2012 Annual Report: 

Opportunities to 

Reduce Duplication, 

Overlap and 

Fragmentation, 

Achieve Savings, and 

Enhance Revenue

Report to Congressional Addressees

February 2012

GAO-12-342SP

United States Government Accountability Office

GAO
Page 1 GAO-12-342SP 2012 Annual Report

United States Government Accountability Office

Washington, DC 20548

February 28, 2012

Congressional Addressees

This is GAO’s second annual report to Congress in response to the 

statutory requirement that GAO identify and report annually on federal 

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

governmentwide, which have duplicative goals or activities.1 This body of 

work can help to inform government policymakers as they address the 

fiscal pressures facing our national government. The first report in this 

series, issued in March 2011,2

This report for 2012 presents 51 areas where programs may be able to 

achieve greater efficiencies or become more effective in providing 

government services. Like our March 2011 publication, this report 

identifies government duplication, overlap, and fragmentation as well as 

other cost savings and revenue enhancement opportunities. Its findings 

involve a wide range of government missions and touch virtually all major 

federal departments and agencies.

presented 81 opportunities to reduce 

potential government duplication, achieve cost savings, or enhance 

revenue.

Federal agencies and Congress have taken or planned a number of 

actions that respond to issues we raised in our March 2011 report. 

Consistent with the commitment expressed in that report, we have 

continued to monitor developments in the 81 areas we identified. In a 

companion publication, Follow-up on 2011 Report: Status of Actions 

Taken to Reduce Duplication, Overlap, and Fragmentation, Save Tax 

Dollars, and Enhance Revenue,

3

 

1

Pub. L. No. 111-139, § 21, 124 Stat. 29 (2010), 31 U.S.C. § 712 Note.

which we are releasing concurrently 

with this report, we describe the extent to which progress has been made 

to address the actions we identified a year ago. In summary, GAO’s 

specific assessment of progress as of February 10, 2012, showed that 4 

2

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

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

3

GAO, Follow-up on 2011 Report: Status of Actions Taken to Reduce Duplication, 

Overlap, and Fragmentation, Save Tax Dollars, and Enhance Revenue, GAO-12-453SP

(Washington, D.C.: Feb. 28, 2012).

 
 

Page 2 GAO-12-342SP 2012 Annual Report

(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.4 In addition, the Office of Management and Budget (OMB) 

instructed agencies to consider areas of duplication or overlap identified 

by GAO and others in their fiscal year 2013 budget submissions and 

management plans.

This report is divided into two sections. Section I presents 32 areas in 

which we found evidence of duplication, overlap, or fragmentation among 

federal government programs. Section II of this report summarizes 19 

additional opportunities for agencies or Congress to consider taking 

action that could either reduce the cost of government operations or 

enhance revenue collections for the Treasury.

To find areas where duplication might exist, GAO’s work begins, in many 

cases, by identifying fragmentation—that is, those circumstances in which 

more than one federal agency (or more than one organization within an 

agency) is involved in the same broad area of national interest. In some 

instances of fragmentation, we find overlap—that is, programs that have 

similar goals, devise similar strategies and activities to achieve those 

goals, or target similar users. Duplication occurs when two or more 

agencies or programs are engaged in the same activities or provide the 

same services to the same beneficiaries. In many cases, the existence of 

unnecessary duplication, overlap, or fragmentation can be difficult to 

estimate with precision due to a lack of data on programs and activities.

Where information has not been available that would provide conclusive 

evidence of duplication, overlap, or fragmentation, we often refer to 

“potential duplication,” and where appropriate we suggest actions that 

agencies or Congress could take to either reduce that potential or to 

improve the accuracy and accessibility of information about program 

operations, performance, and results. In some instances of duplication, 

overlap, or fragmentation, it may be appropriate for multiple agencies or 

entities to be involved in the same programmatic or policy area due to the 

nature or magnitude of the federal effort. However, the areas discussed in 

 

4

An issue area was considered “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. 

What GAO Found
 

Page 3 GAO-12-342SP 2012 Annual Report

the first section of this report identify instances where multiple 

government programs or activities have led to inefficiencies, and we 

determined that greater efficiencies or effectiveness might be achievable.

Further, we have expanded the scope of our work this year to look for 

areas where a mix of federal approaches is used, such as tax 

expenditures, direct spending, and federal grant or loan programs.

Among the 32 areas where we found evidence of duplication, overlap, or 

fragmentation, this report describes a range of conditions. As the “Actions 

Needed” presented in this report show, addressing our varied findings will 

require careful deliberation and tailored, well-crafted solutions.

We have found that agencies can often realize a range of benefits, such 

as improved customer service, decreased administrative burdens, and 

cost savings from addressing the issues we raise in this report. Cost 

savings related to reducing or eliminating duplication, overlap, and 

fragmentation can be difficult to estimate in some cases because the 

portion of agency budgets devoted to certain programs or activities is 

often not clear. In addition, the implementation costs that might be 

associated with consolidating programs, establishing collaboration 

mechanisms, or reducing activities, facilities, or personnel, among other 

variables, are difficult to estimate, or needed information on program 

performance or costs is not readily available.

Section II of this report summarizes 19 additional opportunities for 

agencies or Congress to consider taking action that could either reduce 

the cost of government operations or enhance revenue collections for the 

Treasury. Collectively, this report shows that, if actions are taken to 

address the issues raised herein, as well as those from our 2011 report, 

the government could potentially save tens of billions of dollars annually, 

depending on the extent of actions taken. 
 

Page 4 GAO-12-342SP 2012 Annual Report 

Many federal efforts, including those related to protecting food and 

agriculture, providing homeland security, and ensuring a well trained and 

educated workforce, transcend more than one agency, yet agencies face 

a range of challenges and barriers when they attempt to work 

collaboratively. Both Congress and the Executive Branch have 

recognized this, and in January 2011, the GPRA Modernization Act of 

2010 (the Act) was enacted, updating the almost two-decades-old 

Government Performance and Results Act.5

 The Act establishes a new 

framework aimed at taking a more crosscutting and integrated approach 

to focusing on results and improving government performance. Effective 

implementation of the Act could play an important role in clarifying desired 

outcomes, addressing program performance spanning multiple 

organizations, and facilitating future actions to reduce unnecessary 

duplication, overlap, and fragmentation. 

The Act requires OMB to coordinate with agencies to establish outcomeoriented goals covering a limited number of crosscutting policy areas as 

well as goals to improve management across the federal government, and 

to develop a governmentwide performance plan for making progress 

toward achieving those goals. The performance plan is to, among other 

things, identify the agencies and federal activities—including spending 

programs, tax expenditures, and regulations—that contribute to each goal, 

and establish performance indicators to measure overall progress toward 

these goals as well as the individual contribution of the underlying agencies 

and federal activities. The President’s budget for fiscal year 2013 includes 

14 such crosscutting goals. Aspects of several of these goals—including 

Science, Technology, Engineering, and Math (STEM) Education, 

Entrepreneurship and Small Businesses, Job Training, Cybersecurity, 

Information Technology Management, Procurement and Acquisition 

Management, and Real Property Management—are discussed in this 

report or in our March 2011 report. The Act also requires similar information 

at the agency level. Each agency is to identify the various federal 

organizations and activities—both within and external to the agency—that 

contribute to its goals, and describe how the agency is working with other 

agencies to achieve its goals as well as any relevant crosscutting goals. 

OMB officials stated that their approach to responding to this requirement 

will address fragmentation among federal programs. 

 

5

Pub. L. No. 111-352, 124 Stat. 3866 (2011); Pub. L. No. 103-62, 107 Stat. 285 (1993). 

GPRA Modernization 

Act Provides 

Opportunities to 

Address Duplication, 

Overlap, and 

Fragmentation 
 

Page 5 GAO-12-342SP 2012 Annual Report

These requirements provide a much needed basis for more fully integrating 

a wide array of potentially duplicative, overlapping, or fragmented federal 

activities as well as a cohesive perspective on the long-term goals of the 

federal government focused on priority policy areas. It could also be a 

valuable tool for decision makers when reexamining existing programs and 

considering proposals for new programs.

This annual report is based upon work conducted for completed GAO 

products and certain ongoing audits, which were conducted in 

accordance with generally accepted government auditing standards or 

with our Quality Assurance Framework as appropriate. For issues based 

on GAO work that has not yet been published or those that update prior 

GAO work, we provide additional information on the methodologies used 

in that ongoing work or update in the section of each issue area titled 

“How GAO Conducted Its Work.” For additional information on our 

approach to preparing the overall report, see appendix II.

Appendix III includes lists of federal programs or other activities related to 

issues in this report, and their fiscal year 2010 obligations data, where 

such information was available.6

While the areas identified in our annual reports are not intended to 

represent the full universe of duplication, overlap, or fragmentation within 

the federal government, we will have conducted a systematic examination 

across the federal government to identify major instances of potential 

duplication, overlap, and fragmentation governmentwide by the time we 

issue our third annual report in fiscal year 2013.

Where information is being reported on 

for the first time in this report, GAO sought comments from the agencies 

involved and incorporated those comments as appropriate. In most 

cases, agencies provided technical comments. Written comments are 

reproduced in appendix IV.

7

 

6

For some issue areas, agencies were not able to readily provide programmatic 

information. Similarly, in some cases, we did not report budgetary information because 

such information was either not available or not sufficiently reliable. 

This examination 

involves a multiphased approach. First, to identify potential areas of 

7

The statutory requirement calling for this report also asked GAO to identify specific areas 

where Congress may wish to cancel budget authority it has previously provided—a 

process known as rescission. To date, GAO’s work has not identified a basis for proposing 

specific funding rescissions.

GAO’s Systematic 

Examination of 

Federal Programs and 

Activities
 

Page 6 GAO-12-342SP 2012 Annual Report

overlap, we examined the major budget functions and subfunctions of the 

federal government as identified by OMB. This was particularly helpful in 

identifying issue areas involving multiple government agencies. Second, 

GAO subject matter experts examined key missions and functions of 

federal agencies—or organizations within large agencies—using key 

agency documents, such as strategic plans, agency organizational charts, 

and mission and function documents. This further enabled us to identify 

areas where multiple agencies have similar goals, or where multiple 

organizations within federal agencies are involved in similar activities. 

Next, we canvassed a wide range of published sources—such as 

congressional hearings and reports by the Congressional Budget Office, 

OMB, various government audit agencies, and private think tanks—that 

addressed potential issues of duplication, overlap, and fragmentation. 

Lastly, we have work under way or planned in the coming year to 

evaluate major instances of duplication, overlap, or fragmentation that we 

have not yet covered in our first two annual reports. 

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. Specific questions about individual 

issues may be directed to the area contact listed at the end of each 

summary.

Gene L. Dodaro

Comptroller General

of the United States
 

Page 7 GAO-12-342SP Report at a Glance 

Report at a Glance

This report presents 51 areas where programs may be able to achieve 

greater efficiencies or become more effective in providing government 

services. The findings in this report involve a wide range of government

missions and touch on virtually all major federal departments and 

agencies.

Section I of this report presents 32 areas in which we found evidence of 

duplication, overlap, or fragmentation among federal government 

programs.

Table 1: Duplication, Overlap, and Fragmentation Areas Identified in This Report

Mission Areas Identified Page

Agriculture 1. Protection of Food and Agriculture: Centrally coordinated oversight is needed to ensure nine 

federal agencies effectively and efficiently implement the nation’s fragmented policy to defend the 

food and agriculture systems against potential terrorist attacks and major disasters. 

14

Defense 2. Electronic Warfare: Identifying opportunities to consolidate Department of Defense airborne 

electronic attack programs could reduce overlap in the department’s multiple efforts to develop 

new capabilities and improve the department’s return on its multibillion-dollar acquisition 

investments. 

21

3. Unmanned Aircraft Systems: Ineffective acquisition practices and collaboration efforts in the 

Department of Defense unmanned aircraft systems portfolio creates overlap and the potential for 

duplication among a number of current programs and systems. 

26

4. Counter-Improvised Explosive Device Efforts: The Department of Defense continues to risk 

duplication in its multibillion-dollar counter Improvised Explosive Device efforts because it does 

not have a comprehensive database of its projects and initiatives.

33

5. Defense Language and Culture Training: The Department of Defense needs a more integrated 

approach to reduce fragmentation in training approaches and overlap in the content of training 

products acquired by the military services and other organizations. 

39

6. Stabilization, Reconstruction, and Humanitarian Assistance Efforts: Improving the 

Department of Defense’s evaluations of stabilization, reconstruction, and humanitarian assistance 

efforts, and addressing coordination challenges with the Department of State and the U.S. 

Agency for International Development, could reduce overlapping efforts and result in the more 

efficient use of taxpayer dollars. 

45

Economic 

development

7. Support for Entrepreneurs: Overlap and fragmentation among the economic development 

programs that support entrepreneurial efforts require OMB and other agencies to better evaluate 

the programs and explore opportunities for program restructuring, which may include 

consolidation, within and across agencies. 

52

8. Surface Freight Transportation: Fragmented federal programs and funding structures are not 

maximizing the efficient movement of freight. 62

Energy 9. Department of Energy Contractor Support Costs: The Department of Energy should assess 

whether further opportunities could be taken to streamline support functions, estimated to cost 

over $5 billion, at its contractor-managed laboratory and nuclear production and testing sites, in 

light of contractors’ historically fragmented approach to providing these functions. 

69

10. Nuclear Nonproliferation: Comprehensive review needed to address strategic planning 

limitations and potential fragmentation and overlap concerns among programs combating nuclear 

smuggling overseas. 

73

General 

government

11. Personnel Background Investigations: The Office of Management and Budget should take 

action to prevent agencies from making potentially duplicative investments in electronic case 

management and adjudication systems.

79
 

Page 8 GAO-12-342SP Report at a Glance 

Mission Areas Identified Page

12. Cybersecurity Human Capital: Governmentwide initiatives to enhance cybersecurity workforce 

in the federal government need better structure, planning, guidance, and coordination to reduce 

duplication.

84

13. Spectrum Management: Enhanced coordination of federal agencies’ efforts to manage radio 

frequency spectrum and an examination of incentive mechanisms to foster more efficient 

spectrum use may aid regulators’ attempts to jointly respond to competing demands for spectrum 

while identifying valuable spectrum that could be auctioned for commercial use, thereby 

generating revenues for the U.S. Treasury. 

89

Health 14. Health Research Funding: The National Institutes of Health, Department of Defense, and 

Department of Veterans Affairs can improve sharing of information to help avoid the potential for 

unnecessary duplication. 

96

15. Military and Veterans Health Care: The Departments of Defense and Veterans Affairs need to 

improve integration across care coordination and case management programs to reduce 

duplication and better assist servicemembers, veterans, and their families. 

102

Homeland 

security/Law 

enforcement

16. Department of Justice Grants: The Department of Justice could improve how it targets nearly 

$3.9 billion to reduce the risk of potential unnecessary duplication across the more than 11,000 

grant awards it makes annually. 

110

17. Homeland Security Grants: The Department of Homeland Security needs better project 

information and coordination among four overlapping grant programs. 120

18. Federal Facility Risk Assessments: Agencies are making duplicate payments for facility risk 

assessments by completing their own assessments, while also paying the Department of 

Homeland Security for assessments that the department is not performing. 

128

Information 

technology

19. Information Technology Investment Management: The Office of Management and Budget, and 

the Departments of Defense and Energy need to address potentially duplicative information 

technology investments to avoid investing in unnecessary systems.

132

International 

affairs

20. Overseas Administrative Services: U.S. government agencies could lower the administrative 

cost of their operations overseas by increasing participation in the International Cooperative 

Administrative Support Services system and by reducing reliance on American officials overseas 

to provide these services. 

139

21. Training to Identify Fraudulent Travel Documents: Establishing a formal coordination 

mechanism could help reduce duplicative activities among seven different entities that are 

involved in training foreign officials to identify fraudulent travel documents. 

146

Science and the 

environment

22. Coordination of Space System Organizations: Fragmented leadership has led to program 

challenges and potential duplication in developing multibillion-dollar space systems. 150

23. Space Launch Contract Costs: Increased collaboration between the Department of Defense 

and the National Aeronautics and Space Administration could reduce launch contracting 

duplication. 

157

24. Diesel Emissions: Fourteen grant and loan programs at the Department of Energy, Department 

of Transportation, and the Environmental Protection Agency, and three tax expenditures fund 

activities that have the effect of reducing mobile source diesel emissions; enhanced collaboration 

and performance measurement could improve these fragmented and overlapping programs. 

162

25. Environmental Laboratories: The Environmental Protection Agency needs to revise its overall 

approach to managing its 37 laboratories to address potential overlap and fragmentation and 

more fully leverage its limited resources. 

169

26. Green Building: To evaluate the potential for overlap or fragmentation among federal green 

building initiatives, the Department of Housing and Urban Development, the Department of 

Energy, and the Environmental Protection Agency should lead other federal agencies in 

collaborating on assessing their investments in more than 90 initiatives to foster green building in 

the nonfederal sector. 

175

Social services 27. Social Security Benefit Coordination: Benefit offsets for related programs help reduce the 

potential for overlapping payments but pose administrative challenges. 180

28. Housing Assistance: Examining the benefits and costs of housing programs and tax 

expenditures that address the same or similar populations or areas, and potentially consolidating 

them, could help mitigate overlap and fragmentation and decrease costs. 

185
 

Page 9 GAO-12-342SP Report at a Glance 

Mission Areas Identified Page

Training, 

employment, and 

education

29. Early Learning and Child Care: The Departments of Education and Health and Human Services 

should extend their coordination efforts to other federal agencies with early learning and child 

care programs to mitigate the effects of program fragmentation, simplify children’s access to these 

services, collect the data necessary to coordinate operation of these programs, and identify and 

minimize any unwarranted overlap and potential duplication. 

193

30. Employment for People with Disabilities: Better coordination among 50 programs in nine 

federal agencies that support employment for people with disabilities could help mitigate program 

fragmentation and overlap, and reduce the potential for duplication or other inefficiencies. 

203

31. Science, Technology, Engineering, and Mathematics Education: Strategic planning is needed 

to better manage overlapping programs across multiple agencies. 214

32. Financial Literacy: Overlap among financial literacy activities makes coordination and 

clarification of roles and responsibilities essential, and suggests potential benefits of 

consolidation. 

221

Section II of this report summarizes 19 additional opportunities for 

agencies or Congress to consider taking action that could either reduce 

the cost of government operations or enhance revenue collections for the 

Treasury.

Table 2: Other Cost Savings or Revenue Enhancement Opportunities Identified in This Report

Mission Areas Identified Page

Defense 33. Air Force Food Service: The Air Force has opportunities to achieve millions of dollars in cost 

savings annually by reviewing and renegotiating food service contracts, where appropriate, to 

better align with the needs of installations. 

229

34. Defense Headquarters: The Department of Defense should review and identify further 

opportunities for consolidating or reducing the size of headquarters organizations. 

233

35. Defense Real Property: Ensuring the receipt of fair market value for leasing underused real 

property and monitoring administrative costs could help the military services’ enhanced use lease 

programs realize intended financial benefits. 

239

36. Military Health Care Costs: To help achieve significant projected cost savings and other 

performance goals, DOD needs to complete, implement, and monitor detailed plans for each of its 

approved health care initiatives. 

243

37. Overseas Defense Posture: The Department of Defense could reduce costs of its Pacific region 

presence by developing comprehensive cost information and re-examining alternatives to planned 

initiatives. 

250

38. Navy’s Information Technology Enterprise Network: Better informed decisions are needed to 

ensure a more cost-effective acquisition approach for the Navy’s Next Generation Enterprise 

Network. 

255

Economic 

development

39. Auto Recovery Office: Unless the Secretary of Labor can demonstrate how the Auto Recovery 

Office has uniquely assisted auto communities, Congress may wish to consider prohibiting the 

Department of Labor from spending any of its appropriations on the Auto Recovery Office and 

instead require that the department direct the funds to other federal programs that provide funding 

directly to affected communities. 

259

Energy 40. Excess Uranium Inventories: Marketing the Department of Energy’s excess uranium could 

provide billions in revenue for the government. 

264

General 

government

41. General Services Administration Schedules Contracts Fee Rates: Re-evaluating fee rates on 

the General Services Administration’s Multiple Award Schedules contracts could result in 

significant cost savings governmentwide.

269

42. U.S. Currency: Legislation replacing the $1 note with a $1 coin would provide a significant 

financial benefit to the government over time. 

273

43. Federal User Fees: Regularly reviewing federal user fees and charges can help the Congress 

and federal agencies identify opportunities to address inconsistent federal funding approaches 

and enhance user financing, thereby reducing reliance on general fund appropriations.

278
 

Page 10 GAO-12-342SP Report at a Glance 

Mission Areas Identified Page

44. Internal Revenue Service Enforcement Efforts: Enhancing the Internal Revenue Service’s 

enforcement and service capabilities can help reduce the gap between taxes owed and paid by 

collecting billions in tax revenue and facilitating voluntary compliance.

285

Health 45. Medicare Advantage Payment: The Centers for Medicare & Medicaid Services could achieve 

billions of dollars in additional savings by better adjusting for differences between Medicare 

Advantage plans and traditional Medicare providers in the reporting of beneficiary diagnoses. 

291

46. Medicare and Medicaid Fraud Detection Systems: The Centers for Medicare & Medicaid 

Services needs to ensure widespread use of technology to help detect and recover billions of 

dollars of improper payments of claims and better position itself to determine and measure 

financial and other benefits of its systems. 

294

Homeland 

security/Law 

enforcement

47. Border Security: Delaying proposed investments for future acquisitions of border surveillance 

technology until the Department of Homeland Security better defines and measures benefits and 

estimates life-cycle costs could help ensure the most effective use of future program funding. 

298

48. Passenger Aviation Security Fees: Options for adjusting the passenger aviation security fee 

could further offset billions of dollars in civil aviation security costs.

304

49. Immigration Inspection Fee: The air passenger immigration inspection user fee should be 

reviewed and adjusted to fully recover the cost of the air passenger immigration inspection 

activities conducted by the Department of Homeland Security’s U.S. Immigration and Customs 

Enforcement and U.S. Customs and Border Protection rather than using general fund 

appropriations.

312

International 

affairs

50. Iraq Security Funding: When considering new funding requests to train and equip Iraqi security 

forces, Congress should consider the government of Iraq’s financial resources, which afford it the 

ability to contribute more toward the cost of Iraq’s security. 

316

Social services 51. Domestic Disaster Assistance: The Federal Emergency Management Agency could reduce the 

costs to the federal government related to major disasters declared by the President by updating 

the principal indicator on which disaster funding decisions are based and better measuring a 

state’s capacity to respond without federal assistance. 

321

Table 3: Appendixes

Appedixes Page

Appendix I: List of Congressional Addressees 329

Appendix II: Objectives, Scope, and Methodology 331

Appendix III: Lists of Programs Identified 335

Appendix IV: Agency Comments 388
 

Page 11 GAO-12-342SP Abbreviations 

Abbreviations 

Auto Recovery Office Office of Recovery for Auto Communities and Workers

ATA Anti-Terrorism Assistance

ATAT abusive tax avoidance transaction

BEDI Brownfields Economic Development Initiative

CBO Congressional Budget Office

CBP U.S. Customs and Border Protection 

CCDF Child Care and Development Fund

CDBG Community Development Block Grant

CERP Commander’s Emergency Response Program

CIO Chief Information Officer

CMS Centers for Medicare & Medicaid Services

Commerce Department of Commerce

COPS Community Oriented Policing Services

DHS Department of Homeland Security

DI Disability Insurance

DOD Department of Defense

Dodd-Frank Act Dodd-Frank Wall Street Reform and Consumer Protection Act

DOT Department of Transportation

Education Department of Education

Energy Department of Energy

EPA Environmental Protection Agency

EUL enhanced use lease

FCC Federal Communications Commission

FECA Federal Employees Compensation Act

Federal Reserve Board of Governors of the Federal Reserve System 

FEMA Federal Emergency Management Agency

FHA Federal Housing Administration

FMS U.S. Foreign Military Sales

FPS Federal Protective Service

FRCP Federal Recovery Coordination Program

GM General Motors

GPRA Government Performance and Results Act

GPRAMA GPRA Modernization Act of 2010

GPS Global Positioning System

GSA General Services Administration

HHS Department of Health and Human Services

HSPD-9 Homeland Security Presidential Directive-9 

HUD Department of Housing and Urban Development

ICASS International Cooperative Administrative Support Services

ICE Immigration and Customs Enforcement 

IDR Integrated Data Repository

IED improvised explosive device

IPC Interagency Policy Committee

IRAC Interdepartment Radio Advisory Committee

IRS Internal Revenue Service

ISC Interagency Security Committee

IT information technology

IWG interagency working group

JAG Edward Byrne Memorial Justice Assistance Grant

JIEDDO Joint IED Defeat Organization
 

Page 12 GAO-12-342SP Abbreviations 

Justice Department of Justice

MALD-J Miniature Air Launched Decoy-Jammer

MAS Multiple Award Schedules

MOU memorandum of understanding

NASA National Aeronautics and Space Administration

Navy Department of the Navy

NGEN Next Generation Enterprise Network

NIH National Institutes of Health

NIST National Institute of Standards and Technology

NNSA National Nuclear Security Administration

NOAA National Oceanic and Atmospheric Administration 

NPOESS National Polar-orbiting Operational Environmental Satellite System

NRO National Reconnaissance Office

NSC National Security Council

NSTC National Science and Technology Council

NTIA National Telecommunications and Information Administration

OJP Office of Justice Programs

OMB Office of Management and Budget

One PI One Program Integrity

OPM Office of Personnel Management

ORD Office of Research and Development 

OSTP Office of Science and Technology Policy

OVW Office on Violence Against Women

PTSD post-traumatic stress disorder

RAMP Risk Assessment and Management Program

RCP Recovery Coordination Program 

RHS Rural Housing Service

SBA Small Business Administration

SSA Social Security Administration

SSI Supplemental Security Income

State Department of State

STEM Science, Technology, Engineering, and Mathematics

Treasury Department of the Treasury

TSA Transportation Security Administration

UAS unmanned aircraft system

ULA United Launch Alliance 

USAID U.S. Agency for International Development

USDA U.S. Department of Agriculture

VA Department of Veterans Affairs

Wi-Fi wireless fidelity
 

Page 13 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Section I: Areas in Which GAO Has Identified 

Duplication, Overlap, or Fragmentation 

This section presents 32 areas in which we found evidence of duplication, 

overlap, or fragmentation among federal government programs.
 

Page 14 GAO-12-342SP Duplication, Overlap, and Fragmentation 

1. Protection of Food and Agriculture

Centrally coordinated oversight is needed to ensure nine federal agencies effectively and efficiently implement 

the nation’s fragmented policy to defend the food and agriculture systems against potential terrorist attacks and 

major disasters.

Agriculture is critical to public health and the nation’s economy. It annually 

produces $300 billion worth of food and other farm products, provides a 

major foundation for prosperity in rural areas, and is estimated to be 

responsible for 1 out of every 12 U.S. jobs. As a result, any natural or 

deliberate disruption of the agriculture or food production systems can 

present a serious threat to the national economy and human health. 

Recognizing the vulnerability of the U.S. food and agriculture systems, 

the President issued Homeland Security Presidential Directive-9 (HSPD9) in January 2004 to establish a national policy to defend the food and 

agriculture systems against terrorist attacks, major disasters, and other 

emergencies. HSPD-9 assigns more than nine federal agencies various 

responsibilities to enhance the nation’s preparedness for food and 

agriculture emergencies. 

For many years, GAO has reported that federal oversight of food safety is 

fragmented and results in inconsistent oversight, ineffective coordination, 

and inefficient use of resources. In 2007, GAO added food safety to its list 

of high-risk areas that warrant attention by Congress and the executive 

branch. More recently GAO found that this fragmentation extends to the 

responsibilities across multiple agencies to defend food and agricultural 

systems against terrorist attacks and natural disasters. (See the table 

below for information on agencies’ roles and responsibilities under HSPD9.) Many of these activities are everyday functions or part of the broader 

food and agriculture defense initiative and would be difficult for the 

agencies to separately quantify.

Why This Area Is 

Important

What GAO Found
 

Page 15 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Federal Agency Roles and Responsibilities for Food and Agriculture Defense as Defined by HSPD-9 
 

Page 16 GAO-12-342SP Duplication, Overlap, and Fragmentation 

a

The National Response Plan was replaced by the National Response Framework in 2008. 

As GAO reported in August 2011, there is no centralized coordination to 

oversee the federal government’s overall progress in implementing the 

nation’s food and agriculture defense policy. Because the responsibilities 

outlined in this policy (HSPD-9) are fragmented and cut across at least 

nine different agencies, centralized oversight is important to ensure that 

efforts are coordinated to overcome this fragmentation, efficiently use 

scarce funds, and promote the overall effectiveness of the federal 

government.
 

Page 17 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Previously, the White House Homeland Security Council conducted some 

coordinated activities to oversee federal agencies’ HSPD-9 

implementation by gathering information from agencies about their 

progress. In 2008, it tasked the Department of Homeland Security (DHS) 

with creating an online forum intended to enable agencies to share 

information that coordinated their HSPD-9 efforts, allowing the Council to 

efficiently view agencies’ implementation progress in a consistent 

manner. However, these efforts are no longer ongoing. Officials from the 

U.S. Departments of Agriculture (USDA), Homeland Security, Health and 

Human Services (HHS) and the Environmental Protection Agency (EPA) 

told us that the Homeland Security Council’s efforts were valuable. For 

example, officials from EPA told us it was valuable to interact with other 

agencies regarding HSPD-9 efforts, HHS officials found the Homeland 

Security Council’s consolidation of information across multiple agencies 

to be useful. Officials from EPA noted that although the Homeland 

Security Council’s and DHS’s oversight roles have not been consistent for 

the past few years, EPA and other agencies have used multi-agency 

working groups to coordinate food and agriculture emergency activities.1

Moreover, without centrally coordinated oversight, agencies may not have 

sufficient direction for prioritizing responsibilities, and they may not have 

sufficient incentive to monitor progress internally. For example, GAO 

found that USDA does not have a departmentwide strategy for prioritizing 

and allocating resources to its numerous HSPD-9 responsibilities. 

