ◐

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 87 GAO-12-453SP Follow-up on 2011 Report 

General Government 

63. Congress and IRS can help S corporations and their 

shareholders be more tax compliant, potentially 

increasing tax revenues by hundreds of millions of dollars 

each year 

Action 1 progress 

No legislative action identified. 

Action 2 progress 

IRS has an ongoing project to identify potential preparer noncompliance of flowthrough returns. 

IRS plans to work on guidance on S corporation requirements, such as on-basis 

calculations, during 2013. 

IRS updated its guidance to S Corporations on adequate shareholder 

compensation about 6 months before GAO issued its December 2009 report on 

noncompliance with S Corporation tax rules,59 but has not issued more guidance 

since then and has no scheduled date for issuing more guidance. 

 

59GAO, Tax Gap: Actions Needed to Address Noncompliance with S Corporation Tax 

Rules, GAO-10-195 (Washington, D.C.: Dec. 15, 2009).

Overall assessment

◐

Action 1 

Congress could require S corporations 

to use information already available to 

them to calculate shareholders’ basis 

as completely as possible and report it 

to shareholders and the Internal 

Revenue Service (IRS). 

Not addressed ○

Action 2 

IRS should evaluate options for 

improving paid tax return preparer 

performance, send additional guidance 

on S corporation requirements such as 

on basis calculations and adequate 

wage determinations to new S 

corporations, and provide more 

guidance to shareholders and tax 

preparers on determining adequate 

shareholder compensation. 

Partially addressed ◐

For more information, contact Michael Brostek 

at (202) 512-9110 or brostekm@gao.gov.

See GAO-11-318SP Actions Needed
Page 88 GAO-12-453SP Follow-up on 2011 Report 

General Government 

64. IRS needs an agencywide approach for addressing tax 

evasion among the at least 1 million networks of 

businesses and related entities 

Action 1 progress 

IRS has not yet created a documented, agencywide strategy to manage network 

noncompliance efforts; however, it has elements of the strategy. For example, it 

continues to focus on making iterative improvements to its network analysis 

tools. Although these improvements are not contained within an IRS-wide 

strategy, they touch on assessing effectiveness. For example, IRS has taken 

steps to assess its most predominantly used network analysis tool. As part of an 

annual survey, IRS asked users of this tool about its effectiveness and to 

suggest improvements. IRS also certified the tool as conforming to agency 

guidelines and requirements for usefulness. The agency continues to develop 

other data and tools to address network-related noncompliance but not on a 

specific time schedule. IRS also had plans to create a research center that 

would focus on the detection of tax schemes and other abusive transactions. 

IRS envisioned that the proposed center would promote collaboration across 

IRS, help develop and use a suite of tools for addressing abusive transactions, 

and centralize datasets into a cohesive data-sharing strategy. However, the 

program was not funded in IRS’s fiscal year 2011 budget. To fulfill the 

recommendation, IRS would at least need to create a specific approach on 

managing network compliance efforts across IRS that includes time frames for 

network analysis tool development. 

Action 2 progress 

IRS completed an annual survey of staff using yK-1, a network analysis tool. 

Results from the survey were used to enhance staff knowledge about yK-1. For 

example, IRS added an index to an existing yK-1 users' manual. Agency officials 

also reported adding updated information to training programs for new staff 

using yK-1. As part of the survey process, IRS held feedback sessions between 

programmers and users of the tool. During these discussions, participants 

discussed ways to make the yK-1 tool more effective. Officials representing the 

Large Business and International Division, which is a user of yK-1, said they 

were satisfied with the way the feedback loop operated. 

Overall assessment

◐

Action 1 

The Internal Revenue Service (IRS) 

should create an agencywide strategy 

with goals to coordinate and plan its 

enforcement efforts on network tax 

evasion. The strategy should include 

(1) assessing the effectiveness of 

network analysis tools to ensure that 

resources are being devoted to those 

that provide the largest return on 

investment; (2) determining whether to 

increase access to IRS data or collect 

new data for network analysis; (3) 

developing network analysis tools on a 

specific time schedule; and (4) 

deciding how to manage network 

efforts across IRS. 

Partially addressed ◐

Action 2 

IRS should ensure that its staff 

understand the network tools and 

establish formal ways for users to 

interact with tool programmers and 

analysts to ensure that the network 

tools are easy to use and achieve 

goals. 

Addressed ●

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 89 GAO-12-453SP Follow-up on 2011 Report 

General Government 

65. Opportunities exist to improve the targeting of the $6 

billion research tax credit and reduce forgone revenue 

Action 1 progress 

No legislative action identified. 

The Department of the Treasury issued a report on March 25, 2011, that 

acknowledged problems with the “regular” method for computing the credit. 

Despite those problems, the Department of the Treasury’s report recommended 

making both the regular credit and the ASC permanent so as not to “disrupt” 

taxpayers. 

Overall assessment

○

Action 1 

Congress could eliminate the regular 

credit and add a minimum base 

amount (equal to 50 percent of a 

taxpayer’s current spending) to the 

method for computing the alternative 

simplified credit (ASC). 

Not addressed ○

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 90 GAO-12-453SP Follow-up on 2011 Report 

General Government 

66. Converting the new markets tax credit to a grant 

program may increase program efficiency and 

significantly reduce the $3.8 billion 5-year revenue cost of 

the program 

Action 1 progress 

No legislative action identified. 

Overall assessment

○

Action 1 

Congress should consider offering 

grants in lieu of credits to Community 

Development Entities (CDE) if it 

extends the program again. If it does 

so, Congress should require the 

Department of the Treasury to gather 

appropriate data to assess whether 

and to what extent the grant program 

increases the amount of federal 

subsidy provided to low-income 

community businesses compared to 

the New Markets Tax Credit; how costs 

for administering the program incurred 

by the Community Development 

Financial Institutions Fund, CDEs, and 

investors would change; and whether 

the grant program otherwise affects the 

success of efforts to assist low-income 

communities. One option would be for 

Congress to set aside a portion of 

funds to be used as grants and a 

portion to be used as tax credit 

allocation authority under the current 

structure of the program to facilitate 

comparison of the two program 

structures. 