According to USDA officials, because food and agriculture defense has 

not been a primary focus in recent years for the National Security Staff—

which supports the White House Homeland Security Council under the 

current administration—USDA has been less focused on HSPD-9 

oversight and has prioritized other, more recently directed activities. 

Instead, USDA assigned its responsibilities to its component agencies

based on their statutory authority and expertise and allowed individual 

agencies to set their implementation and budget priorities.

It is unclear why the Homeland Security Council no longer gathers such 

information, but officials from DHS noted that interest from agencies and 

the Homeland Security Council has decreased, and as of late 2008 or

early 2009, they no longer coordinate agencies’ reporting of their HSPD-9 

implementation progress. Top-level review can help ensure that 

management’s directives are carried out and determine if agencies are 

effectively and efficiently using resources.

However, USDA agencies are facing various challenges carrying out 

these responsibilities. For example, from 2005 through 2010, USDA’s 

 

1

In 2005, GAO reported that, since the terrorist attacks of 2001, agencies had formed 

numerous working groups to protect agriculture. For example, DHS created a Food and 

Agriculture Sector Coordinating Council to help the federal government and industry share 

ideas about how to mitigate the risk of an attack on agriculture. See GAO, Homeland 

Security: Much Is Being Done to Protect Agriculture from a Terrorist Attack, but Important 

Challenges Remain, GAO-05-214 (Washington, D.C.: Mar. 8, 2005).
 

Page 18 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Agricultural Research Service allocated approximately $10.6 million to 

develop a system—the National Plant Disease Recovery System—to help 

the nation recover from plant disease outbreaks that could devastate the 

nation’s production of economically important crops. A major part of this 

effort involved developing recovery plans that identified critical research 

gaps; however, the Agricultural Research Service does not have a 

documented, systematic process to monitor the extent to which research 

gaps are filled, calling into question the efficient use of these funds. In 

addition, from 2006 through 2010, USDA’s Animal and Plant Health 

Inspection Service allocated approximately $33 million (including about 

$18 million in supplemental funding) to develop the National Veterinary 

Stockpile—a stockpile containing resources to respond to the 17 most 

damaging animal diseases affecting human health and the economy. 

HSPD-9 calls for the National Veterinary Stockpile to leverage where 

appropriate the mechanisms and infrastructure that have been developed 

for HHS’s Strategic National Stockpile—which contains medical supplies 

to address public health emergencies. Although there has been some 

collaboration, there appears to be confusion about the mission and 

capabilities of the stockpiles that could hinder USDA’s and HHS’s efforts 

to identify leveraging opportunities. Unless resolved, the agencies may be 

missing opportunities to more efficiently use federal resources.

Because there is currently no centralized coordination to oversee 

agencies’ HSPD-9 implementation progress, it is unclear how effectively 

or efficiently agencies are using resources in implementing the nation’s 

food and agriculture defense policy. As a result, the nation may not be 

assured that agency efforts to protect agriculture and the food supply are 

well designed and effectively implemented. USDA officials told us that the 

department would benefit from strategic direction from the National 

Security Staff to help prioritize specific activities and funding decisions in 

this time of limited resources. GAO has previously reported that effective 

strategies help set priorities and allocate resources to inform decision 

making and help ensure accountability.2 Such priority setting and 

resource allocation is especially important in a fiscally constrained 

environment.

 

2

See, for example, GAO, Combating Terrorism: Evaluation of Selected Characteristics in 

National Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004).
 

Page 19 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO recommended in August 2011 that to help ensure that the federal 

government is effectively implementing the nation’s food and agriculture 

defense policy, the Secretary of Homeland Security should

• resume DHS’s efforts to coordinate agencies’ overall HSPD-9 

implementation efforts.

In addition, the Homeland Security Council should direct the National 

Security Staff to

• establish an interagency process that would provide oversight of 

agencies’ implementation of HSPD-9; and

• encourage agencies to participate in and contribute information to 

DHS’s efforts to coordinate agencies’ implementation of HSPD-9.

Furthermore, to ensure that USDA is fulfilling its responsibilities to protect 

the nation’s food and agriculture systems, the Secretary of Agriculture 

should

• develop a departmentwide strategy for implementing its HSPD-9 

responsibilities. Such a strategy would include an overarching 

framework for setting priorities, as well as allocating resources.

Also, to help ensure that the nation is adequately prepared to recover 

from high-consequence plant diseases, the Secretary of Agriculture 

should direct the Administrator of the Agricultural Research Service, in 

coordination with relevant USDA agencies, to

• develop and implement a documented, systematic process to track 

research gaps identified in the National Plant Disease Recovery 

System recovery plans and monitor progress in filling these gaps.

Moreover, to ensure the most effective use of resources and to resolve 

any confusion, the Secretaries of Agriculture and Health and Human 

Services should

• jointly determine on a periodic basis if there are appropriate 

opportunities for the National Veterinary Stockpile to leverage 

Strategic National Stockpile mechanisms or infrastructure as directed 

by HSPD-9. If such opportunities exist, the two agencies should 

formally agree upon a process for the National Veterinary Stockpile to 

use the identified mechanisms and infrastructure.

By taking these actions, federal decision makers will acquire critical 

information they need to help assess how well the nation is prepared for 

major emergencies and how efficiently agencies are using federal 

resources to prepare.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 20 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO provided a draft of its August 2011 report to DHS, HHS, USDA, 

EPA, and the National Security Staff for review and comment. DHS, HHS, 

and USDA generally agreed with GAO’s recommendations. In addition, in 

an e-mail received July 22, 2011, the National Security Staff’s Deputy 

Legal Advisor stated that the National Security Staff agrees that a review 

of HSPD-9 is appropriate and that they will look for an opportunity to do 

so. DHS, HHS, USDA, EPA, and the National Security Staff also provided 

technical comments, which were incorporated as appropriate. As part of 

GAO’s routine audit work, GAO will track agency actions to address these 

recommendations and report to Congress.

This information contained in this analysis is based on findings from the 

products in the related GAO products section. GAO reviewed key 

documents and interviewed officials from USDA, DHS, HHS, and EPA 

because these agencies have the most responsibilities under HSPD-9. 

GAO also met with an official from the National Security Staff to discuss 

any current efforts they are coordinating to oversee agencies’ HSPD-9 

implementation progress.

Homeland Security: Challenges for the Food and Agriculture Sector in 

Responding to Potential Terrorist Attacks and Natural Disasters. 

GAO-11-946T. Washington, D.C.: September 13, 2011.

Homeland Security: Actions Needed to Improve Response to Potential 

Terrorist Attacks and Natural Disasters Affecting Food and Agriculture. 

GAO-11-652. Washington, D.C.: August 19, 2011.

For additional information about this area, contact Lisa Shames at (202) 

512-3841 or shamesl@gao.gov. 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 21 GAO-12-342SP Duplication, Overlap, and Fragmentation 

2. Electronic Warfare

Identifying opportunities to consolidate Department of Defense airborne electronic attack programs could 

reduce overlap in the department’s multiple efforts to develop new capabilities and improve the department’s 

return on its multibillion-dollar acquisition investments.

Airborne electronic attack—an electronic warfare capability—involves use 

of aircraft to neutralize, destroy, or temporarily suppress enemy air 

defense and communications systems, either through destructive or 

disruptive means. These capabilities are increasingly important and 

complex as networked systems, distributed controls, and sophisticated 

sensors become ubiquitous in military equipment, civilian infrastructure, 

and commercial networks. These technological developments complicate 

the Department of Defense’s ability to exercise control over the 

electromagnetic spectrum, when necessary, to support U.S. military 

objectives. Aircraft executing airborne electronic attack missions employ a 

variety of mission systems, such as electronic jamming pods, and 

weapons, such as antiradiation missiles and air-launched expendable 

decoys. These aircraft also rely on aircraft self-protection systems and 

defensive countermeasures for additional protection.

All four military services within the Department of Defense are separately 

acquiring new airborne electronic attack systems. Department of Defense 

investments to develop and procure new and updated airborne electronic 

attack systems are projected to total more than $17.6 billion from fiscal 

years 2007 through 2016. With the prospect of slowly growing or flat 

defense budgets for years to come, the department must get better 

returns on its weapon system investments and find ways to deliver more 

capability to the warfighter for less than it has in the past.

GAO’s ongoing review of planned airborne electronic attack systems 

found that the department is developing multiple systems to provide 

similar capabilities. Opportunities may exist for consolidating some 

current service-specific acquisition efforts. As GAO reported in March 

2011, service-driven requirements and funding processes continue to 

hinder integration and efficiency and contribute to unnecessary 

duplication in addressing warfighter needs. In the airborne electronic 

attack mission area, systems in development may overlap—at least to 

some extent—in terms of planned mission tasks. Yet, they are being 

developed as individual programs by the different services. The table 

below highlights overlap among four systems being developed to counter 

irregular warfare1

 

1

Irregular warfare is defined as a violent struggle among state and nonstate actors for 

legitimacy and influence over the relevant population(s). Irregular warfare favors indirect 

and asymmetric approaches, though it may employ the full range of military and other 

capacities, in order to erode an adversary’s power, influence, and will. 

threats—one subset of airborne electronic attack. While 

Why This Area Is 

Important

What GAO Found
 

Page 22 GAO-12-342SP Duplication, Overlap, and Fragmentation 

the host platforms for each system are different, the missions each 

system performs are similar. 

Potential Overlap among Communication Jamming Systems Supporting Ground Forces 

System name 

Collaborative On-line 

Reconnaissance 

Provider Operationally 

Responsive Attack Link 

(CORPORAL) Intrepid Tiger II 

Communications 

Electronic Attack with 

Surveillance and 

Reconnaissance 

(CEASAR) 

MQ-9 Reaper Electronic 

Attack Pod 

Service sponsor Marine Corps Marine Corps Army Air Force 

Host platform RQ-7B Shadow unmanned 

aerial vehicle 

AV-8B fixed wing aircrafta C-12 fixed wing aircraft MQ-9 Reaper unmanned 

aerial vehicle 

Mission 

description 

Communications jamming 

in support of ground 

forcesb

Communications jamming 

and surveillance capability 

in support of ground forces

Denial and disruption of 

enemy communications 

systems and improvised 

explosive devices in 

support of unit-level ground 

commanders 

Communications and 

improvised explosive 

device jamming in support 

of combatant commander 

mission needs 

Estimated 

acquisition cost 

$54.5 million $76.8 million $13.8 millionc $233.7 million 

Source: GAO analysis of Department of Defense data. 

a

After the AV-8B, the Intrepid Tiger II pod will be integrated onto additional aircraft. 

b

CORPORAL also consists of other technologies that serve broader purposes. 

c

Total excludes $26.3 million in funding from the Operations and Maintenance, Army budget account 

through fiscal year 2013. The Army uses these funds to (1) lease two C-12 aircraft to fly the CEASAR 

pod and (2) fund aircraft and pod sustainment costs. 

According to Department of Defense officials, airborne electronic attack 

limitations in recent operations, urgent needs of combatant commanders, 

and the desire to provide ground units with their own locally controlled 

assets have all contributed to the services’ decisions to develop their own 

systems to address irregular warfare threats. 

Requirements for most of these irregular warfare systems were derived 

from Department of Defense urgent needs processes—activities aimed at 

rapidly developing, equipping, and fielding solutions and critical 

capabilities to the warfighter in a way that is more responsive to urgent 

warfighter requests than the department’s traditional acquisition 

procedures. As GAO reported in March 2011, the department’s urgent 

needs processes often lead to multiple entities responding to requests for 

similar capabilities, resulting in potential duplication of efforts. As military 

operations in Iraq and Afghanistan wind down—and the services evaluate 

whether to transition their current urgent needs program over to the 

formal weapon system acquisition process—opportunities may exist to 

better consolidate current program activities, such as the CORPORAL 

and CEASAR pod systems that are still demonstration programs whose 

transitions to formal acquisition programs have not yet been determined. 

The potential for unnecessary duplication of efforts within the airborne 

electronic attack area is not limited to irregular warfare systems. Similar 
 

Page 23 GAO-12-342SP Duplication, Overlap, and Fragmentation 

issues exist with airborne electronic attack systems designed to counter 

potential near-peer adversaries.2

The two services have held discussions with one another about 

combining efforts toward a joint solution—including a meeting between 

Navy and Air Force requirements offices and acquisition officials in 

December 2010—but they have not reached resolution on a common 

path forward. According to Navy officials, relatively minor design and 

software modifications to the Air Force’s planned MALD-J Increment II 

system could produce a system that satisfies both services’ mission 

requirements. However, Air Force officials stated that accommodating the 

Navy’s mission requirements within the system would increase program 

costs and delay planned fielding of the Increment II system, essentially 

rendering the current program unexecutable. Subsequently, Air Force 

officials stated that unless MALD-J Increment II, as currently configured, 

sufficiently meets Navy requirements, they do not expect the Navy to 

have any formal role in the program. In July 2011, the Air Force 

suspended MALD-J Increment II because of future funding shortfalls. This 

pause in the program affords an opportunity for continued dialogue 

between the two services as to potential benefits and drawbacks to the 

pursuit of a common acquisition solution.

Most notably, both the Air Force and 

Navy are separately evaluating options for acquiring advanced jamming 

decoys—the Air Force through an upgrade (referred to as Increment II) to 

its Miniature Air Launched Decoy-Jammer (MALD-J) program, and the 

Navy through its planned Airborne Electronic Attack Expendable initiative.

On the other hand, the services have shown in some instances that they 

can share information across the different efforts. For example, Marine 

Corps decisions to reuse jammer technologies from CORPORAL for 

Intrepid Tiger II have driven significant commonality in hardware and 

software for these systems, which program officials state has reduced 

technical challenges and produced cost savings. 

Pursuing multiple separate acquisition efforts to develop similar 

capabilities within the airborne electronic attack mission area can lead to 

insufficient use of resources and may contribute to other warfighting 

needs going unfilled. Leveraging resources and acquisition efforts across 

services can simplify developmental efforts, improve interoperability 

among systems, and decrease operations and support costs—outcomes 

that position the department to maximize the returns it gets on its airborne 

electronic attack investments.

 

2

Potential near-peer adversaries include countries capable of waging large scale 

conventional war on the United States. These nation-states are characterized as having 

nearly comparable diplomatic, informational, military, and economic capacity to the United 

States. 
 

Page 24 GAO-12-342SP Duplication, Overlap, and Fragmentation 

To ensure investments in airborne electronic attack systems are costeffective and to prevent unnecessary overlap, GAO expects to 

recommend that the Secretary of Defense

• review the capabilities provided by the Marine Corps’s Intrepid Tiger II 

pod and CORPORAL, Army’s CEASAR, and Air Force MQ-9 Reaper 

Electronic Attack Pod systems and identify opportunities for 

consolidating these different efforts, as appropriate; and

• assess Air Force and Navy plans for developing and acquiring new 

expendable jamming decoys, specifically those services’ MALD-J 

Increment II and Airborne Electronic Attack Expendable initiatives, to 

determine if these activities should be merged.

Department of Defense analysis of airborne electronic attack programs—

both current and planned—could reduce duplication of similar acquisition 

initiatives and improve efficiencies. More analysis is needed by the 

department to determine the potential for cost savings.

GAO provided a draft of this report section to the Department of Defense 

for review and comment. The department provided technical comments, 

which were incorporated as appropriate. In its comments, the department 

noted that the Army and Marine Corps have held high-level discussions to 

collaborate on the CEASAR, Intrepid Tiger II, and CORPORAL programs. 

According to the department, discussions to share hardware and software 

technology are ongoing—an arrangement that, if implemented, could 

result in significant cost avoidance—but talks have not yet yielded a 

design or set of requirements agreeable to both services. As part of 

GAO’s routine audit work, GAO will track agency actions to address these 

expected recommendations and report to Congress.

The information contained in this analysis is based on findings from the

products listed in the related GAO products section and additional work 

GAO conducted to be published as a separate product in 2012. 

GAO reviewed program documentation to identify planned capabilities, 

technical challenges, and anticipated costs for key systems. GAO also 

analyzed Department of Defense documents outlining airborne electronic 

attack-related mission requirements and acquisition needs and reviewed 

platform-specific capabilities documents, service roadmaps, and budget 

documents, which together provided insight on the department’s overall 

strategy for acquiring airborne electronic attack capabilities. GAO 

conducted interviews with relevant Department of Defense officials 

responsible for managing airborne electronic attack requirements and 

programs.

Appendix III lists the programs GAO identified that may have similar or 

overlapping objectives, provide similar services or be fragmented across 

government missions. Overlap and fragmentation may not necessarily

lead to actual duplication, and some degree of overlap and duplication 

may be justified.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 25 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Warfighter Support: DOD’s Urgent Needs Processes Need a More 

Comprehensive Approach and Evaluation for Potential Consolidation. 

GAO-11-273. Washington, D.C.: March 1, 2011.

Opportunities to Reduce Potential Duplication in Government Programs, 

Save Tax Dollars, and Enhance Revenue. GAO-11-318SP. Washington, 

D.C.: March 1, 2011. 

For additional information about this area, contact Michael J. Sullivan at 

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

Related GAO 

Products 

Contact Information
 

Page 26 GAO-12-342SP Duplication, Overlap, and Fragmentation 

3. Unmanned Aircraft Systems

Ineffective acquisition practices and collaboration efforts in the Department of Defense unmanned aircraft 

systems portfolio creates overlap and the potential for duplication among a number of current programs and 

systems.

The Department of Defense (DOD) estimates that the cost of current 

unmanned aircraft systems (UAS) acquisition programs and related 

systems will exceed $37.5 billion in fiscal years 2012 through 2016.1

In 2009, GAO’s work highlighted the need to consider commonality in 

UAS—using the same or interchangeable subsystems and components in 

more than one subsystem to improve interoperability of systems—and 

indicated that DOD lacked an analytical approach to prioritize capability 

needs which would reduce the likelihood of redundancies in UAS 

capabilities. As GAO reported in June 2011, although the Joint 

Requirements Oversight Council is directed to ensure that trade-offs 

among cost, schedule, and performance objectives are considered as 

part of its requirements review process, it currently does not prioritize 

requirements, consider redundancies across proposed programs, or 

prioritize and analyze capability gaps in a consistent manner. Congress 

has enacted legislation requiring DOD to establish a policy and 

acquisition strategy for more common ground stations and payloads for 

manned and unmanned aircraft systems.

These programs and systems can be found across DOD and the military 

services (Air Force, Army, Navy, and Marine Corps). The continued 

success of UAS on the battlefield has led to greatly increased demand 

from warfighters and the development of many new systems. Further, in 

announcing the department’s new budget priorities, the Secretary of 

Defense highlighted various current and planned unmanned systems that 

are considered to be high-priority in terms of meeting the requirements of 

the new strategic guidance.

2

The elements of DOD’s planned UAS portfolio include unmanned aircraft, 

payloads, and ground control stations. Unmanned aircraft are fixed or 

rotary winged aircraft capable of flight without an onboard crew. Payloads 

are subsystems and equipment carried on a UAS configured to 

accomplish specific missions, including intelligence, surveillance, and 

reconnaissance and attack. Ground control stations handle multiple 

mission aspects such as system command and control, mission planning, 

payload control, and communications. 

 

1

The $37.5 billion amount includes funding for the development, procurement, 

sustainment, military construction and personnel, and war funding to support UAS 

activities in then year dollars identified in the President’s 2012 budget submission.

2

Duncan Hunter National Defense Authorization Act for Fiscal Year 2009, Pub. L. No. 110-

417, §144 (2008).

Why This Area Is 

Important
 

Page 27 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Military service-driven requirements—rather than an effective 

departmentwide strategy—have led to overlap in DOD’s UAS capabilities, 

resulting in many programs and systems being pursued that have similar 

flight characteristics and mission requirements. DOD currently has 15 

unmanned aircraft programs which it categorizes into five groups 

according to weight, altitude, and speed. Groups 4 and 5 contain the 

largest and most expensive aircraft, with weights exceeding 1,320 

pounds. Group 5 aircraft fly higher—above 18,000 feet—than Group 4 

aircraft. DOD has spent almost $19 billion through fiscal year 2011 to 

develop and procure three aircraft in Group 5 and five aircraft in Group 4, 

where GAO found potential overlap, and expects to spend an additional 

$32.4 billion to complete these programs.

Illustrative of the overlap, in Group 5, the Navy plans to spend more than 

$3 billion to develop its own variant of the Air Force Global Hawk—the 

Broad Area Maritime Surveillance UAS—rather than using the already 

fielded Global Hawk. According to the Navy, its unique requirements 

necessitate modifications to the Global Hawk airframe, payload 

interfaces, and ground control station. However, the Navy program office 

was not able to provide quantitative analysis to justify the variant. 

According to program officials, no analysis was conducted to determine 

the cost-effectiveness of developing a new aircraft to meet the Navy’s 

requirements versus buying more Global Hawks.

If the preference for service-unique solutions persists in the absence of a 

departmentwide strategy, so will the potential for overlap in the future. 

DOD plans to significantly expand the UAS portfolio through 2040, 

including five new systems in the planning stages that are expected to 

become formal programs in the near future.

In addition to unmanned aircraft, DOD expects to spend about $9 billion 

to buy 42 UAS payloads through fiscal year 2016. Each payload provides 

a sensor using one of three different technologies: electro-optical/infrared, radar, and signals intelligence. For Group 4 and 5 aircraft, GAO 

identified overlap among numerous sensors being developed within each 

of the three technologies (see table below).

What GAO Found
 

Page 28 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Overlapping Development of Sensors for UAS Payloads in Group 4 and 5 Aircraft

Sensor type Number of programs

Electro-optical/infra-red Four Air Force programs

Four Army programs

One Navy program

Five multiservice programs

Radar Three Air Force programs

Two Army programs 

One Navy program

One multiservice program

Signals intelligence Four Air Force programs

Two Navy programs

Two Army programs

Source: GAO analysis of DOD data.

While the fact that some multiservice payloads are being developed shows 

the potential for collaboration, the service-centric requirements process still 

creates the potential for overlap. For example, the Army and Air Force are 

developing two separate signals intelligence sensors (the TSP and ASIP 2-

C, respectively) that have similar capabilities to track ground 

communication and activity. According to a DOD-sponsored study in March 

2010, the department could have saved almost $1.2 billion had the Air 

Force acquired the same sensor as the Army. However, since such an 

approach was not considered earlier in the program, DOD concluded there 

was not a business case for combining the programs. Instead, the study 

noted, the ideal time for such a decision would have been when 

requirements were being determined. More recently, the Navy has begun 

development of its own signals intelligence payload (the MCS-21) for the 

Broad Area Maritime Surveillance aircraft, even though the sensor’s 

capabilities are similar to those of the Air Force and Army payloads.

Through fiscal year 2016, DOD plans to spend about $3 billion to acquire 

13 ground control stations and GAO identified overlap and potential 

duplication among 10 of these systems. Because aircraft, payloads and 

control stations are usually developed together, a unique ground control 

station therefore exists for almost every UAS that DOD has acquired. 

According to a cognizant DOD official, the associated software is about 

90 percent duplicative because similar software is developed for each 

ground control station. Even though the functionality of the software is 

similar, a considerable amount of additional time and money is invested in 

capabilities that have already been paid for and can also make it difficult 

and costly to modify or upgrade.

DOD has acknowledged that an open architecture framework could 

provide opportunities for increased competition and collaboration to 

satisfy requirements through common software solutions, among other 

areas. DOD has created a UAS control segment working group, which is 

chartered to increase interoperability and enable software re-use and 
 

Page 29 GAO-12-342SP Duplication, Overlap, and Fragmentation 

open systems. This could allow for greater efficiency, less redundancy, 

and lower costs, while potentially reducing levels of contractor proprietary 

data that cannot be shared across UAS programs. However, existing 

ground control stations already have their own architecture and migration 

to a new service-oriented architecture will not happen until at least 2015, 

almost 6 years after it began.3

DOD has acknowledged that it has bought many UAS systems 

inefficiently and has begun to take steps to improve outcomes as it 

expands these capabilities over the next several years. DOD continues to 

face challenges in its ability to improve efficiency and reduce the potential 

for overlap and duplication as it buys UAS capabilities:

• GAO recommended in November 2008, among other things, that 

DOD designate a single entity to integrate all crosscutting efforts 

related to improving the management and operation of UAS, including 

to ensure that all UAS systems were designed to meet joint service 

requirements and interoperability standards. DOD did not agree, 

stating that rather than an executive agent, the combination of the 

UAS Task Force (created in 2007 to encourage initiatives for 

collaboration among the military services) and other initiatives would

serve to address UAS challenges. Currently, the Task Force has no 

decision-making authority and cannot direct the military services’ 

efforts to acquire UAS capabilities. As such, while the military services 

participate at all levels of the Task Force, they do not always fully 

support related initiatives and, therefore, do not achieve the potential 

benefits from collaboration.

• GAO recommended in July 2009 that DOD not begin new programs 

until evaluating systems from a multiservice perspective and take an 

open systems approach to product development. While DOD 

concurred with this recommendation, it believes current practices do 

not encourage duplicative systems development. However, among 

future UAS aircraft, the Army and Navy are planning to spend 

approximately $1.6 billion to acquire separate systems that are likely 

to have similar capabilities to meet upcoming cargo and surveillance 

requirements. DOD officials state that current requirements do not 

preclude a joint program to meet these needs, but the Army and Navy 

have not yet determined whether such an approach will be used.

• Despite DOD direction, although the Air Force and the Army used the 

same contractor to procure the Predator and Gray Eagle UAS, the 

programs achieved only limited success with efforts to combine 

 

3

In 2009, the Office of the Secretary of Defense directed the military services to develop a 

common control station service-oriented architecture for implementation into the military 

services’ control stations to help acquire, integrate, and extend the capabilities of current 

control stations across the UAS portfolio. The Air Force has decided to implement a 

“complementary” architecture.
 

Page 30 GAO-12-342SP Duplication, Overlap, and Fragmentation 

programs and missed an opportunity to potentially save hundreds of 

millions of dollars. The Air Force now plans to procure Reaper UAS 

rather than the Predator.

To reduce the likelihood of overlap and potential duplication in its UAS 

portfolio, GAO has made several prior recommendations to DOD which 

have not been fully implemented. While DOD generally agreed with the 

intent of those recommendations, the department has not always agreed 

with the proposed method of implementation. The overlap in current UAS 

programs, as well as the continued potential in future programs, shows 

that DOD must still do more to implement GAO’s prior recommendations. 

GAO believes the potential for savings is significant and with DOD’s 

renewed commitment to UAS for meeting new strategic requirements, all 

the more imperative. Specifically, DOD should

• re-evaluate whether a single entity would be better positioned to 

integrate all crosscutting efforts to improve the management and 

operation of UAS;

• consider an objective, independent examination of current UAS 

portfolio requirements and the methods for acquiring future unmanned 

aircraft, including strategies for making these systems more common, 

to ensure the best return on every dollar it invests; and

• prior to initiating future unmanned aircraft programs, direct the military 

services to identify and document in their acquisition plans and 

strategies specific areas where commonality can be achieved, take an 

open systems approach to product development, conduct a 

quantitative analysis that examines the costs and benefits of various 

levels of commonality, and establish a collaborative approach and 

management framework to periodically assess and effectively 

manage commonality. 

GAO provided a draft of this report section to DOD. DOD provided 

clarifications on individual program decisions and other technical 

comments which were incorporated as appropriate. As part of its routine 

audit work, GAO will track agency actions to address these 

recommendations and report to Congress.

The information contained in this analysis is based on findings from 

products listed in the related GAO products section and additional work 

GAO conducted. GAO comprehensively identified, to the extent possible, 

using a data collection instrument, DOD’s UAS portfolio to analyze how 

DOD and the military services acquired this portfolio. GAO assessed the 

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

Logistics and military service UAS roadmaps, requirements, and concepts 

of operation. GAO conducted interviews with officials from the Joint 

Chiefs of Staff, the Office of the Under Secretary of Defense for 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 31 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Acquisition, Technology, and Logistics, military service laboratories and 

program offices, as well as UAS contractors. Using these data, GAO 

evaluated to what extent collaboration and coordination efforts by DOD 

and the military services resulted in—or reduced the potential for—

duplication, fragmentation, and overlap. Appendix III lists the programs 

GAO identified that may have similar or overlapping objectives, provide 

similar services or be fragmented across government missions. Overlap 

and fragmentation may not necessarily lead to actual duplication, and 

some degree of overlap and duplication may be justified.

DOD Weapon Systems: Missed Trade-off Opportunities During 

Requirements Reviews. GAO-11-502. Washington, D.C.: June 16, 2011.

Intelligence, Surveillance, and Reconnaissance: Actions Are Needed to 

Increase Integration and Efficiencies of DOD’s ISR Enterprise.

GAO-11-465. Washington, D.C.: June 3, 2011.

Defense Acquisitions: Opportunities Exist to Achieve Greater 

Commonality and Efficiencies among Unmanned Aircraft Systems.

GAO-09-520. Washington, D.C.: July 30, 2009.

Unmanned Aircraft Systems: Additional Actions Needed to Improve 

Management and Integration of DOD Efforts to Support Warfighter 

Needs. GAO-09-175. Washington, D.C.: November 14, 2008.

Unmanned Aircraft Systems: Advance Coordination and Increased 

Visibility Needed to Optimize Capabilities. GAO-07-836. Washington, 

D.C.: July 11, 2007.

Defense Acquisition: Better Acquisition Strategy Needed for Successful 

Development of the Army’s Warrior Unmanned Aircraft System. 

GAO-06-593. Washington, D.C.: May 19, 2006.

Unmanned Aircraft Systems: New DOD Programs Can Learn from Past 

Efforts to Craft Better and Less Risky Acquisition Strategies. 

GAO-06-447. Washington, D.C.: March 15, 2006.

Unmanned Aircraft Systems: DOD Needs to More Effectively Promote 

Interoperability and Improve Performance Assessments. GAO-06-49. 

Washington, D.C.: December 13, 2005.

Unmanned Aerial Vehicles: Changes in Global Hawk’s Acquisition 

Strategy Are Needed to Reduce Program Risks. GAO-05-6. Washington, 

D.C.: November 5, 2004.

Force Structure: Improved Strategic Planning Can Enhance DOD’s 

Unmanned Aerial Vehicles Efforts. GAO-04-342. Washington, D.C.: 

March 17, 2004.

Related GAO 

Products 
 

Page 32 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Defense Acquisitions: Matching Resources with Requirements Is Key to 

the Unmanned Combat Air Vehicle Program’s Success. GAO-03-598. 

Washington, D.C.: June 30, 2003.

Ballistic Missile Defense: More Common Systems and Components 

Could Result in Cost Savings. GAO/NSIAD-99-101. Washington, D.C.: 

May 21, 1999.

Unmanned Vehicles: Assessment of DOD’s Unmanned Aerial Vehicle 

Master Plan. NSIAD-89-41BR. Washington, D.C.: December 9, 1988.

For additional information about this area, contact Michael J. Sullivan at 

(202) 512-4841 or sullivanm@gao.gov. Contact Information
 

Page 33 GAO-12-342SP Duplication, Overlap, and Fragmentation 

4. Counter-Improvised Explosive Device 

Efforts 

The Department of Defense continues to risk duplication in its multibillion-dollar counter Improvised Explosive 

Device efforts because it does not have a comprehensive database of its projects and initiatives.

The threat of improvised explosive devices (IED) continues to be a major 

concern in Afghanistan, as well as to other areas throughout the world 

with over 500 reported IED events per month worldwide outside of 

Southwest Asia according to Department of Defense (DOD) officials. 

Further, there is widespread consensus in DOD that this threat will not go 

away and that IEDs will continue to be a weapon of strategic influence in 

future conflicts. In support of the fight against IEDs, Congress has 

appropriated over $18 billion to the Joint IED Defeat Organization 

(JIEDDO)1

As GAO reported in March 2011, there are several examples of 

duplication in DOD’s counter-IED efforts and neither JIEDDO nor any 

other DOD organization had full visibility over all of DOD’s counter-IED 

efforts.

from fiscal year 2006 through fiscal year 2011 to address the 

IED threat. In addition, other DOD components, including the military 

services, also have spent billions of dollars from their own funds 

developing counter-IED capabilities. For example, the Mine Resistant 

Ambush Protected Task Force, which leads DOD’s efforts to produce and 

field Mine Resistant Ambush Protected vehicles to protect troops against 

IEDs and other threats, received over $40 billion from fiscal years 2005 

through 2010. With the current fiscal challenges facing the nation, it will 

be important for DOD to coordinate its counter-IED efforts in order to use 

funds efficiently.

2 GAO also reported in February 2012 on additional examples of 

potential duplication in DOD’s counter-IED efforts. 

DOD does not have full visibility over all of its counter-IED efforts. DOD 

relies on various sources and systems for managing its counter-IED 

efforts, but has not developed a process that provides DOD with a 

comprehensive listing of its counter-IED initiatives and activities. For 

example, JIEDDO has developed the JIEDDO Enterprise Management 

System to manage its own operations by collecting and reporting cost and 

 

1

This total represents appropriations and rescissions made to the Joint Improvised 

Explosive Device Defeat Fund for JIEDDO. Prior to the establishment of JIEDDO in 2006, 

no single entity was responsible for coordinating DOD’s counter-IED efforts. A primary role 

for JIEDDO is to provide funding and assistance to rapidly develop, acquire, and field 

counter-IED solutions. 

2

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

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

Why This Area Is 

Important

What GAO Found
 

Page 34 GAO-12-342SP Duplication, Overlap, and Fragmentation 

other information related to JIEDDO’s organizational and funds 

management, its coordination of JIEDDO-funded projects and projects 

funded by other DOD activities, its administrative activities, and its own 

counter-IED projects. However, while this system contains information 

that could be used to identify individual initiatives, it does not 

automatically separate costs directly expended on counter-IED initiatives 

from JIEDDO’s overhead and infrastructure costs such as facilities, 

contractor support, pay and benefits, and travel. Consequently, this 

system does not provide an automated means to comprehensively and 

rapidly identify and list all of JIEDDO’s counter-IED initiatives. Further, 

even if it did collect this information, the system is limited to JIEDDO, and 

therefore would not include a comprehensive listing of other DOD efforts 

outside of JIEDDO. However, 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. This 

effort is in the conceptualization stage, and JIEDDO officials do not 

anticipate completion before the end of fiscal year 2012. Further, JIEDDO 

does not have an implementation plan that includes a detailed timeline 

with milestones to help track its progress in achieving this goal.

Without a comprehensive listing of counter-IED initiatives, DOD 

components may be unaware of the total spectrum of counter-IED efforts 

within the department, and thereby continue to independently pursue 

counter-IED efforts that focus on similar technologies and may be 

duplicative. GAO identified three examples of potential duplication within 

DOD counter-IED efforts focusing on relatively high-cost areas.

• Counter-IED directed energy technology: The military services have 

developed six systems that emit energy directed at IEDs to neutralize 

them.3

 

3

The specific capability gap addressed by this technology is classified and therefore not 

discussed in this report. 

DOD has spent about $104 million collectively on these efforts 

to date. However, given the lack of a DOD-wide counter-IED 

database, there could be more directed energy efforts that GAO has 

not identified. Concerns regarding duplication in DOD’s directed 

energy efforts vis-à-vis counter-IEDs have risen to the highest levels 

within DOD’s warfighter community. Specifically, the commander of 

U.S. Central Command, in August 2011, conveyed concern regarding 

issues including apparent “duplicity of (development) effort” in directed 

energy technology with organizations (in DOD) working different 

solutions. The correspondence called for coordination and 

cooperation by DOD on its directed energy efforts to develop a 

directed energy system that works in theater as quickly as possible 

given that the development has been under way since 2008. In 

response in August 2011, JIEDDO, as DOD’s coordinating agency for 

these efforts, developed a plan and, in September 2011, brought 

various service program offices together to develop a solution as soon 

as possible. According to JIEDDO officials, the six systems will 
 

Page 35 GAO-12-342SP Duplication, Overlap, and Fragmentation 

continue in development through fiscal year 2012, at which point, 

JIEDDO will determine which of the systems best satisfies U.S. 

Central Command’s requirement. While this new approach may 

eliminate future unnecessary duplication of effort, earlier coordination 

and better visibility could have prevented duplication that may have 

occurred up to this point.

• Radio-frequency jamming systems: The Army and Navy continue to 

pursue separate development of counter-IED jamming systems, which 

provide a limited radius of protection to prevent IEDs from being 

triggered by an enemy’s radio signals. In 2007, DOD established the 

Navy as the single manager and executive agent for ground-based 

jamming.4

In 2010, according to Navy officials, the Army continued to develop 

new technology for insertion into its Duke system—expected to cost 

about $1.062 billion when completed and installed—without notifying 

and coordinating with the Navy. According to Army officials, the Army 

is pursuing development of its own system because it intends to 

expand the use of this technology for purposes other than countering 

IEDs, such as jamming enemy command, control, and communication 

systems. However, according to Navy officials, the CREW system’s 

technology has the flexibility and capacity to expand and provide the 

same additional functions as the Army plans for its Duke system. 

Moreover, according to Navy officials, the Navy’s system is further 

along in its development. Because the Navy and Army are pursuing 

separate jamming systems, it is not clear if DOD is taking the most 

cost-effective approach. While, according to JIEDDO officials, the 

Office of the Secretary of Defense was considering how to resolve this 

issue, a decision had not been made before GAO’s report was 

completed. Regardless of the final outcome, however, a more 

coordinated approach early in the process when initiating programs of 

this magnitude could prevent unnecessary duplication in costs and 

effort.

Under DOD Directive 5101.14, military services may 

conduct ground-based jammer research and development to satisfy 

military service-unique requirements if the requirements are 

coordinated before initiation with the DOD’s single manager for 

jammers and, for any system or system modifications resulting from 

such efforts, operational technical characteristics and logistics plans are 

approved by the single manager. The Navy has developed a standard 

technology and system for ground-based jamming called JCREW I1B1, 

which DOD has designated as the ground-based jamming program for 

the entire department. However, the Army has continued to develop its 

own ground-based jamming system called Duke.

 

4

See Department of Defense Directive 5101.14, DoD Executive Agent and Single 

Manager for Military Ground-Based Counter Radio-Controlled Improvised Explosive 

Device Electronic Warfare (CREW) Technology, ¶ 5.3.1 (June 11, 2007) (requiring the 

Secretary of the Navy to designate a single manager).
 

Page 36 GAO-12-342SP Duplication, Overlap, and Fragmentation 

• Electronic data collection systems: According to JIEDDO officials, 

JIEDDO has funded the development and support of approximately 

70 electronic data collection and analysis tools that overlap to some 

degree because they include capabilities to collect, analyze, and store 

data to help the warfighter combat the IED threat. Although JIEDDO 

recently reported that it could not verify total funding for its information 

technology investments,5

According to JIEDDO officials, JIEDDO is aware of the redundancy 

within these electronic tools. In April 2011, the JIEDDO Deputy 

Director for Information Management raised the issue of redundancy 

in JIEDDO’s information technology systems, including its counterIED data collection and analysis systems and tools. Consequently, 

since April 2011, JIEDDO has worked to eliminate overlapping 

information technology capabilities where feasible, including among 

the approximately 70 analytical tools JIEDDO has funded and 

developed for use in countering IED networks. For example, on July 

1, 2011, JIEDDO discontinued funding for one of these initiatives—

Tripwire Analytical Capability—citing as reasons the initiative’s limited 

purpose, high cost, and duplicative capabilities.

GAO determined through a review of DOD 

financial records that the department has expended at least $184 

million collectively on information technology development for its data 

collection and analysis tools.

However, in making its decision to discontinue the Tripwire Analytical 

Capability, yet continue operating the other data collection and 

analysis tools, JIEDDO had not compared and quantified all of the 

potential options to streamline or consolidate these tools to create a 

single, collective system that includes extracting data on counter-IED 

efforts across DOD. As a result, JIEDDO cannot be certain it is 

pursuing the most advantageous approach for collecting, analyzing, 

storing, and using available data for combating the IED threat. 

Further, although JIEDDO has discontinued funding the Tripwire 

Analytical Capability, the Defense Intelligence Agency is continuing to 

develop the tool for its own use, resulting in the potential for DODwide duplication between the Tripwire Analytical Capability and 

JIEDDO’s other data collection and analysis tools.

These above three examples of potential duplication are based on GAO’s 

examination of selected efforts identified during its review of DOD’s 

progress in developing a comprehensive DOD-wide counter-IED 

database. However, given the continued absence of a database and a 

process to identify and reduce duplication in DOD’s counter-IED efforts, 

the potential exists for additional cases of duplication.

 

5

Joint Improvised Explosive Device Defeat Organization Office of Internal Review, Joint 

Improvised Explosive Device Defeat Organization: Information Technology Investment 

Management, Report of Audit 2011-07-002 (September 6, 2011). 
 

Page 37 GAO-12-342SP Duplication, Overlap, and Fragmentation 

To improve visibility of its collective counter-IED expenditures and 

investments, GAO has in prior years recommended that DOD develop a 

database of all department-wide counter-IED efforts. However, after 

expending billions of dollars on developing counter-IED capabilities, DOD 

has not made progress in establishing such a database. Consequently, 

GAO recommended in February 2012 that DOD should 

 develop an implementation plan, including a detailed timeline with 

milestones to help achieve this goal; and 

 develop a process to use this database once it is established to 

identify and reduce duplication, overlap, and fragmentation among its 

counter-IED initiatives. 

It is essential that DOD follow-through in implementing GAO’s 

recommendations to address the risk of duplication in its multibillion-dollar 

counter-IED expenditures and investments. Given that JIEDDO and other 

DOD organizations have spent billions of dollars on counter-IED efforts, 

cost savings could be significant should DOD focus on reducing 

duplication across its counter-IED efforts. 

GAO provided a draft of its February 2012 report to DOD for review and 

comment. DOD agreed with GAO’s recommendation to develop an 

implementation plan for the establishment of DOD’s counter- IED 

database. The department did not agree with the recommendation to 

develop a means to identify and reduce any duplication, overlap, and 

fragmentation among counter-IED initiatives, stating that it had existing 

processes to facilitate coordination and collaboration with the military 

services and across DOD, which would address this recommendation. 

GAO agrees that existing DOD processes such as JIEDDO’s Capabilities 

Development Process and DOD’s Senior Integration Group prioritization 

process can be helpful in coordinating DOD’s counter-IED efforts. 

However, the effectiveness of these processes has been limited given 

that they did not prevent the instances of potential duplication GAO 

identified. For example, in the case of DOD’s directed energy counter-IED 

efforts where DOD has collectively expended $104 million, the processes 

cited by DOD in its response did not identify and resolve the potential 

duplication present in these efforts. As a result the commander of U.S. 

Central Command, as mentioned previously, protested in writing to DOD 

officials about potential duplication of efforts. Without a process to use 

DOD’s counter-IED database, once it is developed, DOD will continue to 

lack assurance that it is identifying and addressing instances of potential 

duplication before making significant investments. In finalizing its 

February 2012 report, GAO modified the wording of the recommendation 

to clarify the intent that DOD establish a process to use its counter-IED 

data base once it is established. 

Actions Needed and 

Potential Financial or 

Other Benefits 

Agency Comments 

and GAO’s Evaluation 
 

Page 38 GAO-12-342SP Duplication, Overlap, and Fragmentation 

The information contained in this analysis is based on findings from the 

products in the related GAO products section. GAO reviewed JIEDDO 

databases on counter-IED efforts and interviewed DOD, military service, 

and JIEDDO officials to determine the degree of comprehensive visibility 

regarding DOD’s counter-IED efforts. GAO identified and evaluated 

examples of potential duplication using information from interviews with 

DOD officials and data and documentation collected that evidenced 

similar capabilities and objectives among two or more counter-IED efforts.

Warfighter Support: DOD Needs Strategic Outcome-Related Goals and 

Visibility Over Its Counter-IED Efforts. GAO-12-280. Washington, D.C.:

February 22, 2012.

Warfighter Support: DOD’s Urgent Needs Processes Need a More 

Comprehensive Approach and Evaluation for Potential Consolidation.

GAO-11-273. Washington, D.C.: March 1, 2011.

Warfighter Support: Actions Needed to Improve Visibility and 

Coordination of DOD’s Counter-Improvised Explosive Device Efforts.

GAO-10-95. Washington, D.C.: October 29, 2009.

Warfighter Support: Challenges Confronting DOD’s Ability to Coordinate 

and Oversee Its Counter-Improvised Explosive Devices Efforts. 

GAO-10-186T. Washington, D.C.: October 29, 2009.

Defense Management: More Transparency Needed over the Financial 

and Human Capital Operations of the Joint Improvised Explosive Device 

Defeat Organization. GAO-08-342. Washington, D.C.: March 6, 2008.

For additional information about this area, contact Cary B. Russell at 

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

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 39 GAO-12-342SP Duplication, Overlap, and Fragmentation 

5. Defense Language and Culture Training

The Department of Defense needs a more integrated approach to reduce fragmentation in training approaches 

and overlap in the content of training products acquired by the military services and other organizations. 

Due to changes in the global security environment and operational 

experiences such as those in Afghanistan and Iraq, the Department of 

Defense (DOD) has emphasized the importance of developing language 

skills and knowledge of foreign cultures within its forces to meet the 

needs of current and future military operations. Traditionally, DOD has 

focused on its professional communities of linguists and regional experts 

to ensure that it has the language and culture capabilities it needs. In 

recent years, the department has identified the need to build these 

capabilities within the general purpose forces and has spent considerable 

time and resources to establish language- and culture-related plans,

organizations, and activities.1

Specifically, DOD has invested millions of dollars to provide language and 

culture training to thousands of servicemembers, including those 

deploying to ongoing operations. For example, GAO estimated that DOD 

invested about $266 million for fiscal years 2005 through 2011 to provide 

general purpose forces with training support, such as classroom 

instruction, computer-based training, and training aids. Since 2009, GAO 

has reported on management challenges that DOD faces in developing 

language and culture capabilities, indicating that opportunities exist for 

DOD to approach its language and culture training efforts more efficiently.

As GAO reported in May 2011, language and culture training within DOD 

is not provided through a single department- or servicewide program, but 

rather multiple DOD organizations oversee the development and 

acquisition of language and culture training and related products and 

deliver training. However, GAO has found that the department lacks an 

approach for integrating these efforts, which has contributed to some 

fragmentation of service training efforts and overlap and potential 

duplication in some of the language and culture training products 

acquired by the services.

To establish organizational responsibility for language- and culturerelated efforts, DOD has established the Defense Language Office and 

designated Senior Language Authorities within the Office of the Secretary 

 

1

General purpose forces are the regular armed forces of a country, other than nuclear 

forces and special operations forces, that are organized, trained, and equipped to perform 

a broad range of missions across the range of military operations.

Why This Area Is 

Important

What GAO Found
 

Page 40 GAO-12-342SP Duplication, Overlap, and Fragmentation 

of Defense, the Joint Staff, and the military services.2

In the absence of an integrated approach, GAO found that DOD has not 

approached its language and culture training efforts in an efficient 

manner. In particular, DOD and the military services have not yet reached 

agreement on the common language and cultural skills that general 

purpose forces need to acquire. Without such an agreement, each 

military service has developed an individualized approach for language 

and culture training that varies in the amount, depth, and breadth of 

training. Moreover, DOD did not have a process to coordinate training 

requirements for ongoing operations, and therefore multiple organizations 

independently established varying language and culture training 

requirements. As a result, the services have expended considerable time 

and resources adjusting their language and culture training plans.

 Each military 

service has a dedicated organization that provides culture and, in some 

cases, language training to its respective forces, while the Defense 

Language Institute Foreign Language Center also provides language 

training to each of the services’ forces. GAO also reported that the Office 

of the Secretary of Defense had not yet established internal mechanisms 

to assist the department in reaching consensus with the military services 

and other DOD entities on training priorities, synchronize the 

development of service- and departmentwide plans with the budget 

process, and guide efforts to monitor progress.

In addition, the military services have not fully coordinated efforts to 

develop and acquire language and culture training products. As a result, 

the services have acquired overlapping and potentially duplicative 

products, such as reference materials containing country- or regionspecific cultural information and computer software or web-based training 

programs that can be used within a distributed learning training 

environment.3 GAO previously reported that when assessing delivery 

options for training, agencies may achieve economies of scale and avoid 

duplication of effort by taking advantage of existing training content, such 

as sharable online courseware.4

 

2

The Defense Language Office, within the Office of the Under Secretary of Defense for 

Personnel and Readiness, provides strategic direction and programmatic oversight to the 

DOD components, including the services and combatant commands, on present and 

future requirements related to language, as well as on regional and cultural proficiency. 

The office’s director reports to the Deputy Assistance Secretary of Defense for Readiness, 

who has been designated as the DOD Senior Language Authority.

However, GAO found that 

departmentwide working groups existed but had not been formally 

designated with the responsibility to develop training products that can be 

3

DOD defines distributed learning as structured learning mediated with technology that 

does not require the physical presence of the instructor. Distributed learning models can 

be used in combination with other forms of instruction or it can be used to create wholly 

virtual classrooms.

4

GAO, Human Capital: A Guide for Assessing Strategic Training and Development Efforts 

in the Federal Government, GAO-04-546G (Washington, D.C.: March 2004).
 

Page 41 GAO-12-342SP Duplication, Overlap, and Fragmentation 

used by more than one service. In practice, while GAO found some 

individual examples where the services had coordinated efforts to 

develop or contract for similar language and culture training products, in 

most cases they did not take steps to coordinate these types of efforts. 

To illustrate, GAO analyzed 18 DOD language and culture training 

products and found that the content overlapped to some extent with at 

least one other training product. While all of the products are intended for 

use by the services’ general purpose forces, there is some variance in the 

amount of language and cultural information contained within each 

product type. The following describes instances in which DOD might have 

increased training costs by developing or acquiring overlapping and 

potentially duplicative training products:

• Cultural reference materials. Three of four services (the Air Force, Army, 

and Marine Corps) have used contractors to develop reference materials, 

such as “field guides” and “smart books” at a cost of about $1.6 million 

that contained similar general and country-specific cultural content. In 

addition, the Defense Language Institute Foreign Language Center has 

invested about $15 million to develop two products—”Countries in 

Perspective” and “Cultural Orientations”—that also offer country-specific 

cultural information, including some of the same countries addressed by 

the services’ products.

• Distributed learning products for culture training. According to service 

officials, DOD obligated about $15 million on contracts within the period 

of fiscal year 2008 through fiscal year 2010 for three computer software 

or web-based distributed learning culture training products (for the Air 

Force, the Army, and the U.S. Joint Forces Command) that provided 

overlapping cultural content and similar learning objectives. For example, 

each of the products contained training modules for Afghanistan with 

learning objectives focused on behaviors to show respect and steps to 

avoid gender taboos. The same subcontractor developed the Air Force’s 

and the Army’s products, and the products generally did not contain 

information that was unique to the services’ primary roles and missions. 

At the same time, the Joint Staff was also developing another product 

that provides similar content as the Air Force and Army products. 

• Distributed learning products for foreign language training. The military 

services (the Air Force, Army, Marine Corps, and Navy) and the Defense 

Language Institute Foreign Language Center estimated costs totaling 

about $63 million within the period of fiscal year 2005 through fiscal year 

2011 to develop and acquire multiple computer software or web-based 

distributed learning foreign language products that offered some 

overlapping foreign languages. For Afghan languages, DOD invested in 

at least five products that were intended to build basic foreign language 

skills or specific language skills needed to perform military tasks.
 

Page 42 GAO-12-342SP Duplication, Overlap, and Fragmentation 

DOD has taken positive steps, but has not fully addressed the 

recommendations that GAO has made since 2009 regarding 

management challenges that can cause inefficiencies in DOD efforts to 

develop language and culture capabilities. For example, in February 

2011, DOD published the Department of Defense Strategic Plan for 

Language Skills, Regional Expertise, and Cultural Capabilities 

(2011-2016), but it still needs to take additional action. GAO 

recommended in May 2011 that the Office of the Under Secretary of 

Defense for Personnel and Readiness

• establish a clearly defined planning process with mechanisms, such as 

procedures and milestones, for reaching consensus with the military 

departments; coordinating and reviewing approval of updates to plans; 

synchronizing the development of plans with the budget process; 

monitoring the implementation of initiatives, and reporting progress, on a 

periodic basis, toward the achievement of established goals.

Further, DOD published a September 2010 training strategy that called 

for eliminating unnecessary redundancy and duplication and leveraging 

the investments of stakeholders with similar interests to include identifying 

opportunities for shared use across DOD entities.5

• designate organizational responsibility and a supporting process to 

inventory and evaluate existing language and culture products and plans 

for additional investments, eliminate any unnecessary overlap and 

duplication, and adjust resources accordingly.

In one case, GAO 

identified actions that the Army and Marine Corps took to achieve 

efficiencies and save costs by reducing the number of contracts for 

language training products. DOD could also take steps to achieve greater 

efficiencies and maximize the use of resources by identifying and 

reducing any unnecessary overlap and duplication in language and 

culture training products. Specifically, the Office of the Under Secretary of 

Defense for Personnel and Readiness and the military services should

• take steps to coordinate efforts to contract for future language and culture 

training products where possible and collaborate on the development of 

new products that support co-use by more than one military service.

Because multiple DOD organizations have responsibilities for planning 

and developing language- and culture-related training, and budget and 

cost information is not captured in a centralized manner, determining 

definitive costs in this area is challenging. GAO was able to determine 

that DOD is spending millions of dollars to develop and acquire language 

and culture training products and deliver related training, but cannot 

quantify the actual cost of the overlap within the language and culture 

training products GAO identified due to these data limitations. However, 

 

5

Department of Defense, Strategic Plan for the Next Generation of Training for the 

Department of Defense (Sept. 23, 2010). 

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 43 GAO-12-342SP Duplication, Overlap, and Fragmentation 

based on the level of investments that GAO could determine that DOD is 

making, it appears that DOD has opportunities to achieve significant cost 

savings if it implements the actions outlined above.

GAO provided a draft of this report section to DOD for review and 

comment. DOD provided technical comments, which were incorporated 

as appropriate. DOD officials generally agreed with the facts and findings 

of the analysis. Specifically, officials recognized that coordination is 

important and noted that DOD entities have, in some specific cases, 

collaborated on the development of language and culture training 

products. The officials agreed that departmentwide coordination efforts 

could be improved and noted that GAO’s analysis would be useful in 

targeting specific areas for improvement. DOD officials also noted that a 

certain degree of overlap among training products can serve to prevent 

gaps and accommodate the differing missions and training needs of the 

military services. However, DOD officials recognized that, to avoid 

duplication and maximize available resources, the department needs to 

evaluate its existing language and culture training products and plans for 

future investments to ensure that limited resources are being utilized on 

quality products. GAO recognizes that some overlap in training products 

may be warranted to meet the unique mission needs of the military 

services, but by establishing an integrated approach, the department 

would be better positioned to reach consensus with the military services 

on the language and culture skills needed by general purpose forces as 

well as the content of related training products. Such an approach would 

also assist the department in evaluating the overlap in existing language 

and culture training products and eliminating any unnecessary 

duplication. As part of its routine audit work, GAO will track the extent to 

which progress has been made to address the identified actions and 

report to Congress. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted. GAO examined language and culture training 

investments for general purpose forces; missions, roles, and 

responsibilities among key DOD organizations involved in language and 

culture training; and the content of language and culture training products. 

GAO reviewed key documents, such as directives and training programs 

of instruction; analyzed language and culture products used to train 

general purpose forces; and interviewed relevant DOD and service 

officials. GAO obtained and analyzed budgetary and contracting 

information, where available, for language and culture training support 

provided to DOD’s general purpose forces. For example, GAO estimated 

the costs for this training for fiscal years 2005 through 2011. 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 44 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Language and Culture Training: Opportunities Exist to Improve Visibility 

and Sustainment of Knowledge and Skills in Army and Marine Corps 

General Purpose Forces. GAO-12-50. Washington. D.C.: October 31, 

2011.

Military Training: Actions Needed to Improve Planning and Coordination 

of Army and Marine Corps Language and Culture Training. GAO-11-456. 

Washington, D.C.: May 26, 2011. 

Military Training: Continued Actions Needed to Guide DOD’s Efforts to 

Improve Language Skills and Regional Proficiency. GAO-10-879T. 

Washington, D.C.: June 29, 2010.

Military Training: DOD Needs a Strategic Plan and Better Inventory and 

Requirements Data to Guide Development of Language Skills and 

Regional Proficiency. GAO-09-568. Washington, D.C.: June 19, 2009.

For additional information about this area, contact Sharon Pickup at (202) 

512-9619 or pickups@gao.gov. 

Related GAO 

Products 

Contact Information
 

Page 45 GAO-12-342SP Duplication, Overlap, and Fragmentation 

6. Stabilization, Reconstruction, and 

Humanitarian Assistance Efforts

Improving the Department of Defense’s evaluations of stabilization, reconstruction, and humanitarian 

assistance efforts, and addressing coordination challenges with the Department of State and the U.S. Agency 

for International Development, could reduce overlapping efforts and result in the more efficient use of 

taxpayer dollars.

The Department of Defense (DOD), Department of State (State), and the 

U.S. Agency for International Development (USAID) have been heavily 

involved in stabilization and reconstruction efforts in both wartime and 

peacetime environments to re-establish security, strengthen governance, 

rebuild infrastructure, and improve social and economic well-being in 

foreign countries. These efforts have cost the U.S. government a 

substantial amount of money—about $72 billion since 2002 for programs 

to secure, stabilize, and develop Afghanistan, and about $62 billion since 

2003 for relief and reconstruction in Iraq. DOD’s role in stabilization and 

reconstruction efforts has increased, with several new programs 

emerging in recent years, including the Commander’s Emergency 

Response Program (CERP), DOD’s Task Force for Business and Stability 

Operations, and the Afghanistan Infrastructure Fund. DOD’s efforts are 

often similar in nature to State and USAID efforts, and thus interagency 

coordination is critical for avoiding unnecessary overlap, wasted 

resources, or fragmentation.

DOD has been conducting stabilization and reconstruction efforts that are 

similar to those of USAID and State; and the three agencies face 

challenges in project evaluation and information sharing which, if not 

addressed, could result in the potential for unnecessary overlap, wasted 

resources, and a fragmented approach to U.S. assistance efforts.

As the table below illustrates, DOD has expanded its programs over the 

past several years. In fiscal year 2011, Congress made available a total 

of $950 million for CERP, DOD’s Task Force for Business and Stability 

Operations, and the Afghanistan Infrastructure Fund. State and USAID 

have also pursued a variety of efforts to help rebuild Afghanistan, 

including projects to construct roads, develop water and electrical 

infrastructure, and build the capacity of its government. In Iraq, State and 

USAID projects have involved education, health, water and sanitation 

facilities, and building the capacity of the Iraqi ministries. Outside of Iraq 

and Afghanistan, funding for DOD’s peacetime humanitarian assistance 

efforts has also increased.

Why This Area Is 

Important

What GAO Found
 

Page 46 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Key DOD Stability, Reconstruction, and Humanitarian Assistance Efforts 

Program (Key agencies involved) Description 

Estimated program 

funding 

Commander’s Emergency Response 

Program (CERP)

(DOD)

This program began in 2003 and has enabled commanders to 

respond to urgent humanitarian relief and reconstruction needs in 

Iraq, Afghanistan, and the Philippines. It has evolved in terms of 

project cost and complexity. Projects include new construction or 

rehabilitation of existing infrastructure, ranging from small scale 

projects like water wells to dormitories and roads. DOD uses 

some CERP funds to increase agricultural production with 

projects focused on irrigation systems, wells, and ditches; canal 

cleanup; and water sanitation. 

At least $7.9 billion made 

available for FYs 2004-

2011

Security and Stabilization Assistance 

Program (also known as the Section 

1207 Program)

(DOD, State)

Created in 2006, this program authorized DOD to transfer funds to 

State for nonmilitary assistance related to stabilization, 

reconstruction, and security. Activities could include removing 

unexploded ordnance or reforming extremist educational 

programs. The authority for the program expired in 2010, but 

Congress authorized a similar program for DOD and State in 

fiscal year 2012, called the Global Security Contingency Fund. 