Not addressed ○

For more information, contact Michael Brostek 

at (202) 512-9110 or brostekm@gao.gov.

See GAO-11-318SP Actions Needed
Page 91 GAO-12-453SP Follow-up on 2011 Report 

General Government 

67. Limiting the tax-exempt status of certain 

governmental bonds could yield revenue 

Action 1 progress 

No legislative action identified. 

Overall assessment

○

Action 1 

Congress should consider whether 

facilities, including hotels and golf 

courses, that are privately used should 

be financed with tax-exempt 

governmental bonds. 

Not addressed ○

For more information, contact Michael Brostek 

at (202) 512-9110 or brostekm@gao.gov.

See GAO-11-318SP Actions Needed
Page 92 GAO-12-453SP Follow-up on 2011 Report 

General Government 

68. Adjusting civil tax penalties for inflation potentially 

could increase revenues by tens of millions of dollars per 

year, not counting any revenues that may result from 

maintaining the penalties’ deterrent effect 

Action 1 progress 

In October 2011, Congress enacted the United States-Korea Free Trade 

Agreement Implementation Act, which included a provision increasing from $100 

to $500 the penalty imposed on paid tax preparers who fail to comply with 

earned income tax credit due diligence requirements.60 

No legislation has been identified that would require periodic inflation 

adjustments for all fixed penalties. 

 

60Pub. L. No. 112-41, § 501(a) (2011).

Overall assessment

◐

Action 1 

Congress may want to consider 

requiring the Internal Revenue Service 

(IRS) to periodically adjust for inflation, 

and round appropriately, the fixeddollar amounts of civil tax penalties to 

account for the decrease in real value 

over time and so that penalties for the 

same infraction are consistent over 

time. 

Partially addressed ◐

For more information, contact Michael Brostek 

or James R. White at (202) 512-9110 or 

brostekm@gao.gov or whitej@gao.gov.

See GAO-11-318SP Actions Needed
Page 93 GAO-12-453SP Follow-up on 2011 Report 

General Government 

69. IRS may be able to systematically identify 

nonresident aliens reporting unallowed tax deductions 

or credits 

Action 1 progress 

Using various data sources, IRS studied ways to systematically identify 

nonresident aliens who may have improperly filed Form 1040 instead of Form 

1040NR. IRS determined that establishing an automated program to identify this 

type of noncompliance is not cost effective at this time. 

 

Overall assessment

●

Action 1 

The Internal Revenue Service (IRS) 

should determine if creating an 

automated program to identify 

nonresident aliens who may have 

improperly filed Form 1040 instead of 

Form 1040NR would be a costeffective means to improve 

compliance. 

Addressed ●

For more information, contact Michael Brostek 

at (202) 512-9110 or brostekm@gao.gov.

See GAO-11-318SP Actions Needed
Page 94 GAO-12-453SP Follow-up on 2011 Report 

General Government 

70. Tracking undisbursed balances in expired grant 

accounts could facilitate the reallocation of scarce 

resources or the return of funding to the Treasury 

Action 1 progress 

OMB issued guidance in 2010 and 2011 only to certain federal departments and 

entities covered by the Commerce, Justice, Science, and Related Agencies 

Appropriations Act. OMB’s guidance directed them to track and report in their 

respective PARs or Agency Financial Reports on undisbursed balances in grant 

accounts. However, its guidance included grant accounts that were still available 

for disbursement and was not limited only to those grant accounts eligible for 

closeout, as described in GAO’s 2008 report. Funds in these accounts should no 

longer be disbursed to grantees because the period of availability to the grantee 

has expired. 

In 2008, GAO recommended that OMB’s guidance be governmentwide, not just 

limited to certain agencies. Because OMB’s guidance included grant accounts 

with funds still available for disbursement, agencies have reported balances in 

active grant accounts, not just those eligible for closeout. Later this year, GAO 

plans to issue a report on the actions OMB and agencies have taken to track 

undisbursed balances in grant accounts that are eligible for closeout. 

Overall assessment

○

Action 1 

The Office of Management and Budget 

(OMB) should instruct all executive 

departments and independent 

agencies to track undisbursed 

balances in expired grant accounts and 

report on the resolution of this funding 

in their annual performance plan and 

Performance and Accountability 

Reports (PAR). 

Not addressed ○

For more information, contact Stanley L. 

Czerwinski at (202) 512-6806 or 

czerwinskis@gao.gov.

See GAO-11-318SP Actions Needed
Page 95 GAO-12-453SP Follow-up on 2011 Report 

Health 

71. Preventing billions in Medicaid improper payments

requires sustained attention and action by CMS 

Action 1 progress 

Between December 2010 and June 2011, CMS took a number of steps to help 

prevent improper payments, including payments for controlled substances. 

Actions included the following: 

 issuing a final rule to help ensure that payments are not made to providers 

and pharmacies debarred or excluded from Medicaid; 

 issuing guidance to states to acquire and use the Drug Enforcement 

Administration Controlled Substance Registration File; and 

 issuing guidance to states to help them prevent making payments to dead 

beneficiaries. 

While GAO assessed this action as addressed, improper payments are a 

continuing concern. This area will require continued diligence by the agency to 

prevent such payments. 

Action 2 progress 

CMS has not yet established a means by which the agency can routinely identify 

states’ contingency-fee projects to maximize federal Medicaid reimbursements. 

CMS officials told GAO that they do not have the authority to require states to 

regularly report this information, and they were unsuccessful in their attempt to 

obtain such authority from Congress in 2005. In 2008, CMS stated that it was 

working to develop a method to regularly determine states use of contingencyfee consultants to guide its oversight efforts, but as of 2011, the agency had not 

done so. In addition, in response to a congressional inquiry CMS surveyed its 

regional offices in 2008 to identify the extent of states’ use of contingency-fee 

consultants for federal revenue maximization projects. CMS officials told GAO in 

July 2011 that no plans exist to conduct another such survey. Without a means 

to routinely identify states’ use of contingency-fee consultants, GAO remains 

concerned about CMS’s oversight of federal revenue maximization projects. 