Over $350 million 

provided by DOD to

State for FYs 2006-2009; 

at least $250 million 

made available in FY 

2012 for the new fund

Task Force for Business and Stability 

Operations

(DOD)

Established in June 2006, the Task Force supports economic 

stabilization efforts, first in Iraq and now in Afghanistan. Activities 

include developing businesses, creating jobs, and attracting 

foreign investment in sectors such as agriculture, energy, banking 

and finance, and communications and technology.

$828 million made 

available to the Task 

Force for FYs 2007-2012

Afghanistan Infrastructure Fund

(DOD, State)

Established in 2011, the fund supports a joint DOD/State program 

for high-priority, large-scale infrastructure projects that support the 

U.S. military-civilian effort in Afghanistan. 

$800 million for FYs 

2011-2013 

Peacetime Humanitarian Assistance 

Programs 

(DOD)

DOD’s two key programs are the Overseas Humanitarian, 

Disaster, and Civic Aid-funded humanitarian assistance program 

and the Humanitarian and Civic Assistance program. Activities, 

which are typically performed outside of war or disaster 

environments, include renovating schools and hospitals, drilling 

wells, providing basic health care, and providing training to 

prepare for natural disasters. From fiscal years 2005 through 

2010 DOD obligated about $328.4 million to support the Overseas 

Humanitarian, Disaster, and Civic Aid-funded humanitarian 

assistance program, which represented an increase in obligations 

of about 60 percent over the time period (figures in constant FY 

2011 dollars). 

$383 million obligated for 

FYs 2005-2010 outside 

of Iraq and Afghanistan 

Source: GAO analysis of data from DOD, the Special Inspector General for Afghanistan, relevant legislation, and GAO’s prior work.

Note: While direct comparison among dollar figures cannot be made, the table is intended to highlight 

examples of various programs and estimated funding associated with them. 

In some cases, especially during the early stages of a wartime 

environment, it may be advantageous for DOD to conduct stabilization 

and reconstruction efforts because it can provide its own security. 

However, questions have been raised as to DOD’s role in performing 

some of these efforts given that DOD efforts can overlap with those of 

State and USAID. For example, officials in State, USAID, and DOD have 

questioned whether DOD’s Task Force for Business and Stability 

Operations, which has funded economic stabilization efforts in Iraq and 

Afghanistan, should continue to reside in DOD or be transitioned to 

another federal agency, such as USAID, whose role includes providing 

economic, development, and disaster response assistance around the 

world in support of U.S. foreign policy and development goals. In 2011, 

Congress directed that State, USAID, and DOD jointly develop a plan to 
 

Page 47 GAO-12-342SP Duplication, Overlap, and Fragmentation 

transition the Task Force’s activities in Afghanistan to State, with a focus 

on potentially transitioning activities to USAID. To that end, DOD has 

requested that an outside organization conduct a study that would 

develop, describe, and assess organizational options for a continued 

Task Force for Business and Stability Operations for the U.S. government 

in Afghanistan through 2014 and beyond. According to the Task Force 

director, as of January 2012, the transition plan was still being developed 

and will incorporate the results of the outside study, which is due to be 

completed in February 2012.

As GAO reported in February 2012, some DOD humanitarian assistance 

efforts outside of Iraq and Afghanistan potentially overlap with those of 

State and USAID in areas such as health care, infrastructure, disaster 

preparation, and education. For example, both DOD and USAID have 

provided basic medical care in Yemen, built schools and education 

facilities in Azerbaijan, and upgraded and rehabilitated water wells in 

Pakistan. GAO found that it can be difficult to determine whether DOD’s 

projects necessarily or unnecessarily overlap with those of the other 

agencies and suggested that Congress consider the role of DOD in 

providing humanitarian assistance and clarify the relevant legislation of 

DOD’s largest humanitarian assistance program, taking into account the 

roles and similar types of efforts performed by the civilian agencies.1

In addition to potentially overlapping efforts, GAO also found that DOD, 

State, and USAID face challenges in monitoring and evaluating 

stabilization, reconstruction, and humanitarian assistance efforts—which 

makes it difficult to determine whether projects are effective at meeting 

their goals. According to Standards for Internal Control in the Federal 

Government,

2 U.S. agencies should monitor and assess the quality of 

performance over time, and GAO has reported that key practices for 

enhancing interagency collaboration include developing mechanisms to 

monitor, evaluate, and report on the results of collaborative programs.3

• As GAO reported in July 2011, DOD’s Task Force for Business and 

Stability Operations had not developed written guidance, including 

monitoring and evaluation processes, to be used by its personnel in 

managing Task Force projects. According to the Task Force director, 

program management guidance was issued in January 2012 to 

address this issue. While this is a positive step, until the guidance is 

However, several challenges exist with monitoring and evaluation, 

including:

 

1

DOD’s largest humanitarian assistance program is the Overseas Humanitarian, Disaster, 

and Civic Aid-funded humanitarian assistance program. 

2

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

(Washington, D.C.: November 1999). 

3

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 
 

Page 48 GAO-12-342SP Duplication, Overlap, and Fragmentation 

fully implemented, it is unknown whether improvements will be made 

to DOD’s project monitoring and evaluation.

• As GAO reported in February 2012, DOD was not consistently 

evaluating its peacetime humanitarian assistance efforts to determine 

whether they were meeting their intended goals. Specifically, GAO 

estimated that DOD had not completed 90 percent of evaluations 

required 1 year after projects were completed, and had also not 

conducted about half of the evaluations required after 30 days for 

those programs. GAO also found that DOD had not assessed its 

evaluation process or requirements to determine whether changes 

were needed to employ a more risk-based evaluation approach in 

order to strategically allocate resources.

Another theme that has emerged from GAO’s work relates to challenges 

the agencies face in sharing information with each other about their 

respective efforts. Information sharing is a critical tool in national security, 

but GAO’s work has shown several instances of fragmented information 

sharing among DOD, State, and USAID that could lead to poor 

coordination, wasted resources, and potentially duplicative efforts. For 

example:

• As GAO reported in November 2010, USAID had not fully 

implemented a centralized database to provide information on all U.S. 

government development projects in Afghanistan—a challenge that is 

still not fully resolved. Thus, U.S. agencies lacked access to project 

data from other agencies, including DOD, that could contribute to 

better project planning, eliminate potential overlap, and allow 

agencies to leverage each other’s resources more effectively.

• As GAO reported in February 2012, DOD, State, and USAID had 

various initiatives under way to improve information sharing on 

humanitarian and development assistance efforts outside of Iraq and 

Afghanistan but that no framework, such as a common database, 

existed to enable agencies to readily access information on each 

other’s efforts to help them leverage these efforts and to avoid 

unnecessary overlap. The agencies agreed, stating that they are or 

will be engaging each other to determine how best to develop a 

common information-sharing mechanism.

Without enhancements to information sharing, agencies do not have full 

visibility over each other’s efforts, which could lead to “stove-piped” 

agency planning, potential for overlap, and an inefficient use of resources. 

Moreover, improved information sharing could identify opportunities for 

synergy and avoid potential duplication among agencies.
 

Page 49 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Stabilization, reconstruction, and humanitarian assistance efforts have the 

potential to provide tangible benefits to foreign populations and advance 

U.S. interests. While the agencies have taken steps to address some of 

GAO’s recommendations, additional actions are still needed to improve 

information sharing and project evaluations.

USAID, along with DOD and other relevant agencies still need information 

on all U.S. government development projects in Afghanistan. Progress 

has been made, but further effort is needed to ensure that information is 

accessible and used by all U.S. government agencies involved in U.S.-

funded development projects in the country. 

As GAO recommended in February 2012, the Secretaries of Defense and 

State as well as the Administrator of USAID should

• jointly develop a framework, such as a common database, to 

formalize their information sharing on humanitarian or development 

assistance efforts outside of wartime or disaster environments.

As GAO recommended in February 2012, the Secretary of DOD should 

also

• employ a risk-based approach to review and modify its humanitarian 

assistance project evaluation requirements to measure the long-term 

effects of the projects.

Congress may wish to consider DOD’s role in conducting peacetime 

humanitarian assistance efforts. As GAO recommended in February 

2012, Congress should

• consider amending the legislation that supports the Overseas 

Humanitarian, Disaster, and Civic Aid-funded humanitarian assistance 

program—DOD’s largest humanitarian assistance program—to more 

specifically define DOD’s role in humanitarian assistance, taking into 

account the roles and similar types of efforts performed by the civilian 

agencies.

Addressing these issues could lead to a more efficient use of the billions 

of dollars devoted to U.S. stabilization and reconstruction efforts abroad.

GAO provided a draft of its November 2010 report to DOD and USAID 

and its February 2012 report to DOD, State, and USAID for review and 

comment. DOD and USAID generally agreed with GAO’s November 2010 

recommendations to improve planning and coordination of water sector 

projects in Afghanistan, with DOD noting that a centralized U.S. 

government database for U.S. development efforts in Afghanistan, if 

designed to allow easy data access and sharing among partners, would 

make a positive contribution. GAO notes that progress has been made in 

designating a database since GAO’s report was issued but that the 

agencies need to ensure that the database is accessible and used by all 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 50 GAO-12-342SP Duplication, Overlap, and Fragmentation 

U.S. government agencies involved in U.S.-funded development projects 

in Afghanistan.

DOD generally agreed with GAO’s February 2012 recommendations to 

review and modification project evaluation requirements for its peacetime 

humanitarian assistance efforts to measure long-term effects and ensure 

compliance with the requirements. DOD noted that it is developing an 

appropriate method to encourage compliance with the new project 

evaluation requirements. However, as noted earlier, DOD acknowledged 

that the absence of project evaluation data will require that it take at least 

a year to collect data in order to formulate a significant and reliable riskbased approach to project evaluations requirements.

DOD, State, and USAID agreed with GAO’s February 2012 

recommendation that they should jointly develop a framework to 

formalizing their information sharing on peacetime humanitarian and 

development assistance efforts. DOD stated that it will engage State and 

USAID to determine what mechanisms could be used to enhance 

information sharing among the agencies. State noted that it is currently in 

discussions with DOD and USAID about broadening one particular 

information-sharing mechanism it uses to include DOD efforts, and 

USAID said that it will continue to explore opportunities to share 

information with the other agencies. As part of its routine audit work, GAO 

will track agency actions to address the extent to which progress has 

been made to address the identified actions and report to Congress. 

The information contained in this analysis is based on findings from the 

products in the related GAO products section. GAO generally analyzed 

agency documentation and interviewed cognizant agency officials. For 

example, GAO interviewed DOD and USAID officials, including Army 

units that had returned from Afghanistan about the type of management 

and oversight that exists for CERP. GAO analyzed documents and 

interviewed officials in Washington, D.C., Afghanistan, and Iraq as 

appropriate. GAO analyzed funding, project evaluations, and other 

program data and documents, and interviewed officials at DOD, State, 

USAID, nongovernmental organizations, and U.S. embassies. 

Humanitarian and Development Assistance: Project Evaluations and 

Better Information Sharing Needed to Manage the Military’s Efforts. 

GAO-12-359. Washington, D.C., February 8, 2012.

Afghanistan’s Donor Dependence. GAO-11-948R. Washington, D.C., 

September 20, 2011.

DOD Task Force for Business and Stability Operations: Actions Needed 

to Establish Project Management Guidelines and Enhance Information 

Sharing. GAO-11-715. Washington, D.C.: July 29, 2011.

How GAO Conducted 

Its Work

Related GAO 

Products 
 

Page 51 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Afghanistan: Actions Needed to Improve Accountability of U.S. 

Assistance to Afghanistan Government. GAO-11-710. Washington, D.C.: 

July 20, 2011.

Afghanistan Development: U.S. Efforts to Support Afghan Water Sector 

Increasing, but Improvements Needed in Planning and Coordination. 

GAO-11-138. Washington, D.C.: November 15, 2010.

International Security: DOD and State Need to Improve Sustainment 

Planning and Monitoring and Evaluation for Section 1206 and 1207 

Assistance Programs. GAO-10-431. Washington, D.C.: April 15, 2010.

Military Operations: Actions Needed to Improve Oversight and 

Interagency Coordination for the Commander’s Emergency Response 

Program in Afghanistan. GAO-09-615. Washington, D.C.: May 18, 2009.

Interagency Collaboration: Key Issues for Congressional Oversight of 

National Security Strategies, Organizations, Workforce, and Information 

Sharing. GAO-09-904SP. Washington, D.C. September 25, 2009.

Military Operations: Actions Needed to Better Guide Project Selection for 

Commander’s Emergency Response Program and Improve Oversight in 

Iraq. GAO-08-736R. Washington, D.C.: June 23, 2008.

For additional information about this area, contact John H. Pendleton at 

(202) 512-3489 or pendletonj@gao.gov Contact Information
 

Page 52 GAO-12-342SP Duplication, Overlap, and Fragmentation 

7. Support for Entrepreneurs

Overlap and fragmentation among the economic development programs that support entrepreneurial efforts 

require OMB and other agencies to better evaluate the programs and explore opportunities for program 

restructuring, which may include consolidation, within and across agencies.

Economic development programs that effectively provide assistance to 

entrepreneurs may help businesses develop and expand, and thus 

contribute to the nation’s economic growth. The Departments of 

Commerce (Commerce), Housing and Urban Development (HUD), and 

Agriculture (USDA), and the Small Business Administration (SBA) 

administer 53 such programs that focus on supporting entrepreneurs.1

These programs, which typically fund a variety of activities in addition to 

supporting entrepreneurs, spent an estimated $2.6 billion in enacted 

appropriations on economic development efforts in fiscal year 2010.2

As GAO reported in March and May 2011, the majority of the economic 

development programs had missions related to supporting entrepreneurs. 

Programs with overlapping missions can result in inefficiencies, such as 

requiring recipients to fill out applications to multiple agencies with varying 

program requirements, as well as compromising the government’s ability 

to effectively provide the desired service and meet the shared goals of the 

programs. While collaboration is one way to overcome overlap among 

agencies when providing similar services, opportunities for program 

restructuring, which include consolidation, may also exist. GAO has 

ongoing work that will be issued later this year to continue examining 

issues beyond those identified in the March and May 2011 reports. This 

document reports GAO’s findings to date.

 

1

The number of programs administered by Commerce, HUD, SBA, and USDA that were 

identified in GAO-11-477R as supporting entrepreneurial efforts decreased from 54 to 53 

because Commerce merged its Minority Business Opportunity Center program and 

Minority Business Enterprise Center program into one program that is now called Minority 

Business Center. In addition, two of the original Commerce programs identified in GAO’s 

March and May 2011 reports—Community Trade Adjustment Assistance and Research 

and Evaluation—have been replaced with two other Commerce programs—Trade 

Adjustment Assistance for Firms and the Economic Development-Support for Planning 

Organizations—because one of the original programs had temporary funding and the 

other original program was misclassified as an economic development program. The two 

new Commerce programs that have been added should have been included in the March 

and May 2011 reports, according to Commerce officials. See appendix III for a list of the 

53 programs GAO is currently reviewing that support entrepreneurs and their 2010 

enacted appropriations.

2

GAO excluded the portion of the Community Development Block Grant funding that HUD 

reported is not used to support economic development. The total enacted appropriations 

for these 53 programs was about $5.6 billion for fiscal year 2010.

Why This Area Is 

Important
 

Page 53 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Based on a review of the missions and other related program information 

for these 53 programs, GAO determined that these programs overlap 

based not only on their shared purpose of serving entrepreneurs but also 

on the type of assistance they offer. The programs generally can be 

grouped according to at least one of three types of assistance that 

address different entrepreneurial needs: help obtaining (1) technical 

assistance, (2) financial assistance, and (3) government contracts. Many 

of the programs can provide more than one type of assistance, and most 

focus on technical and/or financial assistance:3

• Technical assistance: Thirty-six programs distributed across the four 

agencies provide technical assistance, including business training and 

counseling and research and development support.

• Financial assistance: Thirty-three programs distributed across the four 

agencies support entrepreneurs through financial assistance in the 

form of grants and loans. 

• Government contracting assistance: Seven programs distributed 

between two of the four agencies support entrepreneurs by helping 

them qualify for federal procurement opportunities. 

The table below illustrates overlap among programs that provide 

entrepreneurial assistance in terms of the type of assistance they provide. 

For example, 13 programs across 3 of the agencies provide financial 

assistance only. SBA and USDA both have 5 programs that only provide 

financial assistance, while HUD has 3.

53 Programs That Support Entrepreneurs, by Type of Assistance, as of 

September 30, 2011a

HUD SBA USDA Commerce Totalb

Technical assistance only 2 6 5 4 17

Financial assistance only 3 5 5 13

Technical and financial assistance only 7 3 4 2 16

Government contracting assistance only 2 2 

Technical and government contracting only 1 1 

Financial and government contracting only 2 2 

Technical, financial, and government 

contracting assistance 

2 2 

Total 12 19 14 8 53

Source: GAO analysis of information provided by Commerce, HUD, USDA, and SBA.

 

3

SBA administers the two programs that solely provide entrepreneurs with assistance in 

obtaining government contracts: the HUBZone program, which supports small businesses 

located in economically distressed areas, and the Procurement Assistance to Small 

Businesses program, which serves small businesses located in any area.

What GAO Found
 

Page 54 GAO-12-342SP Duplication, Overlap, and Fragmentation 

a

Some of the programs may not have received funding in fiscal year 2011. 

b

The 36 technical assistance programs include those in the following categories: technical assistance 

only; technical and financial assistance only; technical, financial, and government contracting 

assistance; and technical and government contracting assistance only. The 33 financial assistance 

programs include those in the following categories: financial assistance only; technical and financial 

assistance only; technical, financial, and government contracting assistance; and financial and 

government contracting assistance only. The seven government contracting assistance programs 

include those in the following categories: government contracting assistance only, technical and 

government contracting assistance only, financial and government contracting assistance only, and 

technical, financial, and government contracting assistance. 

Much of the overlap and fragmentation among these 53 programs is 

concentrated among programs that support economically distressed and 

disadvantaged areas and programs that assist disadvantaged and small 

businesses. As the figure below shows, of the 36 programs that provide 

technical assistance (that is, programs that either provide only technical 

assistance or those that provide technical assistance in addition to 

financial and government contracting assistance),

• Commerce’s Economic Development/Technical Assistance program 

and SBA’s 7(j) Technical Assistance program are among the 33 

programs that assist businesses located in economically distressed 

areas.4

• HUD’s Hispanic Serving Institutions Assisting Communities and 

USDA’s Rural Business Opportunity Grants programs are among the 

23 that can assist businesses operating in areas that are 

disadvantaged,5

• SBA’s Small Business Development Centers and Commerce’s 

Minority Business Centers are among the 27 programs that support 

disadvantaged businesses,6

• USDA’s Rural Business Enterprise Grant program and SBA’s 8(a) 

program are among the 32 programs that serve small businesses.

and

Overlap and fragmentation are also evident among programs that provide 

more specific forms of assistance. For example, technical assistance 

programs that provide business training and counseling include SBA’s 

Small Business Development Centers, Women’s Business Centers, 

SCORE (formerly, Senior Core of Retired Executives) programs; 

Commerce’s Minority Business Centers program; and USDA’s Rural 

Business Enterprise Grants program. In addition, many of these 

 

4

GAO characterizes economically distressed areas as those communities with high 

concentrations of low- and moderate-income families and high rates of unemployment 

and/or underemployment.

5

GAO characterizes disadvantaged communities include as those with concentrations of 

minority populations, among other factors. 

6

GAO characterizes disadvantaged businesses as those owned by women, minority 

groups and veterans, among other factors. 
 

Page 55 GAO-12-342SP Duplication, Overlap, and Fragmentation 

economic development programs also operate in both urban and rural 

areas.7

Programs That Provide Technical and Financial Assistance, by Type of Business 

and Community Served, as of September 30, 2011

Note: Some of the programs may not have received funding in fiscal year 2011. 

The number of programs that support entrepreneurs—53—and the 

overlap among these programs raise questions about whether a 

fragmented system is the most effective way to support entrepreneurs. By 

exploring alternatives, agencies may be able to determine whether there 

are more efficient ways to continue to serve the unique needs of 

entrepreneurs, including consolidating various programs. In ongoing 

work, GAO plans to examine the extent of potential duplication among 

these programs.

In addition, in order to effectively evaluate and oversee the services being 

provided, Congress and the agencies need meaningful performance 

information such as evaluation studies and performance measures. This 

information is needed to help decision makers identify ways to make 

more informed decisions about allocating increasingly scarce resources 

among overlapping programs. Specifically, performance measures can 

provide information on an agency’s progress toward meeting certain 

program and agencywide strategic goals, expressed as measurable 

performance standards. For example, while some of the financial 

assistance programs track measures that include number of businesses 

assisted and dollar value of loans obtained, they could begin to track 

measures like defaults, prepayments, and number of loans in good 

standing to better report how businesses fare after they participate in 

 

7

The definition of rural varies among these programs, but according to USDA—the agency 

that administers many of the economic development programs that serve rural areas—the 

term “rural” typically covers areas with population limits ranging from less than 2,500 to 

50,000.
 

Page 56 GAO-12-342SP Duplication, Overlap, and Fragmentation 

these programs. In contrast, program evaluations are systematic ways to 

assess a broader range of information on program performance. As a 

result, evaluation studies can help identify which programs are effective 

or not, explain why goals were not met and identify strategies for meeting 

unmet goals, and estimate what would have occurred in the absence of 

the program.

Based on preliminary results, GAO found that while most (45) of the 53 

economic development programs that support entrepreneurs have 

reasonable performance measures and tend to meet their annual 

performance goals, few evaluation studies have been completed and little 

evaluative information exists to assess programs’ effectiveness. For 39 of 

the 53 programs, the four agencies have either never conducted a 

performance evaluation or have conducted only one in the past decade. 

For example, while SBA has conducted recent periodic reviews of 3 of its 

10 programs that provide technical assistance, the agency has not 

reviewed its other 9 financial assistance and government contracting 

programs on any regular basis.8

Without results from program evaluations and performance measurement 

data, agencies lack the ability to measure the overall impact of these 

programs, and decision makers lack information that could help them to 

identify programs that could be better structured and improve the 

efficiency with which the government provides these services. Moreover, 

the federal government has recently required the Office of Management 

and Budget (OMB) to coordinate with agencies to ensure that they better 

track the results of their programs. Specifically, the GPRA Modernization 

Act of 2010 (GPRAMA) requires OMB to work with agencies to, among 

other things, develop outcome-oriented goals for certain crosscutting 

policy areas and report annually on how these goals will be achieved.

Moreover, Commerce, HUD, and USDA 

have not routinely conducted program evaluations for the majority of their 

economic development programs.

9

 

8

SBA administers a total of 19 programs that support entrepreneurs. Six of its programs 

provide technical assistance only, 5 provide financial assistance only, 2 provide only 

contracting assistance, 3 can provide both technical and financial assistance, 1 provides 

technical and government contracting assistance, and 2 provide financial and government 

contracting assistance. 

Other GPRAMA requirements could lead to improved coordination and 

collaboration among agencies. For instance, GPRAMA requires each 

agency to identify the various organizations and program activities—both 

within and external to the agency—that contribute to each agency’s goals. 

In ongoing work, GAO plans to determine reasons why the agencies (1) 

do not conduct more routine evaluations of these programs and (2) have 

not established and do not track performance measures for 8 of the 53 

programs. In addition, GAO plans to determine the ongoing and planned 

efforts of OMB and the agencies to address the provisions contained in 

GPRAMA. 

9

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

Page 57 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Based on ongoing work, GAO expects to recommend the following: 

Congress may wish to consider 

• ways to tie funding more closely to a program’s demonstrated 

effectiveness. One way to increase accountability and elevate 

the importance of program evaluation activities is to tie these 

factors to funding decisions. Therefore, Congress may want to 

consider requiring agencies to provide greater support for 

funding requests and requiring information on demonstrated 

results of program effectiveness.

Agencies should

• improve program evaluation and performance metrics. In order 

to identify options to better structure these programs for the 

Congress to consider, SBA, Commerce, HUD, and USDA 

should conduct program evaluations and collect data on 

performance measures.

OMB and the agencies should

• explore opportunities to restructure programs through means 

such as consolidation, elimination, and collaborative 

mechanisms, both within and across agencies. As OMB works 

with the agencies to identify programmatic areas that should 

be better coordinated and tracked, the agencies should look 

for ways to consolidate programs or opportunities for greater 

collaboration. In addition, to better ensure the most efficient 

and effective delivery method for federal assistance to 

entrepreneurs, SBA, Commerce, HUD, and USDA should 

individually, and collectively, explore options for restructuring 

programs that target particular types of businesses or 

communities and report the results of their efforts to the 

Congress.

GAO provided a draft of this report to OMB, Commerce, HUD, SBA, and 

USDA for review and comment. Commerce and HUD provided written 

comments. OMB, HUD, SBA, and USDA provided technical comments, 

which were incorporated where appropriate. All written comments are 

reprinted in appendix IV.

OMB stated that the Administration has taken a number of steps to 

increase coordination among economic and entrepreneurial development 

programs, provide better service to businesses seeking federal services, 

and improve performance evaluation. For example, OMB stated that a 

new website will be publicly launched for entrepreneurs and business 

owners in February 2012 named BusinessUSA; the website is intended to 

provide a virtual one-stop shop for small businesses and enable them to 

access the wide array of federal programs and services available to them 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 58 GAO-12-342SP Duplication, Overlap, and Fragmentation 

across the government regardless of where they are located. According 

to OMB, BusinessUSA, while still in its early stages, will help remedy 

many of the coordination and fragmentation issues identified in the GAO 

report. OMB also stated that the President has proposed to consolidate 

the federal government’s primary business and trade agencies and 

programs into a new more efficient agency that will promote 

competitiveness, exports and American business. OMB noted that more 

than half of the programs identified in GAO’s recent report on duplication 

in federal economic development programs would be consolidated into 

the new department under the Administration’s proposal, and the new 

department would more fundamentally address the issues raised in 

GAO’s report. As GAO continues work in this area, it plans to further 

monitor and assess OMB’s efforts to work with Commerce, HUD, USDA, 

and SBA to increase coordination among economic development 

programs, provide better service to businesses under the programs, and 

improve program evaluation.

Commerce stated that prior GAO reports have focused on the types of 

investments made without considering the goals of each program, and 

GAO may be incorrectly identifying duplication where none exists as a 

result. For this report, GAO examined the missions, goals, services 

provided, and targeted beneficiaries and areas for 53 programs that fund 

entrepreneurial assistance. GAO’s report states that these programs 

overlap based not only on their shared purpose of serving entrepreneurs 

but also on the type of assistance they offer; it does not state that 

duplication exists among these programs. As GAO continues its work, 

GAO plans to examine the extent of potential duplication among these 

overlapping programs. Commerce also stated that GAO’s report presents 

premature actions needed and that the report does not recognize the 

significant advances that Commerce’s Economic Development Agency 

has made to improve program evaluation with the development of a 

performance management improvement logic model. GAO recognizes the 

action that the Economic Development Agency has taken to develop its 

new performance management model. However, because the Economic 

Development Agency has not completely designed its new model or 

provided sufficient information to explain how results of program 

evaluations will be included in the model, this action does not change 

GAO’s findings. In this report, GAO identified areas of concern related to 

the extent that Commerce, HUD, SBA, and USDA conduct performance 

evaluations for their economic development programs. Recent legislation 

also requires OMB to work with agencies to ensure that they better track 

the results of their programs. GAO believes that the actions needed 

presented in this report are consistent with its findings and recent 

legislation. As GAO continues work in this area, it also plans to further 

monitor and assess the efforts the four agencies undertake to improve 

program evaluation and performance metrics.

HUD’s Deputy Assistant Secretary for Grant Programs stated that GAO 

should reduce the number of economic development programs identified 

as being administered by HUD. First, she recommended that five of the 

Community Development Block Grant (CDBG) programs be identified as 
 

Page 59 GAO-12-342SP Duplication, Overlap, and Fragmentation 

one CDBG program. She noted that the five programs may have separate 

Catalog of Federal Domestic Assistance numbers, but the programs are 

funded from a single source within HUD’s annual appropriation, the 

economic development activities CDBG grantees carry out under the five 

programs are all subject to the same statutory and regulatory 

requirements, and CDBG grantees generally cannot obtain assistance 

under more than one of the five programs. Because GAO relies on the 

executive branch’s definition of these programs, which separates them 

into five distinct programs, we disagree that the five programs should be 

identified as one CDBG program. The Catalog of Federal Domestic 

Assistance defines federal programs based on legal authority, 

administering office, funding, purpose, benefits, and beneficiaries; also, 

the catalog may define a program separately regardless of whether it is 

identified as a separate program by statute or regulation. While GAO 

would be receptive to actions the executive branch may take to better 

define programs, using the Catalog of Federal Domestic Assistance GAO 

initially identified 80 federal programs administered by Commerce, SBA, 

USDA, and HUD that can fund economic development activities. For this 

report, GAO focused its analysis on 53 of these programs across the four 

agencies that support entrepreneurial efforts, including the five programs 

HUD noted. Second, the Deputy Assistant Secretary recommended that 

GAO delete the Brownfields Economic Development Initiative (BEDI) as 

one of HUD’s active programs that can fund economic development 

activities. She noted that HUD did not request funding nor did Congress 

appropriate funding for the BEDI program in fiscal years 2011 and 2012.10

USDA stated that GAO’s report does not emphasize the significant 

difference in agencies and programs. For example, USDA stated its Rural 

Business Service administers programs that are unique and not 

duplicative because of the agency’s mission to provide assistance to 

businesses in rural communities. USDA acknowledged that other 

agencies’ programs may provide assistance to businesses in rural areas, 

but the Rural Business Service’s programs are focused in these areas. 

USDA also stated that the Rural Business Service delivers its programs 

through an expansive field structure of state and local offices. According 

She further noted that HUD will continue to administer existing BEDI 

grants, but the department is unlikely to request program funding for fiscal 

year 2013. She added that the activities authorized under the BEDI 

program can be funded under other CDBG programs. GAO disagrees 

that the BEDI program should be removed from the list of HUD programs 

because the department is actively administering grants under the 

program. 

 

10The BEDI program received $17.5 million in enacted appropriations for fiscal year 2010, 

which is the fiscal year funding data that GAO is currently reporting for the 53 programs 

that support entrepreneurs. In addition, while a number of programs that GAO is reviewing 

received $0 during fiscal year 2010, they are still considered to be active programs by the 

executive branch. In addition, these active programs could receive funding in the future 

(see appendix III). 
 