Overall assessment

◐

Action 1 

The Centers for Medicare & Medicaid 

Services (CMS) should issue guidance 

to states to implement processes that 

better prevent payment of improper 

claims for controlled substances in 

Medicaid. 

Addressed ●

Action 2 

CMS should improve its oversight of 

projects developed by consultants on a 

contingency-fee basis, in part, by 

routinely requesting information on 

these projects and associated claims. 

Not addressed ○

For more information, contact Katherine Iritani

at (202) 512-7114 or iritanik@gao.gov.

See GAO-11-318SP Actions Needed
Page 96 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

No executive action taken. In 2011, CMS officials stated that they have not 

established the recommended standard guidance, that legislation would be 

needed to give CMS the authority to require facility specific reporting, and that 

they have not developed a strategy to ensure that all existing supplemental 

payment arrangements have been reviewed. 

- 

Overall assessment

○

Action 1 

The Centers for Medicare & Medicaid 

Services (CMS) should 

- establish uniform guidance for 

states that set acceptable methods 

for calculating nonDisproportionate Share Hospital 

payment amounts, 

- require facility specific reporting of 

non-Disproportionate Share 

Hospital supplemental payments, 

and 

- develop a strategy to ensure that 

all state supplemental payment 

arrangements have been reviewed 

by CMS. 

Not addressed ○

For more information, contact Katherine Iritani 

at (202) 512-7114 or iritanik@gao.gov.

See GAO-11-318SP Actions Needed

Health 

72. Federal oversight over Medicaid supplemental 

payments needs improvement, which could lead to 

substantial cost savings 
Page 97 GAO-12-453SP Follow-up on 2011 Report 

Health 

73. Better targeting of Medicare’s claims review could 

reduce improper payments 

Action 1 progress 

CMS took action to improve Medicare payment accuracy by introducing predictive 

analytics to help identify patterns of potentially improper claims, but has not begun to 

use predictive analytics or other methods to implement this specific recommendation. 

The Small Business Jobs Act of 2010 requires CMS to use predictive modeling and 

other analytic techniques—known as predictive analytic technologies—to identify 

improper claims and to prevent improper payments under the Medicare fee-for-service 

program.61 CMS officials told GAO that the agency issued a contract to implement 

predictive modeling, and its contractors began analyzing claims before payment to 

identify potential fraud in June 2011. The predictive modeling system assigns risk 

scores to groups of claims. CMS’s contractors have begun to investigate whether the 

highest risk-scored groups of claims are fraudulent, but it is too early to determine the 

full impact that this may have on reducing improper payments. However, CMS has not 

begun to use predictive analytics or other methods to implement this specific 

recommendation, which is to have automated prepayment controls based on 

particular thresholds related to unexplained increases in billing and has not indicated 

that it plans to do so.

Action 2 progress 

CMS has indicated that its contractors conduct postpayment medical reviews for 

agencies with high rates of home health services billing, as their resources 

permit. However, CMS has not reported any specific efforts to routinely conduct 

postpayment reviews on home health agencies with high rates of improper 

billing identified through prepayment review. 

Action 3 progress 

CMS has indicated that this recommendation could be costly and difficult to 

implement and has not reported any efforts to implement it. However, CMS has 

not provided any information about cost or feasibility, or tried to implement this 

recommendation as a demonstration in high-fraud areas to determine its costeffectiveness as a strategy. 

Action 4 progress 

Because funding for medical review by the claims administration contractors is 

limited, starting in April 2011, CMS required each claims administration 

contractor to develop plans on how they would collaborate with the RACs on 

medical reviews. CMS required each claims administration contractor’s plan to 

cover the types of claims best reviewed by the claims administration contractor 

versus the RAC, issues that the RACs could potentially review or known 

improper payment vulnerabilities that the RAC could help address, and providers 

that could be referred to the RACs for review. CMS also required and has 

received regular reporting on the results of this collaboration. The claims 

administration contractors are now reporting to CMS when they have referred to 

the RACs, or plan to refer as appropriate, specific issues or providers of certain 

services whose claims warrant further review to identify improper payments. 

 

61Pub. L. No. 111-240 (2010).

Overall assessment

◐

Action 1 

The Centers for Medicare & Medicaid 

Services (CMS) should require its 

contractors to develop thresholds for 

unexplained increases in billing and 

use them to develop automated 

prepayment controls. 

Partially addressed ◐

Action 2 

CMS should conduct postpayment 

reviews on claims submitted by home 

health agencies with high rates of 

improper billing identified through 

prepayment review. 

Not addressed ○

Action 3 

CMS should require that physicians 

receive a statement of home health 

services that beneficiaries received 

based on the physicians’ certification. 

Not addressed ○

Action 4 

CMS should direct contractors to focus 

on services where recovery audit 

contractors (RACs) are not expected to 

focus their reviews, and where 

improper payments are known to be 

high, specifically home health services. 

Such direction could make other 

contractors’ postpayment review 

activities more valuable. 

Addressed ●

For more information, contact Kathleen King at 

(202) 512-7114 or kingk@gao.gov.

See GAO-11-318SP Actions Needed
Page 98 GAO-12-453SP Follow-up on 2011 Report 

Health 

74. Potential savings in Medicare’s payment for health 

care 

Action 1 progress 

CMS continues its phased implementation of the Medicare Physician Feedback 

Program, which it developed to, among other things, identify physicians with 

inefficient practice patterns and help those physicians reduce their service costs. 

CMS established the program in 2008 and is distributing feedback reports to an 

increasing number of physicians. These reports can help control costs in several 

ways, such as providing information to physicians on how their resource use 

compares to their peers’ and helping them develop strategies for reducing costs 

in their practices. In September 2011, CMS provided reports to 35 physician 

groups and plans to provide reports to over 20,000 individual physicians in early 

2012 and to over 100,000 physicians later in 2012. CMS plans to do further 

testing of the reports with the goal of providing feedback reports to all applicable 

physicians by 2017. However, in previous testing of the reports, CMS found that 

physicians did not generally access those reports.