Page 60 GAO-12-342SP Duplication, Overlap, and Fragmentation 

to USDA, federal agencies such as SBA do not utilize a similar field 

structure to deliver programs. As previously noted, GAO’s report does not 

state that duplication exists among the 53 economic development 

programs that support entrepreneurial efforts; it states that overlap and 

fragmentation are evident based on GAO’s review of the missions and 

other related program information for these programs. For example, 

GAO’s report states that USDA administers many of the economic 

development programs that serve rural areas. However, GAO also 

determined that there was overlap because other agencies’ economic 

development programs can provide assistance to entrepreneurs in rural 

areas. GAO plans to examine the extent of potential duplication in GAO’s

ongoing work. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section and additional work 

GAO conducted that will be published as a separate product in 2012. 

GAO focused its analysis on the 53 economic development programs at 

Commerce, HUD, USDA, and SBA that fund entrepreneurial assistance 

because these programs appeared to overlap the most. GAO examined 

the extent to which the federal government’s efforts to support 

entrepreneurs overlap among these numerous, fragmented programs by 

examining their missions, goals, services provided, and targeted 

beneficiaries and areas. GAO also collected information on performance 

measures that the agencies collect to track the performance of each of 

the 53 programs, and any evaluation studies conducted or commissioned 

by the agencies evaluating the effectiveness of these programs. This 

process included meeting with agency officials to corroborate the publicly 

available information. GAO also determined the reasonableness of the 

performance measures by assessing each measure against agency 

strategic goals and specific program missions to determine the extent to 

which they are aligned. GAO plans to issue a report evaluating (1) the 

support that the programs provide to entrepreneurs, and the types of 

information available on this support; (2) the extent to which federal 

agencies collaborate on the provision of counseling, training, and related 

services to entrepreneurs; and (3) the extent to which programs that 

support entrepreneurs overlap or are fragmented, the extent to which 

these programs have met their performance goals, and the information 

that is available on their effectiveness. 

Appendix III lists the programs GAO identified that may have similar or 

overlapping objectives, provide similar services or be fragmented across 

government missions. Overlap and fragmentation may not necessarily 

lead to actual duplication, and some degree of overlap and duplication 

may be justified.

How GAO Conducted 

Its Work
 

Page 61 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Efficiency and Effectiveness of Fragmented Economic Development 

Programs Are Unclear. GAO-11-477R. Washington, D.C.: May 19, 2011.

List of Selected Federal Programs That Have Similar or Overlapping 

Objectives, Provide Similar Services, or Are Fragmented Across 

Government Missions. GAO-11-474R. Washington, D.C.: March 18, 

2011.

Opportunities to Reduce Potential Duplication in Government Programs, 

Save Tax Dollars, and Enhance Revenue. GAO-11-318SP. Washington, 

D.C.: March 1, 2011.

Small Business Administration: Additional Guidance on Documenting 

Credit Elsewhere Decisions Could Improve 7(a) Program Oversight. 

GAO-09-228. Washington, D.C.: February 12, 2009.

Small Business Administration: Additional Actions Are Needed to Certify 

and Monitor HUBZone Businesses and Assess Program Results. 

GAO-08-643. Washington, D.C.: June 17, 2008.

Small Business Administration: Additional Measures Needed to Assess 

7(a) Loan Program’s Performance. GAO-07-769. Washington, D.C.: July 

13, 2007.

Rural Economic Development: More Assurance Is Needed That Grant 

Funding Information Is Accurately Reported. GAO-06-294. Washington, 

D.C.: February 24, 2006.

Economic Development Administration: Remediation Activities Account 

for a Small Percentage of Total Brownfield Grant Funding. GAO-06-7. 

Washington, D.C.: October 27, 2005.

For additional information about this area, contact William B. Shear at 

(202) 512-4325 or shearw@gao.gov. 

Related Products

Contact Information
 

Page 62 GAO-12-342SP Duplication, Overlap, and Fragmentation 

8. Surface Freight Transportation

Fragmented federal programs and funding structures are not maximizing the efficient movement of freight.

The movement of freight is critical to the economy and the livelihood of 

Americans who rely on freight transportation for food, clothing, and other 

essential commodities. Freight shipments move predominantly over vast 

networks of highways, railroads, and waterways and often are transported 

by more than one mode before reaching their final destination. System 

performance is essential for the timely transportation of freight from its 

sources and manufacturers to the customer. Congress authorized around 

$43 billion in fiscal year 2010 for Department of Transportation programs 

that can benefit surface freight transportation.

1

While freight transportation has some issues that are similar to the 

surface transportation issues that GAO identified in its first annual report 

to Congress on federal programs with duplicative goals or activities,

However, the Department 

of Transportation is just one of many stakeholders that are involved in 

freight movement—all with complex and varied roles, but none are 

responsible for the entire system. Federal funds in the form of grants, 

loans, and tax incentives are provided to state and local governments and 

the private sector, all of whom play major roles in ensuring freight 

mobility. Specifically, public sector transportation agencies at the federal, 

state, and local levels have a significant role in developing and managing 

some modes of the freight transportation system—such as highways and 

waterways—while private sector entities—such as railroads—finance and 

manage their own infrastructure. According to the Department of 

Transportation, in 2007, the surface freight transportation system, which 

crosses multiple surface modes, connected an estimated 8 million 

businesses and 116 million households moving $12 trillion in goods. 

Federal leadership can help assure that projects that facilitate movement 

of freight, which can be high-cost and cross jurisdictional lines, are 

undertaken.

2

 

1

An unknown amount of the funding went to projects that benefit freight. These programs 

have broad eligibility and may be used for a variety of types of projects that benefit freight 

to greater or lesser degrees. 

inefficiencies affecting freight transportation such as poor roads and the 

lack of intermodal connections can impact the nation’s economy. Freight 

volumes are closely linked to the gross domestic product—increases in 

freight shipments closely coincide with economic growth. However, freight 

vehicles often compete with non-freight vehicles, such as on the U.S. 

highway system, which consists of mixed-use facilities where passenger 

and freight vehicles operate in the same stream of traffic on the same 

facilities. Systems that cannot adequately accommodate both freight and 

2

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

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

Why This Area Is 

Important
 

Page 63 GAO-12-342SP Duplication, Overlap, and Fragmentation 

non-freight vehicles can become congested, leading to delays in freight 

movements, lost revenues, and increased carbon emissions—all of which 

can increase transportation costs and, consequently, the price of goods, 

hurting businesses that rely on freight transportation infrastructure.

As GAO previously reported, federal goals in surface transportation are 

numerous and roles are unclear, and the federal government does not 

maximize opportunities to promote the efficient movement of freight, 

despite a clear federal interest, the billions of dollars provided, and the 

importance of freight transportation to the national economy. There is 

currently no separate federal freight transportation program, only a loose 

collection of many freight-related programs that are embedded in a larger 

surface transportation program aimed at supporting both passenger and 

freight mobility. This fragmented structure makes it difficult to determine 

the types of freight projects that are funded and their impact on overall 

freight mobility. As GAO reported in January 2008, the need for the 

federal government to reassess its role and strategy in funding, selecting, 

and evaluating transportation investments, including those for freight 

transportation.

Department of Transportation administrations that have a role in freight 

transportation include the Federal Highway Administration, Federal 

Railroad Administration, Federal Motor Carrier Safety Administration, and 

the Maritime Administration (see table below). There also is an Office of 

Freight Management and Operations within the Federal Highway 

Administration that administers programs, develops policies, and 

undertakes research that promotes freight movement across the nation 

and its borders. However, the office does not coordinate federal actions 

related to freight mobility, specifically. In addition, the U.S. Army Corps of 

Engineers in the Department of Defense is responsible for planning, 

constructing, operating, and maintaining the nation’s waterways. 

Department of Transportation administrations also coordinate freight 

issues with other federal agencies including the Department of 

Commerce, Department of Homeland Security, and Environmental 

Protection Agency. The various federal agencies and modal 

administrations play key roles in planning, designing, constructing, 

maintaining, and regulating freight transportation. GAO could not 

determine the total amount spent on freight transportation projects 

because it is not separately tracked from other transportation 

investments. According to Federal Highway Administration officials, 

isolating freight transportation expenditures is not possible at this time 

because the vast majority of the nation’s highway system is used by both 

passenger and freight vehicles, and most highway projects benefit both.

What GAO Found
 

Page 64 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Number of Department of Transportation Programs GAO Identified That Provide 

Funding for Freight Surface Transportation Infrastructure

Department of Transportation administration Number of programs identified

Federal Highway Administration 48

Federal Motor Carrier Safety Administration 2 

Federal Railroad Administration 2 

Maritime Administration 2 

Office of the Secretary of Transportation 1 

Source: GAO analysis of Department of Transportation information.

These programs’ structures for funding freight transportation projects include

• grants (such as the National Highway System program, which funds 

projects that benefit both freight and passenger travel and, since 

2009, the Transportation Investment Generating Economic 

Recovery—TIGER—programs, which use a criteria-based, 

competitive process to fund projects serving national and regional 

priorities);

• loans (such as the Railroad Rehabilitation and Improvement 

Financing program, which directs federal loans and loan guarantees 

to finance the development of railroads); and

• tax credits (such as the exemption from federal taxes on interest 

earned from state and local government bonds for general 

transportation purposes and tax credits for certain expenditures on 

railroad track maintenance, which can create incentives for the 

investment of private sector funds on transportation improvements).

These programs are administered by different agencies and modal 

administrations with different missions, oversight, and funding 

requirements; do not necessarily coordinate with each other; and at times 

may overlap. As a result, funds have not always been allocated based on 

need or condition of the infrastructure carrying freight. For instance, 

highway funds are distributed to states through formulas that are not 

linked to performance or need. Examples of programs that may overlap

include loan programs such as the Federal Railroad Administration’s 

Railroad Rehabilitation and Improvement Financing Program and the 

Federal Highway Administration’s Transportation Infrastructure Finance 

and Innovation Act Program. Both may be used for freight rail facilities 

and infrastructure. Additionally, certain state and local governments issue 

tax-exempt bonds for financing infrastructure projects.

Although the current federal structure of loans, tax credits, and grants 

(including formula grants and congressionally directed funds) is 

beneficial, opportunities may exist to return greater national public and 

private benefits. Furthermore, intermodal considerations may not be 

evaluated in considering beneficial freight solutions for a given corridor, 

which may result in funding projects across multiple modes without regard 

for how each works toward meeting a common goal. Current law 
 

Page 65 GAO-12-342SP Duplication, Overlap, and Fragmentation 

generally ties transportation funding to a single mode, limiting the ability 

of state and local transportation planning agencies to use federal funds 

for intermodal projects. Further, Department of Transportation 

administrations and state and local transportation agencies are organized 

by mode—reflecting the structure of funding programs—resulting in an 

organizational structure that the department’s own assessments 

acknowledge can impede intermodal coordination. In addition, 

collaboration between the public and private sectors can also be 

challenging; for example, private-sector interests in airport, rail, and 

freight (such as freight shippers and carriers) have historically not 

participated in the regional planning process.

The federal government’s fragmented approach also has resulted in a 

situation where the users of each freight mode are not equally bearing the 

costs those modes impose on society. When looking at the three 

categories of social costs borne by freight transportation services—private 

costs (labor, equipment, and fuel), public costs (paid out of government 

budgets and can be funded through taxes and fees), and “external” costs 

(congestion, accidents, health, and environmental impacts), GAO reported 

in January 2011 that freight trucking costs that were not passed on to 

consumers of that service were at least 6 times greater than rail costs, and 

at least 9 times greater than waterways costs. Therefore, public and private 

investment choices may be distorted, and there may be misallocation of 

scarce government resources to one mode over another.

Constrained freight mobility could have negative economic, 

environmental, and health implications. Because of the growth in freight 

and passenger demand, there has been an increase in truck and rail 

congestion that is particularly pronounced in major urban areas that 

contain important freight hubs such as ports, airports, border crossings, 

and rail yards. Congestion results in increased delays, carbon emissions, 

and fuel and labor costs, among other things.

Since the expiration of the last surface transportation authorization in 

2009, Congress has funded transportation programs through a series of 

temporary extensions; the most recent will expire on March 31, 2012. 

Comprehensive legislative action has not been taken to fundamentally 

reexamine the nation’s surface transportation policies; however, several 

legislative 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.3

 

3

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

 

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 
 

Page 66 GAO-12-342SP Duplication, Overlap, and Fragmentation 

eliminating a number of programs.4 When we completed our 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.

Although there is a clear federal interest in freight transportation, there is 

no strategy or clearly defined federal role in freight transportation or 

mechanism to implement the strategy, complete with defined national and 

regional transportation priorities, to achieve the highest return on federal 

investments. As noted, federal funding for freight-related infrastructure is 

based on discrete programs’ objectives, not on a national freight policy, 

and it is currently not possible to identify program costs associated with 

only freight. Further, the Department of Transportation does not have a 

national freight strategy to guide its different operating administrations’ 

freight programs. In addition, oversight and funding requirements by the 

different modal administrations can make it difficult for planners to 

develop and implement intermodal freight projects which could result in 

more efficient freight movement.

In recent years, GAO has recommended or proposed for congressional 

consideration the following actions. The Department of Transportation 

has agreed to consider the following recommendations, but they have yet 

to be implemented, in large part because the authorization for surface 

transportation programs expired in 2009, and existing programs 

subsequently have been funded through temporary extensions.

GAO recommended in June 2007 that the Secretary of Transportation

• direct one operating administration or office—such as the Federal 

Highway Administration’s Office of Freight Management and 

Operations—to take the lead in coordinating intermodal activities for 

freight at the federal level by improving collaboration among operating 

administrations and the availability of intermodal guidance and 

resources.

GAO recommended in January 2008 that the Secretary of Transportation 

• develop with Congress and public and private stakeholders a 

comprehensive national strategy to transform the federal 

government’s involvement in freight transportation projects, including 

defining federal and nonfederal stakeholder roles and using new or 

existing federal funding sources and mechanisms to support a 

targeted, efficient, and sustainable federal role.

 

4

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

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 67 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO proposed in February 2009 that Congress, in considering the 

reauthorization of federal surface transportation programs,

• consider defining the federal role in surface transportation in 

accordance with national and regional transportation priorities, 

implementing a criteria-based, competitive project selection process, 

and working with the Secretary of Transportation to develop 

enhancements to ensure the highest return on federal investments.

Congressional reauthorization of transportation programs presents an 

opportunity to address GAO recommendations and matters for 

congressional consideration that have not been implemented. By 

promoting and coordinating solutions across jurisdictional lines, the 

federal government could increase the effectiveness of localities, states, 

and regional governments and planning organizations in overcoming 

freight-related challenges.

GAO provided a draft of this report section to the Department of 

Transportation for review and comment. The Department of 

Transportation provided technical comments, which were incorporated as 

appropriate. Department officials informed GAO that the department is 

working with Congress to address prior GAO recommendations as part of 

efforts to reauthorize the federal surface transportation programs. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. Appendix III lists the 

programs GAO identified that may have similar or overlapping objectives, 

provide similar services or be fragmented across government missions. 

Overlap and fragmentation may not necessarily lead to actual duplication, 

and some degree of overlap and duplication may be justified.

Surface Transportation: Competitive Grant Programs Could Benefit from 

Increased Performance Focus and Better Documentation of Key 

Decisions. GAO-11-234. Washington, D.C.: March 30, 2011.

Surface Freight Transportation: A Comparison of the Costs of Road, Rail, 

and Waterways Freight Shipments That Are Not Passed on to 

Consumers. GAO-11-134. Washington, D.C.: January 26, 2011.

Surface Transportation: Clear Federal Role and Criteria-Based Selection 

Process Could Improve Three National and Regional Infrastructure 

Programs. GAO-09-219. Washington, D.C.: February 6, 2009.

Freight Transportation: National Policy and Strategies Can Help Improve 

Freight Mobility. GAO-08-287. Washington, D.C.: January 7, 2008.

Intermodal Transportation: DOT Could Take Further Actions to Address 

Intermodal Barriers. GAO-07-718. Washington, D.C.: June 20, 2007.

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 
 

Page 68 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Railroad Bridges and Tunnels: Federal Role in Providing Safety Oversight 

and Freight Infrastructure Investment Could be Better Targeted. 

GAO-07-770. Washington, D.C.: August 6, 2007.

For additional information about this area, contact Phillip Herr at (202) 

512-2834 or herrp@gao.gov. Contact Information
 

Page 69 GAO-12-342SP Duplication, Overlap, and Fragmentation 

9. Department of Energy Contractor 

Support Costs 

The Department of Energy should assess whether further opportunities could be taken to streamline support 

functions, estimated to cost over $5 billion, at its contractor-managed laboratory and nuclear production and 

testing sites, in light of contractors’ historically fragmented approach to providing these functions.

The Department of Energy (Energy) spends 90 percent of its annual 

budget—which totaled $27 billion for fiscal year 2011—on the contractors 

that carry out its diverse missions and operate its sites nationwide. These 

management and operating contractors—which include corporations, 

universities, and others—also provide sites’ support functions such as 

procuring needed goods and services; recruiting and hiring workers; 

managing health and retirement benefits; and maintaining facilities and 

infrastructure. GAO reviewed support functions at the 7 national laboratory 

and nuclear production and testing sites overseen by the National Nuclear 

Security Administration (NNSA)1 and the 10 national laboratories overseen 

by the Office of Science. The total annual cost of support functions at 

NNSA and Office of Science sites increased from about $5.0 billion in fiscal 

year 2007 to about $5.5 billion (nominal) in fiscal year 2009.2 Previously, 

GAO has recommended that Energy take actions to manage cost growth in 

certain support functions and related costs. Since that time, however, some 

of these costs have continued to grow.

Because each site has historically had its own unique contractor—as part 

of Energy’s longstanding model for research and nuclear weapons 

production—the sites have also differed in how support functions are 

organized and carried out. This decentralized, or fragmented, approach 

has sometimes led to inefficiencies in support functions. For example, 

sites have long procured goods and services independently of each other, 

sometimes buying from the same vendors in an uncoordinated manner 

and limiting Energy’s ability to leverage sites’ buying power. Similarly, 

Energy’s fragmented approach to prioritizing and funding upgrades to 

 

1

Congress created NNSA as a semi-autonomous agency within the Department of Energy 

in 1999 (Title 32 of the National Defense Authorization Act for Fiscal Year 2000, Pub. L. 

No. 106-65, § 3201 et seq.). 

2

Over the same period, the sites’ total annual support function costs increased from about 

$5.0 billion to about $5.3 billion in constant 2007 dollars. As discussed in GAO’s January 

2012 report, Energy sites’ support costs for more recent years are not fully known, 

because Energy changed its data collection approach in 2010 to improve the quality of its 

cost data. Also, Energy has not yet fully implemented a quality control process for these 

more recent data but intends to do so in fiscal year 2012.

Why This Area Is 

Important

What GAO Found 
 

Page 70 GAO-12-342SP Duplication, Overlap, and Fragmentation 

sites’ aging facilities and infrastructures has made it difficult to leverage 

the resources needed to modernize its facilities. For example, some 

facilities cannot support vibration-free environments or other requirements 

of modern research tools.

As GAO reported in January 2012, Energy and contractors at its 17 

NNSA and Office of Science sites have been carrying out a variety of 

efforts, since 2007, to streamline and reduce the costs of sites’ support 

functions. For example:

• In 2007, NNSA began operating a central Supply Chain Management 

Center to reduce fragmentation in procurement and better leverage 

purchasing power across its seven sites. This center applies “strategic 

sourcing” techniques, aggregating and analyzing NNSA sites’ 

procurement spending data to identify opportunities to coordinate 

sites’ purchases and negotiate better prices for goods and services. 

One such analysis revealed that the sites were purchasing most of 

their laboratory supplies and equipment from the same set of 38 

vendors through individual contracts negotiated by each site. The 

center was able to negotiate a single contract for all the sites, saving 

an estimated $22 million, or 17 percent, over the contract’s 3-year 

term, according to a center official.

• Also that year, the Office of Science adopted a less fragmented 

approach to upgrading facilities and infrastructure at its 10 national 

laboratories by using a centrally managed process to prioritize funding 

for modernizing the sites’ facilities. According to Office of Science 

officials, this approach has helped tie modernization efforts more 

closely to mission needs, while lowering the costs and shortening the 

lead times for upgrading facilities at sites.

In addition, GAO found that contractors at sites have undertaken their 

own streamlining and cost-reduction efforts, ranging from automating 

hiring, training, or other human resources activities to reducing employee 

health care and pension costs. As GAO reported in September 2011, 

while not all site-led efforts were aimed at reducing inefficiencies of 

Energy’s fragmented approach, some of the efforts appeared to 

incorporate key practices for streamlining and improving the efficiency of 

federal programs and functions identified.

While these efforts have been made, there are additional opportunities to 

streamline support functions. For example:

• In an August 2010 memorandum, the Deputy Secretary of Energy 

called for expanding Energy’s use of strategic sourcing and cited 

NNSA’s Supply Chain Management Center, with its centralized 

approach to procuring goods and services for NNSA sites, as a 

possible model for leveraging Energy’s and sites’ buying power.

• NNSA is considering whether to consolidate certain support services, 

such as payroll and finance, at all seven NNSA sites. In a March 2011 
 

Page 71 GAO-12-342SP Duplication, Overlap, and Fragmentation 

white paper, NNSA concluded that a centralized approach was 

technically feasible and could lead to cost savings.

• In a July 2011 draft solicitation to industry, Energy and NNSA 

proposed having a single contractor manage and operate two NNSA 

sites. Energy and NNSA estimated that the new approach would save 

around $895 million (nominal) over the next 10 years, largely through 

efficiency gains and other improvements to the sites’ business 

systems and support functions.

Energy and contractor officials noted that further assessment of the 

appropriateness of these and other potential efforts is warranted, as each 

can present challenges. For example, in response to the Deputy 

Secretary’s August 2010 memo, the Office of Science expressed 

reluctance to implement a more centralized approach to procurement, 

citing the efficiencies of its current approach. Others in Energy noted, 

however, that similar concerns were expressed during prior streamlining 

efforts, including NNSA’s own implementation of a centralized approach, 

and can be addressed through further assessment. In addition, a 

centralized approach may not always be more efficient or effective, but 

that determination can benefit from further assessment. For example, as 

GAO reported in September 2011, the anticipated cost savings from 

NNSA’s proposal to consolidate management and operating contracts for 

two of its sites were uncertain, and NNSA’s own analysis suggested that 

efficiencies could instead be achieved under its existing contracts through 

improved management practices.

Energy and contractors at NNSA and Office of Science sites have taken 

steps, and are identifying further opportunities, to streamline support 

functions and reduce costs. As fiscal environments become more 

constrained, Energy needs to ensure that streamlining efforts will be 

effective. This includes understanding when it is appropriate to use a 

more centralized approach and addressing any challenges to further 

streamlining. As a result, GAO recommended in January 2012 that the 

Secretary of Energy should 

• assess whether all appropriate efforts are being taken to streamline 

support functions at NNSA and Office of Science sites and to address 

implementation challenges.

GAO provided a draft of its January 2012 report to Energy for review and 

comment. Energy generally agreed with the findings and 

recommendations from the report. As part of its routine audit work, GAO 

will track the extent to which progress has been made to address the 

identified action and report to Congress.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 72 GAO-12-342SP Duplication, Overlap, and Fragmentation 

The information in this analysis is based primarily on findings from the 

products listed in the related GAO products section. GAO reviewed 

documents and data and spoke with Energy, NNSA, and Office of 

Science officials and with contractors at eight sites—the four largest sites 

by budget from NNSA and Office of Science.

Department of Energy: Additional Opportunities Exist to Streamline 

Support Functions at NNSA and Office of Science Sites. GAO-12-255. 

Washington, D.C.: January 31, 2012.

Streamlining Government: Key Practices from Select Efficiency Initiatives 

Should be Shared Governmentwide. GAO-11-908. Washington, D.C.: 

September 30, 2011.

Modernizing the Nuclear Security Enterprise: The National Nuclear 

Security Administration’s Proposed Acquisition Strategy Needs Further 

Clarification and Assessment. GAO-11-848. Washington, D.C.: 

September 20, 2011.

For additional information about this area, contact Gene Aloise at (202) 

512-3841 or aloisee@gao.gov. 

How GAO Conducted 

Its Work

Related GAO

Products 

Contact Information
 

Page 73 GAO-12-342SP Duplication, Overlap, and Fragmentation 

10. Nuclear Nonproliferation

Comprehensive review needed to address strategic planning limitations and potential fragmentation and 

overlap concerns among programs combating nuclear smuggling overseas.

The proliferation of nuclear weapons represents one of the greatest 

threats to U.S. and international security. As little as 25 kilograms of 

weapon-grade highly enriched uranium or 8 kilograms of plutonium could 

be used to build a nuclear weapon. If terrorists or other nations were to 

acquire and use a nuclear weapon, the results could have far-reaching 

and long-lasting social, financial, and health impacts. The United States 

has pursued a range of nuclear nonproliferation programs to address this 

threat through the Department of Energy’s (Energy) National Nuclear 

Security Administration (NNSA). In addition to NNSA, other U.S. 

government agencies—including the Departments of Defense (DOD), 

State (State), and Homeland Security (DHS)—support programs and 

activities to reduce proliferation concerns around the world. National 

Security Council (NSC) staff have the principal role in coordinating the 

implementation of NNSA, DOD, State, and other agency nonproliferation 

programs.

GAO reported in December 2011 on issues relating to the coordination of 

federal programs involved in preventing and detecting nuclear smuggling 

overseas. GAO identified and reviewed 21 U.S. government programs 

and offices under five federal agencies—NNSA, DOD, State, DHS, and 

the Department of Justice (Justice)—that play a role in preventing and 

detecting smuggling of nuclear materials and illicit trafficking of related 

technologies overseas. These include programs that (1) conduct research 

and development on radiation detection technologies; (2) deploy radiation 

detection equipment along foreign borders and points of transit; (3) train 

and equip foreign customs and border security officials to identify and 

interdict illicit nuclear materials or technology transfers; (4) assist foreign 

governments in the development of export control systems; (5) enhance 

and coordinate with foreign antismuggling law enforcement and 

prosecutorial capabilities; and (6) analyze potential foreign nuclear 

smuggling cases and incidents.

Among other things, GAO found that none of the existing strategies and 

plans for coordinating federal efforts to prevent and detect nuclear 

smuggling and illicit nuclear transfers overseas incorporates all of the 

desirable characteristics of national strategies. GAO also identified 

potential fragmentation and overlap among some programs working in 

this area, especially those providing equipment and training in foreign 

countries to counter nuclear smuggling. Furthermore, there is no single 

recognized agency responsible for leading and directing federal efforts to 

combat nuclear smuggling. However, State is taking steps to enhance 

one of the principal interagency coordinating mechanisms.

Why This Area Is 

Important

What GAO Found
 

Page 74 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Regarding strategic planning to combat nuclear smuggling overseas, 

GAO found that existing interagency strategies to coordinate efforts 

governmentwide lacked some of the desirable characteristics of a 

national strategy, such as identifying financial resources needed and 

monitoring mechanisms to be used to determine progress and make 

improvements. For example, the 2010 Global Nuclear Detection 

Architecture Strategic Plan—developed jointly by DHS, DOD, Energy, 

State, Justice, the intelligence community, and the Nuclear Regulatory 

Commission—did not identify the financial resources needed to achieve 

the strategic plan’s objectives or the monitoring mechanisms that could 

be used to determine programmatic progress and needed improvements. 

Similarly, implementation guidelines for international nuclear and 

radiological border security efforts issued by NSC in 2005 did not 

establish priorities, identify measures to track progress, or define the 

resources needed to effectively implement the strategy.

GAO also identified potential fragmentation and overlapping functions 

among some of these programs implemented by these federal agencies. 

Specifically, GAO identified six programs providing training to improve the 

capabilities of foreign border security and customs officials to prevent 

smuggling and illicit nuclear shipments: (1) NNSA’s Second Line of 

Defense program, (2) International Nonproliferation Export Control 

Program, and (3) Cooperative Border Security Program;1

In raising the issue of potential fragmentation and overlap, agency 

officials representing these programs told GAO that not all of them have 

the same focus, that some concentrate on specialized niches, and that 

many are complementary. For instance, in the area of training, NNSA 

officials told GAO that the Second Line of Defense program is focused on 

training in the use and long-term sustainment of the radiation detection 

(4) State’s 

Export Control and Related Border Security program; and (5) DOD’s 

Weapons of Mass Destruction-Proliferation Prevention Program and (6) 

International Counterproliferation Program. Similarly, GAO identified four 

programs that are involved in providing equipment to foreign governments 

to enhance the ability of their customs and border security organizations 

to detect nuclear smuggling: (1) NNSA’s Second Line of Defense 

program, (2) State’s Export Control and Related Border Security program, 

(3) DOD’s Weapons of Mass Destruction-Proliferation Prevention 

Program, and (4) DOD’s International Counterproliferation Program. In 

prior reports on nuclear nonproliferation programs, GAO has found that 

consolidating programs sharing common goals and implementing similar 

projects can maximize limited resources and may achieve potential cost 

savings or other programmatic and administrative efficiencies.

 

1

The Cooperative Border Security Program was an independent program at the time of 

GAO’s audit on the coordination of federal programs involved in combating nuclear 

smuggling overseas. However, the program is no longer an independent program, and its 

functions were merged into the International Nonproliferation Export Control Program in 

June 2010. 
 

Page 75 GAO-12-342SP Duplication, Overlap, and Fragmentation 

equipment provided by the program, whereas the International 

Nonproliferation Export Control Program concentrates on training foreign 

customs and border guard personnel at official points of entry to detect 

illicit weapons of mass destruction-related commodity transfers and 

assisting border security officials to detect illicit trafficking of weapons of 

mass destruction-related items in “green border” areas between official 

points of entry. Regarding the provision of equipment, NNSA, State, and 

DOD officials noted that the Second Line of Defense program tends to 

provide larger equipment, such as radiation portal monitors and cargo 

scanning equipment, while the Export Control and Related Border 

Security program and International Counterproliferation Program provide 

smaller-scale equipment, such as handheld radiation detection pagers, 

hazardous materials kits, and investigative suits to foreign customs and 

border security organizations. While the agencies noted that these 

programs are complementary to one another, in GAO’s view the 

fragmented and overlapping nature of the programs nevertheless raises 

questions as to whether greater efficiency could be obtained through 

possible consolidation of such efforts.

Furthermore, GAO found that no single federal agency has lead 

responsibility to direct federal efforts to prevent and detect nuclear 

smuggling overseas. In the past, GAO has reported that interagency 

undertakings can benefit from the leadership of a single entity with 

sufficient time, responsibility, authority, and resources needed to ensure 

that federal programs are based upon a coherent strategy, are well 

coordinated, and that gaps and duplication in capabilities are avoided. For 

efforts to detect nuclear material smuggling into or movement within the 

United States, a 2005 presidential directive gave DHS’s Domestic Nuclear 

Detection Office responsibility for developing the Global Nuclear Detection 

Architecture and managing the domestic portion of the global architecture. 

However, this directive divided responsibility for the international portion of 

the global architecture among State, DOD, and Energy.

The 2010 Global Nuclear Detection Architecture Strategic Plan takes a 

step toward clarifying lead agencies responsible for different elements of 

the global architecture, including efforts overseas. Specifically, for the 

exterior layer of the global architecture—the portion focused on 

enhancing international capabilities for detecting nuclear and radiological 

materials abroad—the strategic plan identifies four performance goals, 

designating lead and supporting agency roles for each. However, it is 

unclear whether these more defined roles give authority to these lead 

agencies to provide direction and guidance across multiple agencies and 

programs. For instance, State and DOD officials told GAO that neither 

State nor any other federal agency has the authority to direct the activities 

or coordinate implementation of programs administered by other agencies 

involved in preventing or detecting nuclear smuggling overseas.

Regarding interagency coordinating mechanisms, the NSC has 

established mechanisms to coordinate efforts in this area, including a 

Countering Nuclear Threats Interagency Policy Committee (IPC) and a 

sub-IPC for international nuclear and radiological border security efforts. 
 

Page 76 GAO-12-342SP Duplication, Overlap, and Fragmentation 

NSC officials declined GAO’s request to discuss various aspects of the 

IPC structure and how it coordinates U.S. efforts to combat nuclear 

smuggling overseas. However, some officials from other agencies 

expressed doubts about the value of the NSC’s coordinating role. 

Notably, DOD officials told GAO that they believed NSC has played a 

negligible role in coordination of programs to counter nuclear smuggling.

Coordinating groups have been established beneath the IPC structure to 

facilitate greater interagency cooperation at a working level to address the 

nuclear smuggling threat in foreign countries. One of the principal 

coordinating mechanisms for U.S. export control and related border 

security assistance activities overseas is an interagency working group 

(IWG). This IWG meets on a regular basis and officials at DOD, NNSA, 

and State told GAO the meetings are well attended and are useful for 

exchanging information—such as sharing calendars and information on 

planned program activities—and building relationships between program 

managers. However, agency officials GAO interviewed identified some 

limitations with this mechanism and its ability to facilitate a more cohesive 

national response to this threat. For example, NNSA and DOD officials 

told GAO that the coordination meetings are hampered by the 

participation of many individuals and are oriented toward high-level 

discussion, making in-depth discussion of specific issues affecting 

program implementation difficult in these settings. In addition, NNSA and 

DOD officials stated that while the IWG is useful for information 

exchange, it is not a mechanism designed or suitable for conducting more 

fundamental interagency strategic planning or for developing guidance 

and priorities for individual agency programs.

State officials told GAO that they have addressed the first limitation by 

chairing executive-level and regional sub-IWG meetings. For example, 

the quarterly executive-level meetings involving senior-level participation 

at the deputy assistant secretary level, allow for high-level discussion of 

agency programmatic goals and funding priorities, while regional subIWG meetings conducted at the action-officer level provide for more 

focused attention on nonproliferation capacity building in specific 

countries or regions. In addition, State officials told GAO that they have 

proposed addressing the second limitation by using the IWG as a means 

of developing common interagency strategies and approaches toward 

other countries and to encourage individual programs to engage or 

disengage in particular regions, countries, and functional areas.

GAO concluded that effective coordination of federal government efforts to 

prevent and detect nuclear smuggling overseas is limited by shortcomings 

in strategic plans, potential fragmentation and overlap among some 

programs, and divided responsibilities among several agencies. 

Furthermore, it is apparent that no single agency or program has the 

authority to undertake and implement a strategic re-evaluation and 

restructuring across the government to address these concerns.
 

Page 77 GAO-12-342SP Duplication, Overlap, and Fragmentation 

To address these concerns, GAO recommended in December 2011 that 

the Assistant to the President for National Security Affairs (NSC) should 

• undertake—or direct and delegate an appropriate agency or agencies 

to undertake—a comprehensive review of the structure, scope, and 

composition of agencies and programs across the federal government 

involved in preventing and detecting smuggling of nuclear materials, 

equipment, and technologies overseas. Such a review should assess 

several issues, including: (1) the level of overlap and duplication 

among agencies and programs, especially in the provision of training 

and nuclear detection equipment; (2) potential for consolidation of 

these functions to fewer programs and agencies; (3) the feasibility, 

costs, and benefits of establishing a special coordinator to preside 

over the allocation of U.S. counter-nuclear-smuggling assistance to 

foreign nations and be responsible for directing the interagency 

process of development, funding, and implementation of all U.S. 

government programs related to combating nuclear smuggling 

overseas; and (4) any U.S. laws that would need to be amended by 

Congress in order to facilitate consolidation, elimination, or other 

changes to existing programs; and

• issue new guidance that incorporates the elements of effective 

strategic plans, including clearly delineating the roles and missions of 

relevant programs, specific priorities and objectives, performance 

measures and targets, overall program cost estimates, and projected 

time frames for program completion.

GAO provided a draft of its December 2011 report to NSC for report and 

comment. NSC did not comment on these recommendations. 

GAO provided a draft of this report section to the Office of Management 

and Budget for review and comment. The Office of Management and 

Budget provided technical comments, which were considered and 

incorporated as appropriate. The Office of Management and Budget 

provided comments regarding the roles and responsibilities of other 

agencies, noting the administration has taken several steps to enhance 

and promote counter nuclear smuggling options within the national 

security agencies. These observations were addressed in conjunction 

with discussions GAO had with the other agencies during the course of its 

work. As part of GAO’s routine audit work, GAO will track actions to 

address these recommendations and report to Congress.

The information in this analysis is based on findings from the product 

listed in the related GAO products section. GAO reviewed uncosted 

NNSA nuclear nonproliferation program funding, but did not specifically 

discuss funding associated with the programs where GAO identified 

potential fragmentation and overlap, and GAO did not quantify the 

potential financial savings associated with those programs.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 78 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Nuclear Nonproliferation: Action Needed to Address NNSA’s Program 

Management and Coordination Challenges. GAO-12-71. Washington, 

D.C.: December 14, 2011.

For additional information about this area, contact Gene Aloise at (202) 

512-3841 or aloisee@gao.gov. 

Related GAO Product

Contact Information
 

Page 79 GAO-12-342SP Duplication, Overlap, and Fragmentation 

11. Personnel Background Investigations

The Office of Management and Budget should take action to prevent agencies from making potentially 

duplicative investments in electronic case management and adjudication systems.

The federal government spent over $1 billion to conduct more than 2 

million personnel background investigations for government employees in 

fiscal year 2011. The Office of Personnel Management (OPM) conducts 

the majority of these investigations for federal agencies including the 

Department of Defense (DOD). DOD requests more investigations from 

OPM than any other federal agency and received over 788,000 

background investigations that cost over $787 million in fiscal year 2011. 

Agencies use electronic case management systems to identify employees 

who need investigations and monitor the status of investigations. In 

addition, agencies use electronic adjudication systems to store records of 

the decisions that officials make based on investigations, such as whether 

an applicant is suitable for federal employment, and in some cases, 

whether the applicant is eligible for a security clearance, enabling him or 

her to access classified information.

In light of long-standing delays in completing these processes and other 

concerns, Congress set objectives and established requirements for 

improving aspects of the personnel security clearance process in the 

Intelligence Reform and Terrorism Prevention Act of 2004.

1 Among other 

things, the act established requirements for reciprocity—an agency’s 

acceptance of a background investigation or clearance determination 

completed by any authorized investigative or adjudicative agency, subject 

to certain exceptions. When agencies do not reciprocally accept a 

background investigation or clearance determination completed by 

another agency, government resources may be used inefficiently to 

conduct duplicative investigations and adjudications. To meet the 

objectives laid out in the act and oversee reforms of the employment 

suitability and security clearance eligibility processes, DOD and the Office 

of the Director of National Intelligence established the Joint Security 

Clearance Process Reform Team (Joint Reform Team) in 2007. In 2008, 

the President issued an executive order2

 

1

Pub. L. No. 108-458 (2004) (codified at 50 U.S.C. § 435b).

to ensure an efficient, practical, 

reciprocal, and aligned system for the suitability and security processes, 

among other things. The order (1) established a Suitability and Security 

Clearance Performance Accountability Council, which is accountable to 

the President to achieve the goals of reform (2) designated the Deputy 

Director for Management at the Office of Management and Budget (OMB) 

2

Exec. Order No. 13467, Reforming Processes Related to Suitability for Government 

Employment, Fitness for Contractor Employees, and Eligibility for Access to Classified 

National Security Information (June 30, 2008).

Why This Area Is 

Important
 

Page 80 GAO-12-342SP Duplication, Overlap, and Fragmentation 

as the chair of the Council; and (3) outlined the responsibilities of the 

Council, which include establishing requirements for enterprise 

information technology. Since 2008, the Joint Reform Team under the 

guidance of the Performance Accountability Council has encouraged 

agencies to automate their paper-based case management and 

adjudication systems by using electronic systems.3

Multiple agencies have invested in or are beginning to invest in potentially 

duplicative, electronic case management and adjudication systems 

despite governmentwide reform effort goals that agencies leverage 

existing technologies to reduce duplication and enhance reciprocity. The 

governmentwide reform effort, led by the Performance Accountability 

Council, has resulted in progress in reducing delays in the amounts of 

time needed to conduct investigations and adjudicate clearances. 

Additionally, the Joint Reform Team, under the Performance 

Accountability Council’s leadership, set as a goal in its information 

technology strategy that agencies will leverage existing systems to 

reduce duplication and enhance reciprocity.

However, of the agencies that GAO reviewed, GAO found that since 2007 

three agencies—DOD, the Department of Justice (Justice), and the 

Department of Homeland Security (DHS) have each developed and 

implemented their own electronic systems for case management and 

adjudication. In addition, GAO identified three other agencies—the 

National Reconnaissance Office,4

 

3

The Performance Accountability Council is currently comprised of representatives from 

11 executive branch agencies, including DOD and the Office of the Director of National 

Intelligence. 

the Department of Veterans Affairs, 

and the Department of the Treasury—that are beginning to invest in new 

systems that may duplicate the systems that DOD, Justice, and DHS 

have already implemented. Moreover, OPM officials told GAO that OPM 

plans to develop a new electronic case management and adjudication 

system. See the table below for the agencies GAO identified that have 

developed or are planning to develop their own electronic systems for 

case management and adjudication and the amounts those agencies 

have invested as of fiscal year 2011.

4

While the National Reconnaissance Office is an agency within DOD, it is beginning to 

invest in an electronic system distinct from DOD’s system.

What GAO Found
 

Page 81 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Agency Investments in Electronic Systems That Have Potentially Duplicative 

Capabilities for Case Management and Adjudication

Agency Status Investment as of FY11 

Department of Defense Completed $32 million

Department of Justice Completed 15 million

Department of Homeland Security Completed 6.5 million

National Reconnaissance Office In development 6.8 million

Department of Veterans Affairs In development 900,000

Department of the Treasury In development 300,000a

Office of Personnel Management Planned Unknown

Source: GAO.

a

According to officials at the Department of the Treasury, the agency seeks $300,000 to fund its 

system. 

According to DOD officials, DOD has intended to share the technology for 

its case management and adjudication system with other agencies since it 

developed its system. According to Department of Energy officials, the 

agency piloted a part of DOD’s system in 2010 and it is still considering 

whether to implement it. In addition, DOD officials told GAO that the Social 

Security Administration plans to use DOD’s system. DOD officials estimate 

that to implement the DOD system, agencies would need to invest 

approximately $300,000, in addition to any expenses agencies could incur 

if they chose to customize DOD’s system to meet specific needs. 

Furthermore, DOD officials estimate that agencies may need to spend 

approximately $100,000 per year for long-term support and maintenance of 

the system. Likewise, OPM officials told GAO that OPM plans to share the 

technology for any case management and adjudication system that it 

develops with the agencies that request investigations from OPM. 

However, the Performance Accountability Council has not developed 

specific governmentwide guidance regarding how agencies should 

leverage existing technologies to prevent agencies from making 

duplicative investments in electronic case management and adjudication 

systems. As a result, individual agencies can decide to develop their own 

new systems without evaluating whether utilizing an existing system 

would be a more cost-effective approach. Since it was established, the 

Performance Accountability Council and the Joint Reform Team have 

issued several reports detailing reform-related plans, including a Strategic 

Framework in February 2010. The Strategic Framework established 

goals, performance measures, roles and responsibilities, and proposed 

metrics for determining the quality of security clearance investigations 

and adjudications. However, the Council did not include specific guidance 

in the Strategic Framework about how agencies might leverage existing 

technologies. Without specific guidance regarding how agencies should 

leverage existing technologies, agencies may miss opportunities to avoid 

duplicative investments in electronic systems for case management and 

adjudication.
 

Page 82 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO recommended in February 2012 that OMB’s Deputy Director for 

Management, in his capacity as Chair of the Performance Accountability 

Council, should

• develop additional guidance to help ensure that reform stakeholders 

identify opportunities for preventing duplication in the development of 

electronic case management and adjudication technologies in the 

suitability determination and personnel security clearance processes.

The federal government may realize multiple potential benefits from 

taking the actions GAO describes, including improved reciprocity and cost 

savings by preventing duplication of investments in electronic systems. 

Agencies that operate the same electronic systems for case management 

and adjudication may be able to share records of personnel background 

investigations with one another more easily, which may improve 

reciprocity and result in cost savings by using existing investigations 

rather than paying for new ones to be conducted.

GAO provided a draft of its February 2012 report to OMB for review and 

comment. OMB agreed with GAO’s recommendation that OMB develop 

additional guidance to help ensure that reform stakeholders identify 

opportunities for preventing duplication in the development of electronic 

case management and adjudication technologies in the suitability 

determination and personnel security clearance processes. As part of its 

routine audit work, GAO will track the extent to which progress has been 

made to address the identified actions and report to Congress.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products listed below. GAO selected 

agencies to review that meet a combination of one or more of the 

following criteria: (1) utilizes OPM to conduct most of its security 

clearance investigations for civilians, military, and industrial (contractor) 

personnel; (2) ranks among OPM’s top 10 largest investigation 

customers, by volume and/or by total expenditures in fiscal year 2010; 

and (3) is a member of the Performance Accountability Council. GAO also 

reviewed selected additional agencies that are developing or planning to 

develop an electronic system for case management and adjudication. 

GAO then interviewed knowledgeable officials at each of these agencies 

about the status of and their plans for investments in electronic systems 

for case management and adjudication.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 83 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Background Investigations: Office of Personnel Management Needs to 

Improve Transparency of Its Pricing and Seek Cost Efficiencies. 

GAO-12-197. Washington, D.C.: February 28, 2012.

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

February 2011.

Personnel Security Clearances: Overall Progress Has Been Made to 

Reform the Governmentwide Security Clearance Process. GAO-11-232T. 

Washington, D.C.: December 1, 2010.

Personnel Security Clearances: Progress Has Been Made to Improve 

Timeliness but Continued Oversight Is Needed to Sustain Momentum. 

GAO-11-65. Washington, D.C.: November 19, 2010.

DOD Personnel Clearances: Preliminary Observations on DOD’s 

Progress on Addressing Timeliness and Quality Issues. GAO-11-185T. 

Washington, D.C.: November 16, 2010.

Personnel Security Clearances: An Outcome-Focused Strategy and 

Comprehensive Reporting of Timeliness and Quality Would Provide 

Greater Visibility over the Clearance Process. GAO-10-117T. 

Washington, D.C.: October 1, 2009.

Personnel Security Clearances: Progress Has Been Made to Reduce 

Delays but Further Actions Are Needed to Enhance Quality and Sustain 

Reform Efforts. GAO-09-684T. Washington, D.C.: September 15, 2009.

Personnel Security Clearances: An Outcome-Focused Strategy Is 

Needed to Guide Implementation of the Reformed Clearance Process. 

GAO-09-488. Washington, D.C.: May 19, 2009.

DOD Personnel Clearances: Comprehensive Timeliness Reporting,

Complete Clearance Documentation, and Quality Measures Are Needed 

to Further Improve the Clearance Process. GAO-09-400. Washington, 

D.C.: May 19, 2009.

High-Risk Series: An Update.GAO-09-271. Washington, D.C.: 

January 2009.

For additional information about this area, contact Brenda Farrell at (202) 

512-3604 or farrellb@gao.gov. 

Related GAO 

Products 

Contact Information
 

Page 84 GAO-12-342SP Duplication, Overlap, and Fragmentation 

12. Cybersecurity Human Capital

Governmentwide initiatives to enhance cybersecurity workforce in the federal government need better 

structure, planning, guidance, and coordination to reduce duplication.

Threats to federal information technology (IT) infrastructure and systems 

continue to grow in number and sophistication, posing a risk to the 

reliable functioning of government and highlighting the need to ensure 

that the federal and contractor workforce has the knowledge, skills, and 

abilities to maintain the security of federal IT infrastructure and systems.

In discussing his 2009 Cyberspace Policy Review,1 President Obama 

declared the cyber threat to be “one of the most serious economic and 

national security challenges we face as a nation.” Because of the 

importance of federal information systems to government operations, as 

well as continuing weaknesses in the information security controls over 

these systems, GAO has identified federal information security as a 

governmentwide high-risk area since 1997.2

Cybersecurity professionals help to prevent or mitigate vulnerabilities that 

could allow malicious individuals and groups access to federal IT 

systems. Specifically, the ability to secure federal systems is dependent 

on the knowledge, skills, and abilities of the federal and contractor 

workforce that uses, implements, secures, and maintains these systems.

GAO’s work and the work of other organizations suggest that there are 

leading practices that workforce planning for critical positions such as 

federal cybersecurity positions should address. These include defining 

roles, responsibilities, skills, and competencies for these positions and 

establishing a training and development program that supports the 

competencies an agency needs to accomplish its mission.

The Department of Commerce’s National Institute of Standards and 

Technology (NIST), Chief Information Officers (CIO) Council, Office of 

Personnel Management (OPM), and the Department of Homeland 

Security (DHS) have separate efforts intended to help agencies define 

roles, responsibilities, skills, and competencies for their cybersecurity 

workforce. However, it is unclear how or whether the aforementioned 

entities will effectively align their efforts and, if so, the timeframe for 

accomplishing that. The four efforts are discussed briefly below:

 

1

President Barack Obama Cyberspace Policy Review: Assuring a Trusted and Resilient 

Information and Communications Infrastructure (Washington, D.C.: May 29, 2009).

2

See GAO, High Risk Series: An Update GAO-11-278 (Washington, D.C.: February 2011). 

Why This Area Is 

Important

What GAO Found 
 

Page 85 GAO-12-342SP Duplication, Overlap, and Fragmentation 

• As part of its responsibilities under the Federal Information Security 

Management Act, NIST has defined cybersecurity roles and 

responsibilities in NIST Special Publications 800-16, 800-37, and 800-50.

• In October 2010, the CIO Council released an updated version of 11 

standard cybersecurity roles that agencies could use as a guideline in 

developing detailed position descriptions and training. For each role, 

the CIO Council plans to develop a workforce development matrix that 

lists suggestions for qualifications for entry, intermediate, and 

advanced performance levels for the role; additional sources for skill 

and competency materials; educational and professional credentials; 

and learning and development sources. While several of the NISTdefined cybersecurity roles map to the roles defined by the CIO 

Council, others do not. As of August 2011, NIST had not indicated 

plans to modify the roles identified in NIST publications to align with 

the CIO Council roles. According to NIST, its standards and guidance 

which include its definition of cybersecurity roles and responsibilities 

were issued based on its responsibilities under the Federal Information 

Security Management Act, and as such, do not need to be revised to 

align with the CIO Council roles. However, providing multiple 

unaligned sources of guidance to federal agencies limits their value as 

a tool for agencies.

• OPM developed a governmentwide cybersecurity competency model 

that identified the most common job series used by cybersecurity 

professionals across the federal government; however, the identified 

competencies are not unique to cybersecurity work, and there is no 

mechanism in place to determine if agencies will use this model.

• In support of the National Initiative for Cybersecurity Education,

3

Although NIST guidelines are currently widely used throughout the federal 

government, it is unclear whether or how the results of the efforts of the 

CIO Council, OPM, or DHS will be used governmentwide. A more 

DHS 

is developing a framework consisting of 31 specialties across seven 

categories of cybersecurity work, which is intended to provide a 

common language for describing the cybersecurity workforce. 

According to DHS, once the framework has been finalized, other 

federal documents, including relevant NIST Special Publications, will 

be revised to conform to it. However, no time frame was provided on 

when this will occur and it is unclear whether or not NIST will revise its 

publications to conform to the framework.

 

3

The National Initiative for Cybersecurity Education began in March 2010 as an expansion 

of Initiative 8 of the Comprehensive National Cybersecurity Initiative, which focused on 

efforts to educate and improve the federal cybersecurity workforce. According to the 

interagency committee recommendations establishing the National Initiative for 

Cybersecurity Education, it is to provide program management support and promote 

intergovernmental efforts to improve cybersecurity awareness, education, workforce 

structure, and training.
 

Page 86 GAO-12-342SP Duplication, Overlap, and Fragmentation 

consolidated effort to develop one framework defining roles, 

responsibilities, skills, and competencies for the federal cybersecurity 

workforce rather than four separate efforts, would be a more efficient use 

of resources.

In addition to efforts to define roles, responsibilities, skills and 

competencies, there are multiple governmentwide cybersecurity training 

efforts under way. In 2005, the Office of Management and Budget (OMB) 

and DHS began to collaborate on an initiative, called the Information 

Systems Security Line of Business, to address common information 

systems security needs across the government, including cybersecurity 

training. As part of this collaboration, DHS designated five agencies—the 

Departments of Defense, State, and Veterans Affairs (VA), the National 

Aeronautics and Space Administration (NASA), and OPM—to be security 

training shared service centers available to all federal agencies so as to 

reduce duplication and improve the quality of information security training. 

The training courses that these agencies offer are organized into two 

training tiers: general security awareness training and role-based security 

training. While one of the goals of the shared program is to reduce 

duplication, there are several areas in which the training roles overlap 

among the agencies, and no process exists for coordinating or eliminating 

duplication among the efforts. For example, NASA, VA, and State all have 

training for employees in system administrator roles. Additionally, both 

NASA and VA offer training for CIOs, and NASA and State both offer 

training directed at the system owner role. However, neither the individual 

agencies nor DHS evaluate the training for duplicative content, 

effectiveness, or extent of use.

To ensure that governmentwide cybersecurity workforce initiatives are 

better coordinated, GAO recommended in November 2011 that Directors 

of OMB and OPM and the Secretaries of the Departments of Commerce 

and Homeland Security should

• consolidate and align efforts to define roles, responsibilities, skills, and 

competencies for the federal cybersecurity workforce.

Regarding the Information Systems Security Line of Business initiative, 

GAO also recommended in November 2011 that the Secretary of DHS

should

• implement a process for tracking agency use of training, gather 

feedback from agencies on the training’s value and opportunities for 

improvement, and develop a process to coordinate training offered to 

minimize the production and distribution of duplicative products.

Implementation of these recommendations could help the government 

more efficiently and effectively develop the federal cybersecurity 

workforce in a constrained fiscal environment.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 87 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO provided a draft of its November 2011 report to OMB, OPM, the 

Department of Commerce, and DHS, for review and comment. OPM, the 

Department of Commerce, and DHS generally agreed with GAO’s 

recommendation to consolidate and align efforts to define roles and 

responsibilities, skills, and competencies for the federal cybersecurity 

workforce. OMB provided technical comments, which were incorporated 

as appropriate. In addition, DHS officials agreed with GAO’s 

recommendations regarding improvements to the Information Systems 

Security Line of Business and stated that the department is developing a 

mechanism for gathering input to address GAO’s recommendation and 

will work with other shared service centers to ensure that they align with 

the National Initiative for Cybersecurity Education activities and findings.

As part of GAO’s routine audit work, GAO will track agency actions to 

address these recommendations and report to Congress.

GAO provided a draft of this report section to OMB for review and 

comment. OMB provided additional technical comments. However, GAO 

did not revise its findings based on these comments. In one instance, OMB 

indicated that GAO’s statement that the CIO Council released an updated 

version of 11 standard cybersecurity roles in October 2010 was not 

completely accurate and that the CIO Council document we referenced did 

not update the 11 roles. GAO disagrees. The CIO document clearly shows 

that the roles were updated on October 29, 2010. OMB also noted that the 

October 2010 CIO Council document contained additional information 

discussing efforts at NIST and the National Initiative for Cybersecurity 

Education. GAO was not provided this additional information at the time of 

its review, but to the extent this information supports better coordination of 

federal cybersecurity workforce development efforts, this is a positive step. 

Furthermore, OMB commented that it is intended that NIST will account for 

the cybersecurity workforce framework developed by the National Initiative 

for Cybersecurity Education in its follow on work. Any steps OMB and NIST 

take to better coordinate federal cybersecurity efforts will be helpful. 

Nevertheless, we continue to believe that consolidating and aligning efforts 

to define roles, responsibilities, skills, and competencies for the federal 

cybersecurity workforce will help the government more efficiently and 

effectively develop the workforce in a fiscally constrained environment.

The information contained in this analysis is based on findings from the 

product in the related GAO product section. GAO identified 

governmentwide initiatives based on interviews with subject matter 

experts at federal agencies and private organizations, and a review of 

publicly released information on the initiatives. GAO reviewed plans, 

performance measures, and status reports. GAO also interviewed officials 

at agencies responsible for these initiatives, such as NIST, OPM, the 

National Science Foundation, and OMB. GAO assessed the status and 

plans of these efforts against GAO’s prior work on strategic planning, 

training and development, and efficient government operations.

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 88 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Cybersecurity Human Capital: Initiatives Need Better Planning and 

Coordination. GAO-12-8. Washington, D.C.: November 29, 2011.

For additional information about this area, contact Gregory C. Wilshusen 

at (202) 512-6244 or wilshuseng@gao.gov or Valerie C. Melvin at 

(202) 512-6304 or melvinv@gao.gov. 

Related GAO Product

Contact Information
 

Page 89 GAO-12-342SP Duplication, Overlap, and Fragmentation 

13. Spectrum Management

Enhanced coordination of federal agencies’ efforts to manage radio frequency spectrum and an examination of 

incentive mechanisms to foster more efficient spectrum use may aid regulators’ attempts to jointly respond to 

competing demands for spectrum while identifying valuable spectrum that could be auctioned for commercial use, 

thereby generating revenues for the U.S. Treasury.

The radio frequency spectrum is a natural resource that is used to provide 

wireless communications services critical to the U.S. economy and a 

variety of government functions, such as national defense, homeland 

security, and other vital public safety activities. The federal government 

controls the use of spectrum by authorizing federal agencies’ requests for 

spectrum and issuing licenses to nonfederal users. As the nation 

continues to experience significant growth in commercial wireless

broadband services, the demand for spectrum has increased and 

additional capacity will be needed to accommodate future growth. 

Since most spectrum has already been allocated for federal, nonfederal, 

or shared uses, a number of initiatives are under way to identify 

previously assigned spectrum that can be repurposed for commercial 

wireless broadband. When spectrum is repurposed for commercial use, 

an auction may be held to distribute licenses through a bidding process. 

Since the first auction in 1994, auctions have generated nearly $52 billion 

for the U.S. Treasury and have provided additional spectrum for new 

commercial applications. In addition, some spectrum is available for 

unlicensed use, meaning an unlimited number of users can share the 

spectrum on a non-interference basis. Unlicensed spectrum supports a 

variety of technologies, including wireless fidelity (Wi-Fi) networks, and 

regulators are attempting to make more unlicensed spectrum available in 

the hopes of fueling innovation and economic growth. Spectrum 

management decisions require that regulators weigh the potential 

economic and technological benefits of increased spectrum availability 

against the need for federal agencies to use spectrum to achieve their 

missions. 

Over the past 10 years, GAO has identified weaknesses in spectrum 

management—which is fragmented between the Department of 

Commerce’s National Telecommunications and Information 

Administration (NTIA) and the Federal Communications Commission 

(FCC)—that could impact the nation’s ability to meet the growing demand 

for spectrum. In addition, GAO identified FCC’s spectrum management as 

a major governmental challenge, specifically citing the need to balance 

competing demands for limited spectrum.

Why This Area Is 

Important
 

Page 90 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Spectrum management in the United States is fragmented between NTIA 

and FCC.1

Given the fragmented federal approach, coordination is essential to 

ensure that NTIA and FCC take a holistic approach to efficiently and 

effectively manage spectrum use. As GAO reported in March 2006, 

changes that affect existing users of spectrum can cause contentious 

stakeholder conflicts that cross the jurisdictions of both agencies and can 

lead to protracted negotiations. 

NTIA is responsible for managing the federal government’s 

use of spectrum, and FCC regulates spectrum use by nonfederal entities, 

such as television broadcasters, wireless service providers, and state and 

local public safety officials. A number of other entities also play a role in 

spectrum management. For example, the Interdepartment Radio Advisory 

Committee (IRAC), which consists of 19 agencies that hold over 90 

percent of all federally assigned spectrum, coordinates federal use of 

spectrum and provides NTIA policy advice on spectrum issues. In 

addition, the Office of Management and Budget (OMB) is involved in 

spectrum management through the federal budget process and has 

issued a circular (OMB Circular A-11) that provides guidance for the use 

of spectrum-dependent systems by federal agencies. 