Action 2 progress 

CMS has not sought such legislative changes, but it is planning to publicly report 

measures of physician quality and patient experience on its Web site beginning 

January 1, 2013. The law62 provides for confidential reporting of measures of 

resource use to physicians. Consequently, these measures, which are used in 

combination with quality measures to determine efficiency, will not be publicly 

reported. 

Action 3 progress 

CMS has not implemented safeguards such as prior authorization. 

However, CMS has taken steps to discourage excess utilization by expanding its 

use of the multiple procedure payment reduction for imaging services when a 

physician furnishes two or more services to a patient in the same session on the 

same day. It had previously applied the multiple procedure payment reduction 

to the technical component of certain imaging services. In 2012, CMS also 

applied the reduction to the professional component of the same services. 

Action 4 progress 

Congress did not restructure home oxygen payment rates. However, under 

existing provisions of law, competitive bidding for home oxygen was extended to 

91 additional geographic areas. The rates from competitive bidding will likely be 

lower than rates currently paid by Medicare in those areas. Competitive bidding 

is currently underway and the resulting contracts and payment rates are 

scheduled to take effpect July 1, 2013. 

 

62Pub. L. No. 111-148 (2010); Pub. L. No. 110-275 (2008).

Overall assessment

◐

Action 1 

The Centers for Medicare & Medicaid 

Services (CMS) should develop a 

profiling system to identify individual 

physicians with inefficient practice 

patterns and use the results to improve 

the efficiency of care financed by 

Medicare. 

Partially addressed ◐

Action 2 

CMS would likely have to seek 

legislative changes to maximize the 

usefulness of a physician profiling 

system—for example, changes that 

would allow CMS to incentivize 

beneficiaries to select efficient 

providers. 

Not addressed ○ 

Action 3 

CMS should examine the feasibility of 

addressing rapid growth in Medicare 

spending on imaging services by 

expanding payment safeguard 

mechanisms such as prior 

authorization for imaging services. 

Not addressed ○ 

Action 4 

Congress could consider reducing 

Medicare home oxygen payment rates 

to align them more closely with the 

costs of supplying home oxygen. 

Not addressed ○ 
Page 99 GAO-12-453SP Follow-up on 2011 Report 

Health 

74. Medicare’s payment for health care (continued) 

Action 5 progress 

In its 2012 Final Rule with Comment covering Payment Policies Under the 

Physician Fee Schedule and Other Revisions to Part B for CY 2012, CMS 

reported its analysis of advanced imaging services. For 2012, CMS is adopting 

an MPPR that applies a 25 percent reduction to the professional (physician’s 

work) component of certain advanced imaging services furnished together. 

However, a budget neutrality provision applies. Therefore, these “savings” are 

redistributed to increase payments for other services and do not accrue to the 

Medicare program. The budget neutrality provision is law; therefore, Congress 

would have to remove that provision as it applies to the MPPR as it has done in 

certain specified cases so that savings accrue to the program. 

Action 6 progress 

CMS has not taken executive action to expand the scope of the MPPR to 

nonsurgical and nonimaging services. However, in its 2012 physician fee 

schedule proposed rule, CMS asked for comment on two proposals for 

expanding the MPPR in the future: applying the MPPR to the technical portion of 

the payment for all imaging procedures; and applying the MPPR to the physician 

work portion of the payment for all imaging services as well as applying it to the 

technical portion of the payment to all diagnostic tests, such as cardiology and 

audiology. CMS may propose changes in future rulemaking. 

Action 7 progress 

Congress has exempted certain imaging services from the budget neutrality 

provision. However, other imaging services remain subject to budget neutrality; 

“savings” from these services are redistributed to other services and do not 

accrue to the Medicare program. 

Action 5 

CMS should address the issue of 

paying for overlapping services that 

are furnished together by 

systematically reviewing such services 

and implementing a multiple procedure 

payment reduction (MPPR) to capture 

efficiencies, where appropriate, by 

reducing payments to reflect the 

efficiencies. CMS should focus on 

those services that have the greatest 

impact on Medicare spending. 

Partially addressed ◐

Action 6 

CMS should expand the scope of its 

MPPR for services furnished together 

by applying it to nonsurgical and 

nonimaging services and applying the 

MPPR to the part of the payment that 

covers a physician’s work. 

Not addressed ○

Action 7 

Congress could exempt from the 

budget neutrality requirement savings 

attributable to policies that reflect 

efficiencies occurring when services 

are furnished together. 

Partially addressed ◐

For more information, contact James 

Cosgrove at (202) 512-7029 or 

cosgrovej@gao.gov. 

See GAO-11-318SP Actions Needed 
Page 100 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

75. DHS’s management of acquisitions could be 

strengthened to reduce cost overruns and schedule and 

performance shortfalls

Action 1 progress 

DHS has developed plans to address management of acquisitions, including 

ensuring that requirements and cost estimates are well defined, and has begun 

to take actions to implement those plans. Specifically, to strengthen its overall 

acquisition management efforts, DHS reported that it planned to implement an 

integrated investment life cycle model (IILCM) to establish a decision-making 

process for investments’ life cycles and that, as of December 2011, the 

department had chosen three portfolios to pilot this process. Further, in 

December 2011, DHS reported that it plans to examine lessons learned from the 

pilot and develop, among other things, an IILCM schedule and risk management 

plan, while conducting executive steering committee meetings over the next 6 

months with a goal of beginning IILCM operations in the fourth quarter of 2012. 