As GAO reported in November 2011, coordination challenges between 

NTIA and FCC were one of four factors contributing to delays in efforts to 

repurpose spectrum for new commercial uses. Efforts to repurpose 

spectrum require that NTIA and FCC coordinate to determine what 

spectrum is suitable for new commercial uses, and the extent to which 

federal agencies will be affected by efforts to relocate or modify their 

current spectrum assignments. Repurposed spectrum that can be 

auctioned for new commercial uses can generate significant revenues for 

the U.S. Treasury, and GAO and the National Commission on Fiscal 

Responsibility and Reform have supported the continued use of auctions 

to assign spectrum licenses.

While NTIA and FCC have taken steps to improve coordination and are 

collaborating on efforts to make spectrum available for wireless broadband, 

the extent to which they are effectively coordinating and will be able to 

quickly meet growing demands for spectrum is unclear due, in part, to a 

lack of transparency in their joint planning efforts. In 2003, NTIA and FCC 

signed a Memorandum of Understanding (MOU) that stated the Assistant 

Secretary for Communications and Information at NTIA and the Chairman 

of FCC would meet twice a year to conduct joint spectrum planning 

activities, as required by the NTIA Act, to ensure spectrum is used for its 

 

1

The responsibility for managing spectrum was divided between NTIA (an executive 

agency) and FCC (a federal independent regulatory commission) to avoid concentrating 

licensing power into one executive agency, while at the same time taking into account the 

President’s responsibility for both national defense and fulfilling agency missions.

What GAO Found
 

Page 91 GAO-12-342SP Duplication, Overlap, and Fragmentation 

“highest and best purpose.”2

However, according to NTIA and FCC officials, these meetings did not 

occur regularly during one prior FCC Chairman’s term. FCC officials also 

told us that the results of the meetings are not publicly available because 

they contain pre-decisional information. In addition, NTIA and FCC have 

not jointly developed a strategic spectrum plan encompassing federal and 

nonfederal spectrum use, despite statutory requirements and a 2004

Presidential Memorandum to do so. In fact, when GAO asked which 

documents comprise the national spectrum strategy, NTIA and FCC 

officials identified different documents. 

According to the MOU, the joint spectrum 

planning is to include considerations of the future spectrum requirements of 

public and private users, with the goal of promoting efficient use of 

spectrum that reflects the economic and national security interests of the 

nation. 

As GAO reported in November 2011, 62 of 71 experts and stakeholders we 

surveyed strongly or somewhat agreed that there is a need to maintain an 

ongoing strategic spectrum plan. GAO has also reported on the importance 

of transparency and oversight in spectrum management decisions. Lacking 

information on the extent to which NTIA and FCC are coordinating to 

strategically manage spectrum, Congress and stakeholders have no 

assurance that spectrum is being used for its highest and best purpose, 

and it is difficult to assess whether NTIA and FCC are fulfilling the intent of 

the NTIA Act and the MOU.

Furthermore, as GAO reported in April 2011, NTIA relies heavily on 

federal agencies to self-evaluate and determine their current and future 

spectrum needs, with limited oversight or emphasis on holistic spectrum 

management to ensure that spectrum is being used efficiently across the 

federal government. NTIA has explained that because federal agencies 

use spectrum for a variety of applications and missions, it must rely on 

the agencies’ expertise when reviewing spectrum assignments. However, 

prior GAO reports found that such a fragmented, decentralized approach 

proves problematic, since agency use of spectrum may not reflect the 

economic value of spectrum for the following reasons:

• Agencies focus on mission requirements—not an underlying, 

systematic consideration of spectrum efficiency—when making 

investments in spectrum technologies.

• Agencies do not pay for the spectrum they receive (outside of an 

administrative fee to NTIA). While OMB’s Circular A-11 requires that 

agencies consider the economic value of spectrum when purchasing 

 

2

See National Telecommunications and Information Administration Act, title I, § § 103, 112 

(1992) codified as amended at 47 U.S.C. §§ 902 (b)(2)(L)(i), 922, and Memorandum of 

Understanding Between the Federal Communications Commission and the National 

Telecommunications and Information Administration, signed January 31, 2003.
 

Page 92 GAO-12-342SP Duplication, Overlap, and Fragmentation 

spectrum-dependent systems, the requirements only apply to new 

procurements.

• Agencies receive no economic benefit from freeing up spectrum that 

can be auctioned for other uses and potentially generate revenue for 

the U.S. Treasury. In May 2004, GAO recommended that NTIA develop 

a pilot to implement incentives for agencies to use spectrum more 

efficiently, and NTIA undertook a review to identify potential incentives. 

However, according to NTIA, it did not carry out the studies 

recommended by the review due to limited resources and other 

strategic priorities. Some experts GAO spoke with noted the need to 

better incent agencies to use spectrum more efficiently, and a 

subcommittee of the Department of Commerce’s Spectrum Management 

Advisory Committee made recommendations on this issue in a January 

2011 report. NTIA officials told us that NTIA has also highlighted the 

need to amend the Commercial Spectrum Enhancement Act3

• Agencies might not have the up-front resources needed to invest in 

new technologies, which could result in the agencies using outdated, 

inefficient equipment. GAO has noted that OMB has experience 

managing a dedicated governmentwide fund that supports the upfront costs of improving efficiency in certain programs, such as 

improving the administrative efficiency of federal assistance 

programs. Although this fund is not spectrum-related, OMB officials 

noted that one of the benefits of having a centralized multiyear source 

of dedicated funding for efficiency projects is the ability to enhance 

agencies’ abilities to undertake efficiency issues that need to be 

reviewed over time or that are affected by multiple federal agencies.

to provide 

agencies with up-front funding to cover their planning costs associated 

with future spectrum reallocations, as well as covering the costs of 

sharing spectrum and enabling agencies to upgrade their technology.

4

With respect to using incentives to encourage more efficient spectrum 

use among non-federal users, GAO found that FCC has taken steps to 

rely more heavily on market mechanisms, such as auctions, to dictate the 

allocation of spectrum, and recommended Congress consider extending 

FCC’s auction authority.5 FCC is also pursuing additional approaches to 

expand economic incentives, such as incentive auctions—in which an 

existing user could receive a portion of the proceeds from the auction—

however, some of these approaches require congressional approval and 

face mixed support among stakeholders.

 

3

Pub. L. No. 108-494, title II, 118 Stat. 3991 (2004).

4

GAO-11-908 provides more information about OMB’s Partnership Fund for Program 

Integrity Innovation, which funds efforts to improve the efficiency of federal assistance 

programs.

5

GAO-12-118. 
 

Page 93 GAO-12-342SP Duplication, Overlap, and Fragmentation 

In its previously issued reports, GAO has consistently noted that 

spectrum management is not guided by a long-range holistic vision 

encompassing federal and nonfederal users. A Presidential Memorandum 

required NTIA and FCC to collaborate to make more spectrum available 

for wireless broadband. NTIA and FCC are also working together to 

accommodate more flexible and efficient models of spectrum use. These 

efforts could lead to additional spectrum auctions, which could generate 

increased revenues for the U.S. Treasury and provide spectrum for new 

commercial applications. Enhanced transparency in NTIA and FCC’s joint 

spectrum management efforts could aid Congress’ oversight and ensure 

that the agencies are on the path to efficient and effective spectrum 

management. In addition, GAO, the Department of Commerce, and an 

FCC task force have noted the need to develop incentives that encourage 

agencies to use spectrum more efficiently.

To improve transparency in national spectrum policy decisions, assure 

coordination between managers of government and privately-owned 

spectrum, and help ensure that spectrum is used for its highest and best 

purpose, the Assistant Secretary for Communications and Information at 

NTIA and the Chairman of the FCC should 

• report periodically to Congress on their joint spectrum planning 

activities and their consultation with other relevant government 

agencies. The report should include information on estimated future 

spectrum requirements for public and private uses, the spectrum 

allocation actions necessary to accommodate those uses, and any 

actions taken to promote the efficient use of spectrum.

To improve spectrum efficiency among federal agencies, Congress may 

wish to consider

• evaluating what incentive mechanisms could be used to move 

agencies toward more efficient use of spectrum, which could free up 

some allocated for federal use spectrum to be made available for 

other purposes. OMB’s experience managing governmentwide 

efficiency programs could prove helpful in this evaluation.

GAO provided a draft of this report section to the Department of 

Commerce, FCC, and OMB for review and comment. The Department of 

Commerce, FCC, and OMB provided technical comments, which were 

incorporated as appropriate. The Department of Commerce stressed that 

spectrum management is a difficult, complex undertaking with multiple 

growing demands from commercial and governmental users, requiring 

that regulators balance regulatory certainty for existing users against 

flexibility to accommodate new users. The Department of Commerce 

added that NTIA and FCC will need to continue to improve their 

processes to meet competing demands for spectrum, specifically noting 

the need to develop a regulatory basis for spectrum sharing. The 

Department of Commerce stated that if so directed by Congress, NTIA 

would work with FCC to report on planning activities, but cautioned 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 94 GAO-12-342SP Duplication, Overlap, and Fragmentation 

against over-simplifying the complexity of spectrum management, noting 

that it is impossible to simply calculate a number that represents how 

much spectrum each user requires. GAO acknowledges the complexity of 

such decisions, but believes that increased transparency in NTIA and 

FCC’s statutorily-required joint planning efforts would prove useful for 

Congress and stakeholders. With respect to applying market incentives to 

encourage more efficient federal spectrum use, the Department of 

Commerce noted potential difficulties with applying such incentives. For 

example, the Department of Commerce stated that federal agencies 

seldom have exclusive spectrum access and a band of spectrum may be 

used to support a variety of technologies and operations. Thus, providing 

incentives to one federal user to use less spectrum may not mean that 

other federal users in the same spectrum will do the same. However, the 

Department of Commerce stated that NTIA would do its best to ensure 

the implementation of any efficiency requirements ultimately specified by 

Congress, and would fully consider any proposals to fund efficiency gains 

such as those carried out by OMB in other fields.

FCC noted that it has increased strategic planning for spectrum 

designated for commercial use, and has worked to ensure greater 

transparency in FCC’s planning efforts. FCC also provided some 

information on its efforts to expand the use of market incentives to 

encourage efficient spectrum use among commercial users, which were 

incorporated as appropriate. 

OMB disagreed with GAO’s recommendation that NTIA and FCC report 

periodically to Congress on their joint spectrum planning activities and 

their consultation with other relevant government agencies. OMB stated 

that since NTIA and FCC have distinct missions and serve discrete 

populations of spectrum users, additional public reporting would not likely 

appreciably enhance spectrum management efforts. OMB also noted that 

NTIA and FCC are collaborating with one another and with other federal 

agencies to identify spectrum that can be made available for wireless 

broadband, and that NTIA periodically reports on the progress of these 

efforts. GAO recognizes that NTIA and FCC are collaborating to make 

additional spectrum available for broadband. However, GAO has 

previously noted that coordination challenges between NTIA and FCC 

have delayed efforts to repurpose spectrum for new commercial uses, 

and changes that affect existing users of spectrum can cause contentious 

stakeholder conflicts that cross the jurisdictions of both agencies and can 

lead to protracted negotiations. Given that NTIA and FCC have not jointly 

developed a national strategic spectrum plan, despite being statutorily 

required to do so, and did not, during one prior Chairman’s term, hold 

statutorily-required spectrum-planning meetings, GAO believes that 

increased transparency in NTIA and FCC’s coordination efforts would 

prove useful in maintaining coordination between the agencies. In its 

comments, OMB also stated that the Administration has put forth 

proposals to encourage more efficient use of spectrum, such as providing 

FCC with new authority to conduct incentive auctions, and modifying 

existing law to provide federal agencies with up-front funding to plan for 
 

Page 95 GAO-12-342SP Duplication, Overlap, and Fragmentation 

spectrum reallocations and allowing support for upgrading agency 

communication capabilities.

The information contained in this analysis is based on findings from the 

products listed in the related GAO reports section as well as additional 

work GAO conducted. GAO interviewed NTIA and FCC officials, as well 

as academic experts and think tank representatives.

• Commercial Spectrum: Plans and Actions to Meet Future Needs, 

Including Continued Use of Auctions. GAO-12-118. Washington, D.C.: 

November 23, 2011.

• Streamlining Government: Key Practices from Select Efficiency 

Initiatives Should Be Shared Governmentwide. GAO-11-908. 

Washington, D.C.: September 30, 2011.

• Spectrum Management: NTIA Planning and Processes Need 

Strengthening to Promote the Efficient Use of Spectrum by Federal 

Agencies. GAO-11-352. Washington, D.C.: April 12, 2011.

• Telecommunications: Options for and Barriers to Spectrum Reform. 

GAO-06-526T. Washington, D.C.: March 14, 2006.

• Telecommunications: Strong Support for Extending FCC’s Auction 

Authority Exists, but Little Agreement on Other Options to Improve 

Efficient Use of Spectrum. GAO-06-236. Washington, D.C.: December 

20, 2005.

• Spectrum Management: Better Knowledge Needed to Take 

Advantage of Technologies That May Improve Spectrum Efficiency. 

GAO-04-666. Washington, D.C.: May 28, 2004.

For additional information about this area, contact Mark Goldstein at (202) 

512-2834 or goldsteinm@gao.gov. 

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 96 GAO-12-342SP Duplication, Overlap, and Fragmentation 

14. Health Research Funding

The National Institutes of Health, Department of Defense, and Department of Veterans Affairs can improve 

sharing of information to help avoid the potential for unnecessary duplication.

The majority of federal funding for health research and related activities is 

spent by the National Institutes of Health (NIH), within the Department of 

Health and Human Services (HHS), the Department of Defense (DOD), 

and the Department of Veterans Affairs (VA).1 In fiscal year 2010, NIH, 

DOD, and VA obligated about $40 billion, $1.3 billion, and $563 million, 

respectively, for activities related to health research.2 Applications for 

federal funding of health research are typically submitted by principal 

investigators3

—the lead researchers for research projects—through their 

institution, and in some cases they may submit applications to multiple 

agencies at the same time for funding consideration.4 It is common for 

agencies to fund health research on topics of common interest, such as 

breast cancer and post-traumatic stress disorder (PTSD).5

 

1

Specifically, about 94 percent of federal funding for medical sciences research in fiscal 

year 2008 was obligated by these three federal agencies, according to data from the 

National Science Foundation. 

In some 

cases, funding similar research on the same topics is appropriate and 

necessary, for example, for purposes of replicating or corroborating prior 

research results. However, without effective sharing of information among 

2

With respect to DOD, we obtained data on obligations of funds made available for 

research, development, testing, and evaluation in the annual appropriation for the Defense 

Health Program. With respect to VA, we obtained data on obligations of its appropriation 

for Medical and Prosthetic Research.

3

Principal investigators are typically individuals designated by the applicant organization, 

such as a university receiving federal grants, to have the appropriate level of authority and 

responsibility to direct the project or program to be supported by the award. 

4

Agency officials told us that multiple agencies cannot fund the same research application 

unless they work together to jointly fund it. 

5

In some instances, research is initiated in response to congressional direction. For 

example, according to DOD, the Office of Congressionally Directed Medical Research 

Programs is funded through the annual Defense Appropriations Act and manages 

research in many areas, including breast cancer. According to DOD, funds identified 

during the appropriations process at the request of members of the House and Senate are 

used for congressionally directed research. 

http://cdmrp.army.mil/about/fundingprocess.shtml (last visited Dec. 2, 2011). Future GAO 

work is expected to examine the Office of Congressionally Directed Medical Research 

Programs. 

Why This Area Is 

Important
 

Page 97 GAO-12-342SP Duplication, Overlap, and Fragmentation 

federal agencies about their funding decisions, they may use available 

funds inefficiently due to duplication of effort.6

NIH, DOD, and VA each lack comprehensive information on health 

research funded by the other agencies, which limits their ability to identify 

potential areas of duplication in the health research they fund. NIH, DOD, 

and VA program managers—officials who typically manage agency 

research portfolios and may provide input to senior agency officials 

responsible for making funding decisions—told GAO that, when reviewing 

health research applications, they typically search publicly available 

databases for potentially duplicative research projects funded by other 

federal agencies.7

• To obtain information on NIH-funded research applications, DOD and 

VA program managers told GAO that they search NIH’s Research 

Portfolio Online Reporting Tools Expenditures and Results, known as 

RePORTER, an electronic database that provides the public with 

information on the expenditures and results of NIH-supported health 

research. This database is also used by NIH and DOD officials to 

obtain information on some, but not all, of the health research 

applications funded by VA.

These databases are used by various federal 

agencies, including NIH, DOD, and VA, to maintain information on funded 

health research applications. For example:

8

• To obtain information on DOD-funded health research applications, 

the NIH and VA program managers GAO interviewed said that they 

use DOD’s Congressionally Directed Medical Research Programs 

website, which includes a database that provides information on 

health research applications funded through these programs, though 

 

6

GAO recognizes that, in some instances, it is appropriate for multiple agencies or entities 

to be involved in the same programmatic or policy area due to the nature or magnitude of 

the federal effort. For purposes of this report, the term “unnecessary duplication” refers to 

duplicative research funding that is not necessary to corroborate or replicate prior 

research results for scientific purposes. 

7

Officials at NIH, DOD, and VA also stated that they consider the opinions of peer 

reviewers, who are typically scientists or professors who score proposals for scientific 

merit, to determine whether applications may be duplicative of other research. NIH and VA 

applications have a required section where principal investigators and other key personnel 

must list all current funding they receive and all other applications they have submitted at 

the time of their application. Peer reviewers generally have access to this information 

when scoring the proposals. 

8

According to VA officials, NIH’s database contains information on about one quarter of all 

VA-funded health research applications. VA officials told us that they are working to add 

information on most VA-funded applications to this database by August 2012. In addition, 

NIH officials stated that they search NIH’s database for information on proposals funded 

by NIH.

What GAO Found
 

Page 98 GAO-12-342SP Duplication, Overlap, and Fragmentation 

not those funded outside these programs, such as those funded by 

separately managed research centers.9

According to NIH, DOD, and VA officials, the information provided in the 

research databases they use to identify any potential duplication when 

making funding decisions is generally not sufficient. For example, NIH’s 

public database provides basic application information such as the title, 

principal investigator name, abstract, and agency contact information for 

each application.10

Officials at NIH, DOD, and VA added that they also communicate with 

officials at other agencies through participation on joint committees that 

have members from various federal agencies. For example, NIH officials 

stated that the Interagency Breast Cancer and Environmental Research 

Coordinating Committee, a committee established in 2010 by NIH, 

facilitates exchanges of information about breast cancer environment and 

research efforts across various agencies. While DOD’s database for 

applications funded through its Congressionally Directed Medical 

Research Programs provides information about applications’ aims and 

methodologies, DOD’s database does not provide contact information for 

the officials associated with specific applications. One program manager 

at NIH and several VA officials said that they had difficulty knowing who 

to contact at DOD to obtain further information on specific applications.

However, program managers said they need more 

details on the aims and methodologies of funded applications in order to 

determine whether applications considered for funding are duplicative of 

funded research. Officials noted that even applications with identical titles 

may have different aims. In such cases, officials said they typically obtain 

information not contained in the databases by contacting colleagues at 

other federal agencies to obtain details on specific applications. 

Another limitation of the databases is that they do not always allow for 

efficient, comprehensive searches to identify unnecessary duplication of 

research. As stated earlier, information on health research funded by NIH, 

DOD, and VA is in different databases with varying types and amounts of 

information. DOD and VA officials told GAO that, in general, when 

searching multiple databases for potential duplication, the large number 

of funded applications on related topics makes comprehensive checks 

difficult and time-consuming. Because of this, officials at NIH, DOD, and 

VA told GAO that they often limit searches to principal investigators’ other 

federally funded research projects, which they are generally required to 

 

9

NIH, DOD, and VA officials told us that they also may search other databases, such as 

clinicaltrials.gov, DeployMed ResearchLINK, and PubMed, which contain information on 

federally funded health research. 

10NIH officials said the system that provides information to NIH’s database may contain 

additional information for VA applications, such as the actual application and supporting 

documentation; however, this information is only available to NIH and VA officials.
 

Page 99 GAO-12-342SP Duplication, Overlap, and Fragmentation 

list on their applications.11 To address this challenge, VA officials told 

GAO that they are working to make comprehensive searching of the 

various databases less time-consuming. VA awarded a contract for the 

development of an electronic tool to search multiple databases and check 

for potential duplication among health research applications funded by 

various agencies and other sources.12

Officials at NIH, DOD, and VA acknowledged that duplication may 

sometimes go undetected. GAO performed searches on funded 

applications for breast cancer and PTSD research in NIH’s database and 

DOD’s Congressionally Directed Medical Research Programs’ website 

using various key words frequently found in related research.

According to VA officials, this tool, 

when implemented, will allow these officials to identify in a timely manner 

applications that are most likely to be duplicative.

13 While 

most of the applications identified did not appear to be duplicative, GAO 

identified two applications, one funded by VA and the other by DOD, that 

a VA program manager confirmed were duplicative as described in the 

databases. However, the databases were not updated to reflect 

modifications that had been made to the applications’ aims. The VA 

official told GAO that these two applications were originally identical and 

submitted by the same principal investigator. VA funded one of the 

applications with the understanding that DOD would not fund the second, 

duplicative application. Subsequently, according to DOD officials, DOD 

funded the second application after the principal investigator made some 

modifications to its aims in order to make it no longer duplicative. 

However, VA officials did not have information on DOD’s funding of the 

application or on how it had been modified. This example illustrates how 

the databases used to check for duplication in health research do not 

always provide comprehensive information needed to evaluate research 

for potential duplication across federal agencies during the funding 

decision process.

Because multiple federal agencies fund research on topics of common 

interest, there is potential for unnecessary duplication. As long as 

research on similar topics continues to be funded by separate agencies, it 

is incumbent on the agencies to coordinate effectively with each other. 

While NIH, DOD, and VA take steps to check for duplication in the health 

research they fund, the agencies have opportunities to improve sharing of 

 

11Officials told us that they check this information prior to funding to ensure that the 

application is not duplicative of other federally funded research conducted by the principal 

investigator.

12This tool will be completed by June 28, 2012, according to VA’s contractor. After its 

completion, VA plans to use it internally to analyze its research portfolio and to identify 

potential duplication across research funded by various entities. VA also plans to make 

some information resulting from its use of the tool available to the public.

13The searches we performed were not comprehensive or generalizable.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 100 GAO-12-342SP Duplication, Overlap, and Fragmentation 

information needed to evaluate research for potential duplication when 

making funding decisions. In order to do so, the Director of NIH as well as 

the Secretaries of DOD and VA should

• determine ways to improve access to comprehensive electronic 

information on funded health research shared among agency officials 

and improve the ability of agency officials to identify possible 

duplication. 

For example, NIH, DOD, and VA could collaborate to allow for more 

efficient, comprehensive searches to identify duplication, by, for example, 

increasing commonalities among their respective databases; providing 

additional information in their respective databases, such as more details 

on the aims and methodology of applications that may be useful to 

program managers evaluating applications for duplication; and ensuring 

contact information for agency officials associated with specific 

applications is made available in their respective databases, if possible. 

NIH, DOD, and VA could also provide program managers with information 

to help them identify when they receive similar applications and to monitor 

the funding status of these applications, such as which applications 

receive funding, and which are modified during the funding process.

Determining ways to improve access to comprehensive information and 

to improve officials’ ability to identify duplication could help agency 

officials in their efforts to avoid duplication when determining which health 

research applications to fund.

GAO provided a draft of this report section to HHS, DOD, and VA for 

review and comment. HHS and DOD provided written comments. DOD 

generally agreed with GAO’s findings, and HHS did not state whether it 

agreed or disagreed. In its comments, on behalf of NIH, HHS provided 

more detail on NIH’s policies and procedures concerning monitoring and 

managing potential overlap in funding, particularly within NIH. HHS also 

described an internal NIH database that is also available to VA staff and 

that provides more detailed information on grants than is included in 

NIH’s public RePORTER database, but is not generally available to staff 

at other agencies. For this work, GAO focused on RePORTER because it 

is the NIH database that officials at other agencies told GAO they use 

when checking for information on NIH- or VA-funded research and is 

available to officials at all agencies. HHS and VA also provided technical 

comments, which were incorporated as appropriate. All written comments 

are reprinted in appendix IV. As part of its routine audit work, GAO will 

track the extent to which progress has been made to address the 

identified actions and report to Congress. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO reports section as well as additional 

work GAO conducted. GAO used breast cancer and PTSD research as 

examples of areas of research that are funded by these three agencies. 

Within NIH, GAO focused on the National Cancer Institute and the 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 101 GAO-12-342SP Duplication, Overlap, and Fragmentation 

National Institute of Mental Health, because these entities fund the 

majority of breast cancer and PTSD research within NIH, respectively, 

according to NIH officials. Within DOD, GAO focused on the Defense 

Health Program and, within VA, the Office of Research and Development, 

because these entities fund the majority of health research within DOD 

and VA, according to officials with whom GAO spoke. GAO focused its 

work on coordination across federal agencies that impacts decisions to 

fund health research. GAO collected and analyzed documents provided 

by NIH, DOD, and VA officials. GAO did not focus its review on 

coordination within federal agencies. In addition, GAO searched the 

available databases containing information on applications funded by 

NIH, DOD, and VA—RePORTER and DOD’s Congressionally Directed 

Medical Research Programs website—to identify examples of potentially 

duplicative research applications funded by these agencies. GAO 

searched for the terms “breast cancer” and “PTSD” and then searched for 

terms that were frequently cited in titles that appeared to indicate potential 

duplication. GAO also interviewed 23 officials at NIH, DOD, and VA whom 

it selected because of their involvement in coordination across federal 

agencies when determining which research applications to fund in the 

areas of breast cancer and PTSD. 

Defense Health: Coordinating Authority Needed for Psychological Health 

and Traumatic Brain Injury Activities. GAO-12-154. Washington, D.C.: 

January 25, 2012.

HHS Research Awards: Use of Recovery Act and Patient Protection and 

Affordable Care Act Funds for Comparative Effectiveness Research. 

GAO-11-712R. Washington, D.C.: June 14, 2011.

VA Health Care: VA Spends Millions on Post-Traumatic Stress Disorder 

Research and Incorporates Research Outcomes into Guidelines and 

Policy for Post-Traumatic Stress Disorder Services. GAO-11-32. 

Washington, D.C.: January 24, 2011.

National Institutes of Health: Awarding Process, Awarding Criteria, and 

Characteristics of Extramural Grants Made with Recovery Act Funding.

GAO-10-848. Washington, D.C.: August 6, 2010.

VA Health Care: Progress and Challenges in Conducting the National 

Vietnam Veterans Longitudinal Study. GAO-10-658T. Washington, D.C.: 

May 5, 2010.

VA Health Care: Status of VA’s Approach in Conducting the National 

Vietnam Veterans Longitudinal Study. GAO-10-578R. Washington, D.C.: 

May 5, 2010.

For additional information about this area, contact Linda T. Kohn at (202) 

512-7114 or kohnl@gao.gov. 

Related GAO 

Products 

Contact Information
 

Page 102 GAO-12-342SP Duplication, Overlap, and Fragmentation 

15. Military and Veterans Health Care

The Departments of Defense and Veterans Affairs need to improve integration across care coordination and

case management programs to reduce duplication and better assist servicemembers, veterans, and their 

families. 

In 2007, in reaction to media reports criticizing the deficiencies in the 

provision of outpatient services at Walter Reed Army Medical Center, 

various review groups investigated the challenges that the Departments of 

Defense (DOD) and Veterans Affairs (VA) faced in providing care to 

wounded, ill, and injured servicemembers. The review groups cited 

common areas of concern, including case management, which helps 

ensure continuity of care by coordinating services from multiple providers 

and guiding servicemembers’ transitions between care providers, from 

active duty status to veteran status, or back to the civilian community. One 

of these review groups, the President’s Commission on Care for America’s 

Returning Wounded Warriors—commonly referred to as the Dole-Shalala 

Commission—issued a report noting that while the military services did 

provide case management, some servicemembers were being assigned 

multiple case managers, having no single person to monitor and coordinate 

their activities, which often resulted in confusion, redundancy, and delay in 

addressing servicemembers’ health care issues.1

To elevate the response needed to address the problems associated with 

the provision of care and services for returning servicemembers, DOD 

and VA established the Wounded, Ill, and Injured Senior Oversight 

Committee (Senior Oversight Committee) in May 2007. Co-chaired by the 

Deputy Secretaries of Defense and Veterans Affairs, the Senior Oversight 

Committee was designed to be the main decision-making body for the 

oversight, strategy, and integration of DOD’s and VA’s efforts to improve 

seamlessness across the recovery care continuum.2

Under the purview of the Senior Oversight Committee, DOD and VA 

jointly developed the Federal Recovery Coordination Program (FRCP) in 

response to the Dole-Shalala Commission’s recommendation for an 

integrated approach to care management. Specifically, the FRCP was 

The committee 

included the most senior decision makers from both departments, who 

met on a routine basis to ensure timely decisions and actions, including 

ensuring that the recommendations of various review groups were 

properly evaluated, coordinated, implemented, and resourced.

 

1

President’s Commission on Care for America’s Returning Wounded Warriors, Serve, 

Support, Simplify (July 2007).

2

The 2007 Dole-Shalala Commission report outlined a vision for a recovery care 

continuum that provides continuous and integrated care management across both DOD 

and VA to create seamless transitions between the many providers and facilities 

recovering servicemembers and veterans must navigate.