As part of this model and its other planned acquisition management reforms, 

DHS reported that it increased its staff during fiscal year 2011 for developing 

and validating life cycle cost estimates and began to develop independent cost 

estimates to strengthen the accuracy and credibility of program costs. To date, 

DHS has completed 4 validated cost estimates and is currently working to 

complete others. In December 2011, DHS reported that it developed a cost 

estimating Center of Excellence to assist components in developing reliable cost 

estimates and has set goals to complete baseline cost estimates for every major 

program and validate life-cycle cost estimates for 75 percent, or 34, of the Level 

1 programs.63 DHS also reported that the percentage of major programs with a 

validated cost estimate will be a key measure of its progress toward achieving 

these goals. 

DHS also plans to establish various oversight structures and processes, such as 

a capabilities and requirements council to validate investment strategies and 

approve analyses of alternatives and operational requirements documents up 

front. DHS reported in June 2011 that the department planned to form the 

capabilities and requirements council early in the fourth quarter of 2011. 

However, as of December 2011, the council has not yet met. 

These actions are positive steps that should help strengthen DHS’s acquisition 

management processes to improve the department’s ability to deliver major 

acquisition programs that meet critical mission needs on time and within budget. 

However, as GAO reported in July 2011, DHS is in the early stages of 

implementing these actions, thus it is too soon to assess their impact on 

reducing acquisition cost overruns and schedule and performance shortfalls at 

this time.64

 

63Major programs consist of Level 1 and Level 2 acquisitions. Level 1 acquisitions have 

life-cycle costs of $1 billion dollars or more. Level 2 acquisitions have life-cycle costs of 

$300 million or more, but less than $1 billion. In 2011, DHS identified 82 major acquisition 

programs, 45 of which were Level 1. 

64GAO, Homeland Security: DHS Could Strengthen Acquisitions and Development of 

New Technologies, GAO-11-829T, (Washington, D.C.; July 15, 2011). 

Overall assessment

◐

Action 1 

The Department of Homeland Security 

(DHS) should ensure that requirements 

and cost estimates are well defined up 

front. 

Partially addressed ◐
Page 101 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

75. DHS’s management of acquisitions (continued) 

Action 2 progress 

As part of its IILCM, DHS is developing a decision support tool to track 

programs’ cost, schedule, and performance indicators. DHS reported in 

December 2011 that it planned to develop training and a communications plan 

for institutionalizing the decision support tool and fully implement the tool by the 

fourth quarter of 2012. According to DHS, this tool is intended to monitor 

acquisition activities for all of its programs. 

Action 3 progress 

Among other things, DHS reported in December 2011, that it plans to have its 

Investment Review Board, once established, meet regularly to approve major 

program initiation decisions and assign programs to appropriate executive 

steering committees, which are to provide better governance to the department’s 

highest-risk programs. DHS also reported in December 2011 that it plans to 

establish a program review board to allocate funds to prioritized programs and 

set implementation goals and timelines. 

DHS reported in June 2011 that it conducted a survey of its major acquisition 

programs and acquisition oversight offices to identify gaps in its acquisition 

workforce. In addition, DHS reported in June 2011 that its first cohort of 10 

contracting professionals graduated in February 2011 from a 3-year 

development program it established to recruit individuals into acquisition career 

fields, such as program management and cost estimating. In December 2011, 

DHS reported that 14 additional staff graduated from this program. Further, as of 

December 2011, DHS reported that it is developing a procurement staffing 

model and has completed 90 percent of the model. DHS plans to complete the 

model by the end of the second quarter of fiscal year 2012. 

Action 2 

DHS should establish and measure 

performance against departmentapproved baselines and indicators for 

major acquisition programs. 

Partially addressed ◐

Action 3 

DHS should ensure that its investment 

decisions are transparent and 

documented; budget decisions are 

informed by the results of acquisition 

reviews, including acquisition 

information and cost estimates; 

sufficient management resources are 

identified and aligned, such as 

acquisition staff, to implement 

oversight reviews in a timely manner; 

and acquisition program requirements 

are reviewed and validated. 

Partially addressed ◐

For more information, contact David C. Maurer 

at (202) 512-9627 or maurerd@gao.gov.

See GAO-11-318SP Actions Needed
Page 102 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

76. Improvements in managing research and 

development could help reduce inefficiencies and costs 

for homeland security

Action 1 progress 

In June and December 2011, DHS reported that it planned to establish a new 

model for managing departmentwide investments across their life cycles and 

that the Science and Technology Directorate (S&T) has become an integral part 

of DHS’s acquisition review process. In July 2011, GAO reported that under this 

plan, S&T was to be involved in each phase of the investment life cycle and 

participate in new councils and boards that DHS was planning to create to help 

ensure that test and evaluation methods are appropriately considered as part of 

DHS’s overall R&D investment strategies.65 GAO further reported that the new 

councils and boards DHS was planning to establish were to be responsible for 

overseeing key acquisition decisions for major programs, including ensuring that 

testing and evaluation (T&E) is completed. DHS plans to complete the design, 

testing, and roll out this new approach, including the establishment of new 

councils and boards, by the end of fiscal year 2012 and has taken steps to do 

so. For example, since its June 2011 update, DHS established a new Executive 

Steering Council to test this new approach for enhancing oversight. 

In June 2011, GAO reported that S&T was meeting some of its T&E oversight 

requirements, but additional steps were needed to ensure that all requirements 

were met.66 GAO also reported that S&T’s T&E Council was working with 

component program managers to strengthen R&D and T&E processes, such as 

developing program requirements and ensuring the appropriate T&E is complete 

before implementation. In addition, GAO reported in November 2011 that S&T 

recently reorganized and established an office to provide operations analysis, 

systems engineering, test and evaluation, and standards development support 

to DHS component program offices.67

While DHS has made some progress in these areas, it will be important for the 

agency to follow through on the establishment of these new processes and 

councils. 

 

65GAO, Homeland Security: DHS Could Strengthen Acquisitions and Development of 

New Technologies, GAO-11-829T (Washington, D.C.: July 15, 2011). 66GAO, DHS Science and Technology: Additional Steps Needed to Ensure Test and 

Evaluation Requirements Are Met, GAO-11-596 (Washington, D.C.: June 15, 2011). 67GAO, DHS Research and Development: Science and Technology Directorate’s Test 

and Evaluation and Reorganization Efforts, GAO-12-239T (Washington, D.C.: Nov. 17, 

2011). 

Overall assessment

◐

Action 1 

The Department of Homeland Security 

(DHS) could take further actions to 

improve its management of research 

and development (R&D) efforts and 

reduce costs in procuring and 

deploying programs that have not been 

fully tested, including rigorously testing 

devices using actual agency 

operational tactics before making 

decisions on acquisitions. 

Partially addressed ◐
Page 103 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

76. Managing research and development (continued) 

Action 2 progress 

DHS reported in December 2011 that it is working with its components to 

improve the quality and accuracy of cost estimates and has increased its staff 

during fiscal year 2011 to develop independent cost estimates, a GAO best 

practice, to ensure the accuracy and credibility of program costs. However, in 

June 2011, DHS also reported that it was unable to hire the staff needed to fully 

implement its plans due to lack of resources. GAO reported in June 2011 that 

such cost estimates are important first steps for agencies in allowing them to 

conduct cost-benefit analyses and analyses of alternatives.68 To date, DHS has 

completed 4 validated cost estimates out of 135 major programs over the last 

year and is currently working to complete others. In December 2011, DHS 

reported that it developed a cost estimating Center of Excellence to assist 

components in developing reliable cost estimates and has set a goal to complete 

cost estimates for all major programs. DHS also reported that the percentage of 

major programs with a validated cost estimate will now be a key goal. 

DHS also plans to establish various structures and processes to oversee 

program research, development, and testing, including the Capabilities and 

Requirements Council, which is to validate investment strategies and approve 

program analyses of alternatives and operational requirements documents up 

front. DHS reported in June 2011 that the department planned to form the 

Capabilities and Requirements Council early in the fourth quarter of 2011; 

however, as of December 2011 the council has not yet met. In addition, GAO 

reported in June and November 2011 that S&T reviewed and approved key T&E 

documents and plans for major investments as required by DHS’s T&E directive, 

such as documents outlining a program requirements and capabilities.69 

However, GAO reported that S&T could better document its review of 

component acquisition documents and recommended that they develop a 

mechanism to do so. 

While DHS has made some progress in the areas of assessing costs and 

program alternatives and benefits, it will be important for the agency to follow 

through on its new processes and councils. 

 

68GAO, DOD Weapon Systems: Missed Trade-off Opportunities During Requirements 

Reviews, GAO-11-502 (Washington, D.C.: June 16, 2011). 69GAO-11-596 and GAO-12-239T.

Action 2 

DHS should conduct cost-benefit 

analyses as part of research, 

development, and testing efforts, which 

would help DHS and congressional 

decision makers better assess and 

prioritize investment decisions, 

including assessing possible program 

alternatives that could be more costeffective. 

Partially addressed ◐

For more information, contact David C. Maurer 

at (202) 512-9627 or maurerd@gao.gov.

See GAO-11-318SP Actions Needed
Page 104 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

77. Validation of TSA’s behavior-based screening 

program is needed to justify funding or expansion 

Action 1 progress 

In April 2011, DHS completed an initial validation study. However, this study’s 

methodology was not sufficiently comprehensive to validate the program and 

determine the extent to which behavior-based screening can be used for 

counterterrorism purposes in the aviation environment. Instead, the study was 

designed to determine the extent to which SPOT was more effective than 

random screening at identifying security threats and how the program’s 

behaviors correlate to identifying high-risk travelers. DHS’s study made 

recommendations related to the need for further validation efforts, comparing 

SPOT with other screening programs, and broader program evaluation issues, 

some of which echoed previous GAO recommendations. These 

recommendations are intended to help the program conduct a more 

comprehensive validation of whether the science can be used for 

counterterrorism purposes in the aviation environment. Given the broad scope of 

the additional work and related resources identified by DHS for addressing the 

recommendations, it could take several years to complete. According to TSA, 

the program is undertaking actions to address some of DHS’s 

recommendations, such as conducting additional analysis of the program’s 

behaviors and associated SPOT scoring system in coordination with DHS’s 

Science and Technology Directorate. According to TSA, a refined list of the 

behaviors and appearances used in the SPOT program to identify high-risk 

passengers will be completed by mid-2012. TSA is taking actions to refine the 

program, but questions related to the program’s validity will remain until TSA 

demonstrates that using behavior detection techniques can help secure the 

aviation system against terrorist threats. 

Action 2 progress 

TSA completed an annual training analysis to identify gaps in its training 

curricula related to SPOT and as a result, was developing a training plan as of 

November 2011. According to TSA, this plan will identify new training courses, 

additional recurrent training, and required updates to the current training 

curricula. TSA expects to complete this plan by early 2012 and revise it annually. 

TSA has begun to provide refresher training to all SPOT airports and plans to 

complete this effort by the end of 2012. 

Action 3 progress 

Program funds were frozen at fiscal year 2010 levels for fiscal year 2011. The 

conference report accompanying the consolidated appropriations act for fiscal 

year 2012 stated that funding was included for 145 additional behavior detection 

officers.70 This increase is less than half of TSA’s fiscal year 2012 request for 

350 full-time behavior detection officers. The conference report also directed 

TSA to brief congressional committees no later than 90 days after the enactment 

of the act on its plans and actions to implement recommendations from the DHS 

validation study and GAO’s May 2010 report.71

 

70H.R. Rep. No. 112-331, at 971 (2011) (Conf. Rep.). 71See GAO, Aviation Security: Efforts to Validate TSA’s Passenger Screening Behavior 

Detection Program Underway, but Opportunities Exist to Strengthen Validation and 

Address Operational Challenges, GAO-10-763 (Washington, D.C.: May 20, 2010).

Overall assessment

◐

Action 1 

The Department of Homeland Security 

(DHS) should use an independent 

panel of experts to assess the 

methodology of its initial validation 

study of the Transportation Security 

Administration’s (TSA) behavior 

detection program to provide DHS with 

additional assurance regarding 

whether the study’s methodology is 

sufficiently comprehensive to validate 

the Screening of Passengers by 

Observation Techniques (SPOT) 

program. 

Partially addressed ◐

Action 2 

DHS could conduct additional research 

to provide additional information on the 

extent to which SPOT can be 

effectively implemented in airports and 

to help determine the need for periodic 

refresher training. 

Partially addressed ◐

Action 3 

Congress may wish to consider limiting 

program funding pending receipt of an 

independent assessment of TSA’s 

SPOT program. Specifically, Congress 

could consider freezing appropriation 

levels for the SPOT program at the 

2010 level until the validation effort is 

completed. 

Addressed ●
Page 105 GAO-12-453SP Follow-up on 2011 Report 

Homeland Security / Law Enforcement 

77. TSA’s behavior-based screening program 

(continued)

Action 4 progress 

In July 2011, GAO reported to Congress on the initial validation study’s results.72

As noted above, fiscal year 2011 SPOT program funds were frozen at fiscal year 

2010 levels. According to TSA officials, as of January 2012, TSA continues to 

conduct research, develop additional training, assess additional concepts of 

operation for the program, and develop outcome-based performance measures. 

However, given the broad scope of the additional work remaining to validate the 

science for using behavior detection techniques for counterterrorism purposes in 

an airport environment, additional information on these efforts could help 

Congress make future funding decisions regarding the SPOT program. 

 

72See GAO, Aviation Security: TSA Has Taken Actions to Improve Security, but 

Additional Efforts Remain, GAO-11-807T (Washington, D.C.: July 13, 2011).

Action 4 

Upon completion of the validation 

effort, Congress may also wish to 

consider the study’s results—including 

the program’s effectiveness in using 

behavior-based screening techniques 

to detect terrorists in the aviation 

environment—in making future funding 

decisions regarding the program. 

Partially addressed ◐

For more information, contact Stephen M. 

Lord at (202) 512-4379 or lords@gao.gov.

See GAO-11-318SP Actions Needed
Page 106 GAO-12-453SP Follow-up on 2011 Report 

Action 1 progress 

In 2011, GAO reported that TSA could achieve up to $470 million in net savings 

based on reduced TSA staffing costs through the replacement or modification of 

existing checked baggage screening systems with more efficient solutions over 

the next 5 years. TSA agreed that the deployment of more efficient systems 

offers potential personnel cost savings to the federal government. 

Since the issuance of GAO’s 2011 report, TSA has replaced 60 stand-alone 

checked baggage screening machines with more efficient in-line screening 

systems. The Full-Year Continuing Appropriations Act, 2011, required the 

Secretary of Homeland Security to submit a detailed report to the Committees 

on Appropriations of the Senate and House of Representatives on, among other 

things, labor savings it achieves from the deployment of improved technologies 

for passengers and checked baggage screening and how those savings are 

being used to offset security costs or reinvested to address security 

vulnerabilities by August 15, 2011.73 In January 2012, TSA stated that this report 

is currently under internal review and could not provide a date by which it 

expects to submit the labor savings to the committees. 

However, as of August 2011, TSA anticipates that over the next 5 years it will 

support fewer projects to install more efficient systems than in the past due to 

TSA’s shift in strategic focus from completion of optimal airport systems to 

replacement and upgrade of the aging explosive detection system fleet. As a 

result, the assumptions that GAO used to calculate projected potential savings 

of $470 million are now outdated. Under its new plan, however, TSA continues 

to deploy in-line baggage screening systems to airports with facilities capable of 

accommodating them, and will support projects to facilitate the installation of inline systems if TSA determines that such systems are an optimal and costeffective solution for a particular airport. Because TSA has changed its plan to 

focus on replacement of the aging fleet, it is unclear when the agency will be 

capable of completing the installation of more efficient solutions, including in-line 

screening systems, at all airports where such solutions are warranted. While 

TSA’s plans to replace and upgrade its aging explosive detection system fleet 

are understandable, we believe that TSA should continue to pursue the 

installation of more efficient screening solutions to the extent possible. 

 

73Pub. L. No. 112-10, Div. B, § 1616 (2011).

Overall assessment

◐

Action 1 

The Transportation Security 

Administration (TSA) might achieve 

savings in screening personnel costs 

by continuing to replace or modify 

older checked baggage screening 

systems with more efficient solutions, 

including in-line screening systems. 

Partially addressed ◐

For more information, contact Stephen M. 

Lord at (202) 512-4379 or lords@gao.gov.

See GAO-11-318SP Actions Needed

Homeland Security / Law Enforcement 

78. More efficient baggage screening systems could 

result in about $470 million in reduced TSA personnel costs 

over the next 5 years 
Page 107 GAO-12-453SP Follow-up on 2011 Report 

General Government 

79. Clarifying availability of certain customs fee 

collections could produce a one-time savings of $640 

million 

Action 1 progress 

The House Report accompanying the 2012 Department of Homeland Security 

Appropriations bill74 directed the Office of the Chief Financial Officer and CBP to 

report on the appropriate application of these funds no later than 30 days after 

the date of enactment of the 2012 Appropriations Act (i.e., January 23, 2012.) 

On January 27, 2012, officials from the Department of Homeland Security stated 

that the department is working with CBP and the Appropriations Committees to 

schedule a briefing on this issue.

 

74H.R. Rep. No. 112-91, at 27 (2011).

Overall assessment

◐

Action 1 

Congress could clarify the purposes for 

which the $639.4 million in unobligated 

balances are available. The 

unobligated balances have remained in 

U.S. Customs and Border Protection’s 

(CBP) Customs User Fee Account for 

more than 10 years. 

Partially addressed ◐

For more information, contact Susan Irving at 

(202) 512-6806 or irvings@gao.gov.

See GAO-11-318SP Actions Needed
Page 108 GAO-12-453SP Follow-up on 2011 Report 

Income Security 

80. Social Security needs data on pensions from 

noncovered earnings to better enforce offsets and ensure 

benefit fairness, estimated to result in $2.4-$2.9 billion 

savings over 10 years 

Action 1 progress 

No legislative action identified. 

Overall assessment

○

Action 1 

Congress could consider giving the 

Internal Revenue Service (IRS) the 

authority to collect the information that 

the Social Security Administration 

needs on government pension income 

to administer the Government Pension 

Offset and the Windfall Elimination 

Provision accurately and fairly. 

Not addressed ○

For more information, contact Charles A. 

Jeszeck at (202) 512-7036 or 

jeszeckC@gao.gov. 

See GAO-11-318SP Actions Needed 
Page 109 GAO-12-453SP Follow-up on 2011 Report 

International Affairs 

81. Congress could pursue several options to improve 

collection of antidumping and countervailing duties 

Action 1 progress 

No legislative action identified. 

 

Action 2 progress 

No legislative action identified. 

 

 

Overall assessment

○

Action 1 

Congress could eliminate the 

retrospective component of the U.S. 

antidumping and countervailing duty 

system and, instead, treat the 

antidumping and countervailing duties 

assessed at the time the product 

enters the country as final. 

Not addressed ○

Action 2 

Congress could choose to provide the 

Department of Commerce the 

discretion to require companies 

applying for a new shipper review to 

have a greater volume of imports 

before establishing an individual 

antidumping and countervailing duty 

rate. 

Not addressed ○

For more information, contact Alfredo Gomez 

at (202) 512-4101 or gomezj@gao.gov

See GAO-11-318SP Actions Needed
 

Page 110 GAO-12-453SP Follow-up on 2011 Report 

In March 2011, GAO issued its first annual report to the Congress on 

potential duplication, overlap, and fragmentation in the federal 

government.1

 The report also identified opportunities to achieve cost 

savings and enhance revenues. We identified 81 areas—which span a 

wide range of government missions2

—with a total of 176 actions3 that the 

Congress and the executive branch could take to reduce or eliminate 

unnecessary duplication, overlap, and fragmentation or achieve other 

potential financial benefits. We also presented areas where programs 

may be able to achieve greater efficiencies or become more effective in 

providing government services. In many areas, we suggested actions—

identifying some new options, as well as underscoring numerous existing 

GAO recommendations—that policymakers could consider. 

To examine the extent to which the legislative and executive branches 

have made progress in implementing actions in the 81 areas, we 

reviewed relevant legislation and documents such as budgets, policies, 

strategic and implementation plans, guidance, and other information 

related to the 176 actions included in our report. We also analyzed, to the 

extent possible, whether or not financial or other benefits have been 

attained, and included this information as appropriate. In addition, we 

discussed the implementation status of the areas with officials at the 

relevant agencies. 

To assess the progress of the legislative and executive branches in 

implementing the 176 actions, we developed and used the following 

scales: 

 

1

GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save Tax 

Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011). This 

report was issued in response to a new statutory requirement that GAO identify federal 

programs, agencies, offices, and initiatives, either within departments or governmentwide, 

which have duplicative goals or activities. Congress asked GAO to conduct this work and 

to report annually on our findings. See Pub. L. No. 111-139, §21, 124 Stat. 29 (2010), 31 

U.S.C. § 712 Note. 

2

Agriculture, defense, economic development, energy, general government, health, 

homeland security, international affairs, and social services were among the government 

missions included in the March 2011 report. 

3

These actions were identified in the “Actions Needed” section for each respective issue 

area. 

Enclosure III: Scope and Methodology 
 

Page 111 GAO-12-453SP Follow-up on 2011 Report 

For legislative branch actions 

 “addressed,” means relevant legislation was enacted and addresses 

all aspects of the action needed;4

 “partially addressed,” means a relevant bill has passed a committee, 

the House or Senate, or relevant legislation has been enacted, but 

only addressed part of the action needed; and 

 “not addressed,” means a bill may have been introduced, but did not 

pass out of a committee, or no relevant legislation has been 

introduced. 

For executive branch actions 

 “addressed,” means implementation of the action needed has been 

completed; 

 “partially addressed,” means the action needed is in development, 

started but not yet completed; 

 “not addressed,” means the administration and/or agencies have 

made minimal or no progress toward implementing the action needed. 

Using the legislation and documentation collected from agencies, GAO 

analysts and specialists working on defense, domestic, and international 

areas assessed progress for each of the 176 actions within their areas of 

expertise. A core group of GAO staff examined all 176 assessments to 

ensure consistent and systematic application of the criteria, and made 

adjustments as appropriate. 

After GAO analysts completed their assessments of the 176 actions, we 

made an overall assessment for each of the 81 areas using the following 

scale: 

 “addressed” if all actions needed in that area were addressed; 

 “partially addressed” if at least one action needed in that area showed 

some progress toward implementation, but not all actions were 

addressed; and 

 “not addressed” if none of the actions needed in that area were 

addressed. 

 

4

In situations where our action needed suggested that Congress should let a provision 

expire, we classified it as “addressed” if Congress permitted such expiration to happen. 
 

Page 112 GAO-12-453SP Follow-up on 2011 Report 

Finally, GAO provided the draft to the agencies involved and the Office of 

Management and Budget for their comments and incorporated comments 

as appropriate. 

To prepare this report, we conducted our work from July 2011 through 

February 2012 in accordance with all sections of GAO’s Quality 

Assurance Framework that are relevant to our objectives. The framework 

requires that we plan and perform the engagement to meet our stated 

objectives and to discuss any limitations in our work. We believe that the 

information and data obtained, and the analysis conducted, provide a 

reasonable basis for any findings and conclusions in this product. The 

information in this report is current as of February 10, 2012 and does not 

reflect any actions that might have been taken after that date. 
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (www.gao.gov). Each weekday afternoon, 

GAO posts on its website newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.” 

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information. 

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact: 

Website: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Katherine Siggerud, Managing Director, siggerudk@gao.gov, 

(202) 512-4400, U.S. Government Accountability Office, 441 G Street 

NW, Room 7125, Washington, DC 20548 

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Phone 

Connect with GAO 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

Please Print on Recycled Paper.