Why This Area Is 

Important
 

Page 103 GAO-12-342SP Duplication, Overlap, and Fragmentation 

designed to assist Operation Enduring Freedom and Operation Iraqi 

Freedom servicemembers,3 veterans, and their families with access to 

care, services, and benefits provided through DOD, VA, other federal 

agencies, states, and the private sector. The FRCP was envisioned to 

serve “severely” wounded, ill, and injured servicemembers who are most 

likely to be medically separated from the military, including those who 

have suffered traumatic brain injuries, amputations, burns, spinal cord 

injuries, visual impairment, and post-traumatic stress disorder.4 The 

program uses coordinators to monitor and coordinate both the clinical and 

nonclinical services5 needed by program enrollees, by serving as the 

single point of contact among all of the case managers of DOD, VA, and 

other governmental and private care coordination6 and case 

management7

Separately, the Recovery Coordination Program (RCP) was established 

in response to the National Defense Authorization Act for Fiscal Year 

2008 to improve the care, management, and transition of recovering 

servicemembers. It is a DOD-specific program that was designed to use 

coordinators to provide nonclinical care coordination to “seriously” 

wounded, ill, and injured servicemembers, who may return to active duty 

unlike those categorized as “severely” wounded, ill, or injured. The RCP 

is centrally coordinated by DOD’s Office of Wounded Warrior Care and 

Transition Policy, but is implemented separately by each of the military 

services. Most of the military services have implemented the RCP within 

their existing wounded warrior programs, including the Navy Safe Harbor 

programs that provide services directly to servicemembers 

and veterans.

 

3

Operation Enduring Freedom, which began in October 2001, supports combat operations 

in Afghanistan and other locations, and Operation Iraqi Freedom, which began in March 

2003, supported combat operations in Iraq and other locations. Beginning September 1, 

2010, Operation Iraqi Freedom was referred to as Operation New Dawn.

4

The Department of Defense established three injury categories—mild, serious, and 

severe. Servicemembers with “mild” wounds, illnesses, or injuries are expected to return 

to duty in less than 180 days; those with “serious” wounds, illnesses, or injuries are 

unlikely to return to duty in less than 180 days and possibly may be medically separated 

from the military; and those who are “severely” wounded, ill, or injured are highly unlikely 

to return to duty and also likely to medically separate from the military. 

5

For the purposes of this report, clinical services include services such as scheduling 

medical appointments and providing outreach education about medical conditions such as 

post-traumatic stress disorder. Nonclinical services include services such as assisting 

servicemembers with financial benefits and accessing accommodations for families. 

6

According to the National Coalition on Care Coordination, care coordination is a clientcentered, assessment-based interdisciplinary approach to integrating health care and 

social support services in which an individual’s needs and preferences are assessed, a 

comprehensive care plan is developed, and services are managed and monitored by an 

identified care coordinator. 

7

According to the Case Management Society of America, case management is defined as 

a collaborative process of assessment, planning, facilitation, and advocacy for options and 

services to meet an individual’s health needs through communication and available 

resources to promote quality, cost-effective outcomes. 
 

Page 104 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Program, the Air Force Warrior and Survivor Care Program,8 and the 

Marine Wounded Warrior Regiment. The Army Wounded Warrior 

Program and the U.S. Special Operations Command’s Care Coalition 

also provide care coordination services using coordinators referred to as 

“advocates” that meet the requirements of the RCP, although they did not 

specifically implement the RCP program. Depending on how a military 

service’s wounded warrior program is structured, a servicemember may 

receive either case management or care coordination services or both. 

For example, the Navy Safe Harbor Program only provides care 

coordination services and does not have a case management 

component, whereas the Marine Wounded Warrior Regiment provides all 

servicemembers with both case management and care coordination 

services.9

Many recovering servicemembers and veterans are enrolled in more than 

one care coordination or case management program, and as a result, 

they may have multiple care coordinators and case managers, potentially 

duplicating agencies’ efforts and reducing the effectiveness and efficiency 

of the assistance they provide. (See table below.) For example, although 

the FRCP and RCP were intended to serve different populations, a DOD 

official told GAO that shortly after the military services implemented the 

RCP, they began to provide assistance to servicemembers who were 

“severely” wounded, ill, and injured—individuals who may also be 

enrolled in the FRCP—because DOD officials believed these 

servicemembers would also benefit from having RCP coordinators.10

 

8

The Air Force Warrior Survivor Care Program is an overarching wounded warrior 

program, which includes a care coordination component called the Air Force Recovery 

Care Program and a case management component called the Air Force Wounded Warrior 

Program. 

As a 

result, servicemembers may have care coordinators from both programs. 

In addition, recovering servicemembers and veterans who have a care 

coordinator also may be enrolled in one or more of the multiple DOD or 

VA programs that provide case management services to “seriously” and 

“severely” wounded, ill, and injured servicemembers, veterans, and their 

families. These programs include the military services’ wounded warrior 

programs and VA’s Operation Enduring Freedom/Operation Iraqi 

Freedom Care Management Program, among others. For one wounded 

warrior program—the U.S. Special Operations Command’s Care 

Coalition—enrollees may be dually enrolled in another wounded warrior 

program because servicemembers that are part of the Special Operations 

9

The Marine Wounded Warrior Regiment provides nonclinical case management services 

to its enrollees. Although it does not provide clinical case management services, the 

program does facilitate access to medical programs and care needs that have been 

identified for its servicemembers. 

10According to the Army, they have been providing care to severely wounded, ill, and 

injured servicemembers since 2004.

What GAO Found 
 

Page 105 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Forces belong to a separate military service branch.11

Characteristics of Selected Department of Defense and Department of Veterans Affairs Care Coordination and Case 

Management Programs for “Seriously” and “Severely” Wounded, Ill, and Injured Servicemembers, Veterans, and Their 

Families

Servicemembers 

who have specialty needs also may have case managers affiliated with 

specialty programs or services, such as for polytrauma or spinal cord 

injury, during their recovery process, outside of, but in coordination with, 

wounded warrior programs.

Type of services provided

Program

Severity of 

enrollees’ injuriesa

Number of 

active enrollees 

(Sept. 2011) Clinical Nonclinical

Recovery 

plan

DOD and VA Care Coordination Program

Federal Recovery Coordination Program Severeb 777 ● ● ●

DOD Recovery Coordination Programs by 

Military Servicec

Navy Safe Harbor Program Mild to severe 728 ● ●

Air Force Recovery Care Program Mild to severe 946d ● ●

Marine Wounded Warrior Regiment’s 

Recovery Coordination Program

Serious to severe 1,020e

● ●

Other DOD Care Coordination Programs 

by Military Service

Army Warrior Care and Transition Program: 

Army Wounded Warrior Programf Severe 9,144g

● ●

U.S. Special Operations Command’s Care 

Coalition Recovery Programh Serious to severe 115i

● ●

DOD Case Management Programs by 

Military Service

Army Warrior Care and Transition Program: 

Warrior Transition Units and Community 

Based Warrior Transition Unitsf

Serious to severe 9,778g

● ● ●

Air Force Wounded Warrior Program Serious to severe 1270d ●

Marine Wounded Warrior Regimentj Serious to severe 1,020e ●

U.S. Special Operations Command’s Care 

Coalition

Mild to severe 3,615i

●

VA Case Management Program

VA Operation Enduring Freedom/Operation 

Iraqi Freedom Care Management Program

Mild to severe 50,256 ● ● ●

Source: GAO analysis of DOD and VA program information.

Notes: The characteristics listed in this table are general characteristics of each program; individual 

circumstances may affect the enrollees served and services provided by specific programs. For the 

purposes of this report, clinical services include services such as scheduling medical appointments 

and providing outreach education about medical conditions such as post-traumatic stress disorder. 

Nonclinical services include services such as assisting servicemembers with financial benefits and 

accessing accommodations for families. 

 

11According to a U.S. Special Operations Command’s Care Coalition Recovery Program 

official, when an enrollee is dually enrolled in another wounded warrior program, the U.S. 

Special Operations Command’s Care Coalition Recovery Program takes the lead for 

providing nonclinical case management.
 

Page 106 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Because servicemembers and veterans may be enrolled in multiple programs, it is difficult to 

determine the overall number of unique individuals served by these programs. Furthermore, the 

number of “seriously” and “severely” wounded, ill, and injured servicemembers in the Operation 

Enduring Freedom/Operation Iraqi Freedom conflicts is not known with certainty because the terms 

“seriously” and “severely” are not categorical designations used by DOD or VA medical or benefits 

programs, and determinations of the size of this population vary, depending on definitions and 

methodology. 

a

For the purposes of this table, GAO has categorized the severity of enrollees’ injuries according to 

the injury categories established by DOD. Servicemembers with mild wounds, illness, or injury are 

expected to return to duty in less than 180 days; those with serious wounds, illness, or injury are 

unlikely to return to duty in less than 180 days and possibly may be medically separated from the 

military; and those who are severely wounded, ill, or injured are highly unlikely to return to duty and 

also likely to medically separate from the military. These categories are not necessarily used by the 

programs themselves. 

b

Although the Federal Recovery Coordination Program (FRCP) enrollment criteria state that the 

program is for severely wounded, ill, and injured servicemembers and veterans, FRCP officials told 

GAO that the program enrolls or assists seriously wounded, ill, and injured servicemembers and 

veterans who need the program’s care coordination services. 

c

Most of the military services have implemented DOD’s Recovery Coordination Program (RCP) within 

their existing wounded warrior programs, including the Navy Safe Harbor Program, the Air Force 

Warrior and Survivor Care Program, and the Marine Wounded Warrior Regiment. 

d

About one-third (286) of the Air Force Recovery Care Program enrollees were also either tracked or 

actively assisted by the Air Force Wounded Warrior Program. 

e

All servicemembers that are enrolled in the Marine Wounded Warrior Regiment receive care 

coordination and case management services. 

f

The Army Warrior Care and Transition Program includes the Army Wounded Warrior Program as 

well as the Warrior Transition Units and Community Based Warrior Transition Units. The Army did not 

implement DOD’s RCP. However, according to officials, the Army Wounded Warrior Program 

provides care coordination services that meet the requirements of the RCP. 

g

Over 1,100 Army Wounded Warrior Program enrollees were also enrolled in a Warrior Transition 

Unit. Most Army Wounded Warrior Program enrollees are veterans because the program supports 

enrollees throughout their recovery and transition, even into veteran status. 

h

The U.S. Special Operations Command did not implement DOD’s RCP. However, according to 

officials, the U.S. Special Operations Command’s Care Coalition Recovery Program provides care 

coordination services that meet the requirements of the RCP. 

i

Enrollees of the U.S. Special Operations Command’s Care Coalition Recovery Program also receive 

case management services. They may also be enrolled in a military service’s wounded warrior 

program based on their branch of service, but the U.S. Special Operations Command’s Care 

Coalition Recovery Program takes the lead for providing nonclinical case management. 

j

The Marine Wounded Warrior Regiment provides nonclinical case management services to its 

enrollees. Although it does not provide clinical case management services, the program does 

facilitate access to medical programs and care needs that have been identified for its 

servicemembers. 

GAO found that inadequate information exchange and poor coordination 

between these programs have resulted in not only duplication of effort but 

confusion and frustration for enrollees, particularly when case managers 

and care coordinators duplicate or contradict one another’s efforts.12

 

12While FRCP coordinators are generally not expected to provide services directly to 

enrollees, they may do so in certain situations, such as when they cannot determine 

whether a case manager has taken care of an issue for an individual or when asked to 

make complicated arrangements, such as assisting enrollees with adaptive housing grants 

or obtaining medical equipment or prosthetics.

For 

example, an FRCP coordinator told GAO that in one instance there were 

five case managers working on the same life insurance issue for an 

individual. In another example, an FRCP coordinator and an RCP 

coordinator were not aware the other was involved in coordinating care 

for the same servicemember and had unknowingly established conflicting 
 

Page 107 GAO-12-342SP Duplication, Overlap, and Fragmentation 

recovery goals for this individual. In this case, a servicemember with 

multiple amputations was advised by his FRCP coordinator to separate 

from the military in order to receive needed services from VA, whereas 

his RCP coordinator set a goal of remaining on active duty. These 

conflicting goals caused considerable confusion for this servicemember 

and his family.

DOD and VA have been unsuccessful in jointly developing options for 

improved collaboration and potential integration of the two care 

coordination programs—the FRCP and RCP—although they have made 

a number of attempts to do so. Despite the identification of various 

options, no final decisions to revamp, merge, or eliminate programs have 

been agreed upon. As outlined in the following examples, the 

departments’ lack of progress illustrates their continued difficulty in 

collaborating to resolve program duplication.

• Beginning in December 2010, the Senior Oversight Committee 

directed its care management work group13

• In May 2011, the Senior Oversight Committee was asked by the 

House Committee on Veterans Affairs Subcommittee on Health to 

develop options for integrating the FRCP and RCP in order to reduce 

duplication and to provide a response to the subcommittee by June 

20, 2011. On September 12, 2011—almost 3 months after the 

subcommittee requested a response—the co-chairs of the Senior 

Oversight Committee issued a joint letter following notification by the 

subcommittee that it would hold a hearing on the FRCP and RCP care 

coordination issue. The letter stated that the departments are 

considering several options to maximize care coordination resources, 

but these options had not been finalized and were not specifically 

identified or outlined in the letter. 

to conduct an inventory of 

DOD and VA case managers and perform a feasibility study of 

recommendations on the governance, roles, and mission of DOD and 

VA care coordination. According to DOD and VA officials, this 

information was requested for the purpose of formulating options for 

improving DOD and VA care coordination. However, DOD officials 

stated that following compilation of this information, no action was 

taken by the committee, and other issues, such as responding to 

budget reductions, were given higher priority.

Nonetheless, as GAO has previously reported, the need for better 

collaboration and integration extends beyond the FRCP and RCP to also 

encompass other DOD and VA case management programs, such as 

DOD’s wounded warrior programs that also serve seriously and severely 

 

13The Senior Oversight Committee is supported by several internal work groups devoted 

to specific issues, such as DOD and VA care coordination and case management. 

Participants in the committee’s care management work group include officials from the 

FRCP and the RCP.
 

Page 108 GAO-12-342SP Duplication, Overlap, and Fragmentation 

wounded, ill, and injured servicemembers and veterans. Without 

interdepartmental coordination and action to better align and integrate 

these programs, problems with duplication and overlap will persist, and 

perhaps worsen as the number of enrollees served by these programs 

continues to grow. Moreover, the confusion this creates for recovering 

servicemembers, veterans, and their families may hamper their recovery. 

Consequently, the intended purpose of these programs—to better 

manage and facilitate care and services—may actually have the opposite 

effect.

To improve the effectiveness, efficiency, and efficacy of services for 

recovering servicemembers, veterans, and their families by reducing 

duplication and overlap, GAO recommended in October 2011 that the 

Secretaries of Defense and Veterans Affairs should direct the co-chairs of 

the Senior Oversight Committee to

• expeditiously develop and implement a plan to strengthen functional 

integration across all DOD and VA care coordination and case 

management programs that serve this population, including—but not 

limited to—the FRCP and RCP.

GAO provided a draft of its October 2011 report as well as a draft of this 

report section to DOD and VA for review and comment. Although DOD 

and VA did not specifically comment on the recommendation, they 

provided technical comments, which were incorporated as appropriate. 

As part of its routine audit work, GAO will track the extent to which 

progress has been made to address the identified actions and report to 

Congress.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted to be published as a separate product in 2012.

GAO interviewed officials from each of DOD’s wounded warrior programs 

and the VA Operation Enduring Freedom/Operation Iraqi Freedom Care 

Management Program to obtain information about the services that they 

provide and their enrollees.

DOD and VA Health Care: Action Needed to Strengthen Integration 

across Care Coordination and Case Management Programs.

GAO-12-129T. Washington, D.C.: October 6, 2011.

Federal Recovery Coordination Program: Enrollment, Staffing, and Care 

Coordination Pose Significant Challenges. GAO-11-572T. Washington, 

D.C.: May 13, 2011.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 
 

Page 109 GAO-12-342SP Duplication, Overlap, and Fragmentation 

DOD and VA Health Care: Federal Recovery Coordination Program 

Continues to Expand but Faces Significant Challenges. GAO-11-250. 

Washington, D.C.: March 23, 2011.

For additional information about this area, please contact Debra Draper at 

(202) 512-7114 or draperd@gao.gov or Randall B. Williamson at (202) 

512-7114 or williamsonr@gao.gov. 

Contact Information
 

Page 110 GAO-12-342SP Duplication, Overlap, and Fragmentation 

16. Department of Justice Grants

The Department of Justice could improve how it targets nearly $3.9 billion to reduce the risk of potential

unnecessary duplication across the more than 11,000 grant awards it makes annually.

Since fiscal year 2005, Congress has appropriated approximately $30 

billion for crime prevention, law enforcement, and crime victim services for 

more than 200 federal financial assistance programs that the Department 

of Justice (Justice) manages.1 These federal financial assistance programs 

provide funding through formula grants, discretionary grants, cooperative 

agreements, and other payment programs, but are all generally referred to 

as grants.2

As the United States experiences budgetary constraints, there is an everincreasing need to ensure that governmental resources—including those 

awarded through grants and subgrants—are appropriately targeted and 

unnecessary duplication is mitigated. Further, Justice’s Office of the 

Inspector General continues to include Justice’s grants management 

among its list of top challenges affecting the department, and in previous 

reports, has identified fragmentation and duplication between Justice’s 

granting agencies. The Inspector General noted that such fragmentation 

incurs additional cost to Justice, and recommended closer coordination to 

In 2010, Justice awarded nearly $3.9 billion in grants through its 

three granting agencies—the Office of Justice Programs (OJP), the Office 

on Violence Against Women (OVW), and the Community Oriented Policing 

Services (COPS) Office. As established in statute, some of the grant 

programs administered by OJP, OVW, and the COPS Office are similar in 

scope and grant applicants can apply for and receive grant awards from 

more than one program. Moreover, grant recipients may choose to award a 

portion of their grant to subgrantees. These subgrantees may also apply 

directly to Justice for funding through other grant programs for the same or 

similar purposes. The number of grant programs and recipients, and the 

billions of dollars in funds awarded annually, present administrative 

challenges for Justice.

 

1

The amount appropriated since fiscal year 2005 does not include amounts appropriated 

in fiscal year 2012. In addition to fiscal year funding from 2005 through 2011, this amount 

includes $4 billion appropriated in fiscal year 2009 through the American Recovery and 

Reinvestment Act of 2009 (Pub. L. No. 111-5, 123 Stat. 115, 129-30), which includes $10 

million for salaries and expenses to manage, administer, and oversee the grant programs. 

2

Formula grant programs are noncompetitive awards based on a predetermined formula. 

Discretionary grants are awarded on the basis of a competitive process. A cooperative 

agreement is a type of federal financial assistance similar to a grant except the federal 

government is more substantially involved with the grant. Payment programs at Justice 

typically take the form of reimbursements to state and local law enforcement entities for 

purchases such as body armor or the cost to border states for prosecuting criminal cases. 

Why This Area Is 

Important
 

Page 111 GAO-12-342SP Duplication, Overlap, and Fragmentation 

ensure that awards are not made to the same grantee for similar 

purposes.3

Based on audit work with associated findings to be published in a 

forthcoming report, GAO found instances where Justice’s granting 

agencies had awarded funds from different grant programs to the same 

applicants whose applications described similar—and in some cases, the 

same—purposes for using the grant funds.

4 According to Justice officials, 

funding from multiple Justice grant programs may be necessary to fully 

implement grantees’ initiatives. GAO acknowledges that there may be 

times when Justice’s decision to fund grantees in this manner is 

warranted. However, GAO found that Justice made grant award 

decisions without visibility over whether the funds supported similar or the 

same purposes, thus potentially resulting in unnecessary and unintended 

duplication. Moreover, Justice has not assessed its grant programs to 

determine the extent to which they overlap with one another and 

determine if consolidation of grant programs may be appropriate. Further, 

Justice’s granting agencies have not established consistent policies and 

procedures for sharing grant application information that could help them 

identify and mitigate any unnecessary duplication in how grantees intend 

to use their grant awards. Additionally, the granting agencies do not 

consider subgrant data, such as award amounts and project purposes, as 

criteria in making grant award decisions. As a result, Justice is at risk of 

unintentionally awarding funding from multiple grant programs to grant 

recipients in the same communities for the same or similar purposes 

because it does not consistently and routinely check for any unnecessary 

duplication in grant applications.5

GAO reviewed all 253 of Justice’s three granting agencies’ fiscal year 

2010 grant program solicitations, which serve as announcements of new 

grant funding available and explain areas for which funding can be used. 

These solicitations and the respective grant awards are in addition to 

grant programs that Justice continues to administer from prior fiscal years 

or more recently began administering.6

 

3

U.S. Department of Justice Office of the Inspector General, Audit Report 03-27, 

Streamlining of Administrative Activities and Federal Financial Assistance Functions in the 

Office of Justice Programs and the Office of Community Oriented Policing Services 

(Washington, D.C.: August 2003). 

The review found evidence of 

overlap in the justice areas that Justice’s grant programs aim to support. 

4

Reviewing and validating that grantees actually used the funds for the articulated 

purposes was not within GAO’s scope. GAO’s review focused on what the grantees 

proposed in their applications and Justice’s review and approval of those applications. 

5

The three granting agencies support criminal justice interventions targeted at the 

community level.

6

Because Justice grant programs can last from 1 to 5 years, the total number of active 

Justice grant programs can be higher than what is presented in the table, which is a single 

year of grant program solicitations. 

What GAO Found
 

Page 112 GAO-12-342SP Duplication, Overlap, and Fragmentation 

For example, as the table below illustrates, 56 of Justice’s 253 grant 

solicitations—or more than 20 percent—were providing grant funds that 

could be used for victim assistance. Eighteen of these 56 programs were 

administered by offices other than OVW and OJP’s Office for Victims of 

Crime, whose primary functions are to serve individuals who have been 

victims of crime. In addition, more than 50 percent of all grant solicitations 

provided funding that could be used in support of the same three justice 

areas—victim assistance, technology and forensics, and juvenile justice—

indicating concentrated and overlapping efforts. The justice area with the 

least overlap was juvenile justice with 30 of 33 grant programs 

administered by the Office of Juvenile Justice and Delinquency 

Prevention. 

Breakdown of Fiscal Year 2010 Justice Grant Solicitations by Office and Justice Area 

Justice Area

Component 

/ program 

office 

Victim 

assistance 

Technology 

and 

forensics 

Juvenile 

justice 

Enhancing 

policing 

Justice 

information 

sharing Courts

Community 

crime 

prevention 

strategies

Mental 

illness, 

substance 

abuse, 

and crime 

Corrections, 

recidivism, 

and reentry

Multipurposea Total 

COPS 0 1 0 2 0 0 3 1 0 0 7

Jointb 0 0 1 0 0 0 0 0 2 3 6

OVW 15 0 0 0 0 1 0 0 0 1 17

OJPc 

BJA 2 2 0 7 3 7 3 6 7 5 42

BJS 5 2 2 3 6 4 1 1 4 2 30

CCDO 0 0 0 0 0 0 2 0 0 0 2

NIJ 3 36 0 4 0 1 4 0 5 8 61

OJJDP 8 0 30 7 1 8 4 0 0 3 61

OVC 23 0 0 0 0 0 0 0 0 0 23

SMART 0 0 0 0 2 0 0 0 2 0 4

Total 

solicitations 

56 41 33 23 12 21 17 8 20 22 253

Total award 

amount (in 

millions)d

$872 $325 $264 $386 $98 $77 $77 $53 $430 $810 $3,393e

Source: GAO analysis of Justice data. 

Notes: Solicitations in this table reflect those for direct assistance, such as funds Justice provides for 

the hiring of police officers, as well as those for research and data collection on the related justice 

areas. 

a

Multipurpose solicitations were solicitations for grants that addressed more than one justice area 

within a single solicitation. 

b

Joint refers to solicitations issued jointly by multiple program offices, components, or departments 

(e.g., Justice and the Department of Health and Human Services, or BJA and OJJDP). 

c

OJP is comprised of a number of smaller bureaus and offices. BJA is the Bureau of Justice 

Assistance; BJS is the Bureau of Justice Statistics; CCDO is the Community Capacity Development 

Office; NIJ is the National Institute of Justice; OJJDP is the Office of Juvenile Justice and 

Delinquency Prevention; OVC is the Office for Victims of Crime; and SMART is the Sex Offender 

Sentencing, Monitoring, Apprehending, Registering, and Tracking Office. 

d

Actual amount awarded to grantees in millions. 

e

This amount excludes congressional earmarks and direct benefits paid to families of fallen officers 

from Justice’s Public Service Pension Benefit Program. 
 

Page 113 GAO-12-342SP Duplication, Overlap, and Fragmentation 

According to Justice officials, the statutory creation of grant programs with 

similar purposes requires grant design coordination within and among 

Justice’s granting agencies to limit the risk of unnecessary duplication 

from overlapping programs. Officials from all three granting agencies 

stated that they regularly meet with one another to coordinate the goals 

and objectives of their grant programs, especially joint grant programs 

that they believe are complementary. For example, the Bureau of Justice 

Assistance and the Office for Victims of Crime issued a joint solicitation 

for anti-human trafficking programs where each office issued separate 

awards based on coordinated proposals from collaborating police 

departments and community-based victim service organizations. Further, 

according to officials, Justice recently launched the Coordinated Tribal 

Assistance Solicitation to provide a single application for most of Justice’s 

tribal grant programs. 

However, as the above table illustrates, there are a number of justice 

areas in which Justice is offering dozens of grant solicitations, yet Justice 

has not assessed the universe of grant solicitations across its granting 

agencies to identify justice purpose areas that may be overlapping. As a 

result, without this assessment, Justice lacks information on the extent to 

which unnecessary duplication in the administration and grantee use of 

funds in these areas may exist. Additionally, Justice’s granting agencies 

have not established policies and procedures requiring consistent 

coordination to mitigate the risks of unnecessary duplication before 

finalizing their award decisions. While coordination about program goals 

may be occurring on an ad hoc basis, GAO found that the granting 

agencies do not systematically coordinate their application reviews to 

mitigate the risk of unnecessary duplication.

According to Standards for Internal Control in the Federal Government, 

one way to ensure that program managers are effectively managing and 

efficiently using resources is to have access to all financial data—such as 

grant awards, prime and subgrant recipient names, and planned or 

implemented activities. In part because Justice’s granting agencies do not 

routinely share grant applicant finalist lists with one another before 

making their award decisions, GAO identified instances where Justice’s 

granting agencies had awarded funds from different grant programs to the

same grantees whose applications described similar—and in some 

cases, the same—purposes for using the grant funds without being aware 

of the potential for unnecessary duplication or whether it was warranted. 

Specifically, after reviewing a sample of 26 grant applications from 

recipients who received funds from grant programs GAO identified as 

having similar purpose areas, GAO found instances where applicants 

were using the same or similar language to apply for multiple streams of 

funding. For example, one grant recipient applied for funding from both 

the COPS Office’s Child Sexual Predator Program and OJP’s Internet 

Crimes Against Children program to reduce child endangerment through 

cyber investigations. In both of these separate applications, the applicant 

stated that it planned to use the grants to increase the number of 

investigations in its state, provide training for cyber crime investigations, 
 

Page 114 GAO-12-342SP Duplication, Overlap, and Fragmentation 

serve as a forensic resource for the state, and establish an internet safety 

program. Further, included in this applicant’s proposed budgets for both 

funding streams was a plan to purchase equipment, such as forensic 

computers and the same specialized software to investigate internet 

crimes against children. Another grant recipient applied for funding from 

the aforementioned COPS Office and OJP programs to support the same 

types of investigations. In a third instance, an applicant received fiscal 

year 2010 grant funding for planned sexual assault victim services from 

both the Office for Victims of Crime and OVW. The applicant used similar 

language in both applications, noting that it intended to use the funding to 

support child victim services through its child advocacy center. After 

reviewing a draft of this report section, Justice followed-up with the grant 

recipients in these instances and reported to GAO that the grantees were 

not using awarded funds for duplicative purposes. However, such followup for the purpose of assessing duplication is not a routine practice for 

Justice. Absent routine coordination among its granting agencies before 

awarding grants, Justice is not positioned to mitigate the risk of funding 

unnecessarily duplicative grants.

In fiscal year 2010, Justice’s three granting agencies awarded more than 

11,000 prime grant awards, but officials said that they do not generally 

assess the flow of funds to subgrant recipients and in many instances do 

not know the extent to which subgrants are made and for what purposes 

and activities. Officials from Justice’s granting agencies told GAO that 

they encourage applicants to apply for as many sources of Justice 

funding as possible, yet the granting agencies are not assessing subgrant 

data with the specific intent to identify any unnecessarily duplicative grant 

awards. According to the OJP officials, state and local communities have 

expansive criminal justice needs and therefore they encourage applicants 

to seek out as much Justice grant funding as possible, including from 

grant programs that may have similar objectives or allow for similar 

activities to be carried out. 

Justice officials reported that OVW assesses subgrant data for some of 

its formula grant programs to better understand how funding is used; 

however, officials did not provide specific examples of how such 

assessments are used to identify unnecessary duplication in funding. In 

addition, officials indicated that OVW required applicants for some of its 

fiscal year 2010 grant programs to notify OVW of the other federal grant 

programs it had either received money from or applied for in the same 

fiscal year, but GAO found that this requirement was not in place across 

all OVW programs. Further, OVW officials stated they intended to require 

that applicants for all of OVW’s programs identify other federal funding 

they are receiving beginning in fiscal year 2012. While this is a positive 

step, there is no indication that this information would be shared with 

other granting agencies or whether other granting agencies are 

considering implementing a similar practice. 

In part because this coordination is not routinely occurring before grant 

awards are made, GAO found examples where federal funds were 

awarded to the same local communities through multiple grants including
 

Page 115 GAO-12-342SP Duplication, Overlap, and Fragmentation 

subawards for the same or similar uses. In one of the states GAO visited, 

a county received an Edward Byrne Memorial Justice Assistance Grant 

(JAG) program subaward and used the funding for its officers to conduct 

community policing. The county also received a COPS Office hiring grant 

and used the funding for an officer to conduct community policing.7

State Officials from 10 of the 11 states GAO interviewed stated that the 

delivery of federal criminal justice assistance could be improved and the 

risk of unnecessary duplication limited if Justice relied more on their 

perspectives before making discretionary grant awards to localities in 

their states. In particular, officials from two of these states told GAO that 

they are better positioned than Justice to determine the demonstrated 

needs of their communities. Moreover, state officials reported they would 

prefer to receive assistance from Justice in the form of block grants citing 

reasons such as flexibility and reducing unnecessary duplication and 

fragmentation. With respect to state input related to discretionary grant 

award decisions, Justice officials stated that since states can compete 

with localities for the receipt of direct awards, the provision of pre-award 

information to the states or the solicitation of states for input on funding 

decisions could present a conflict of interest. With respect to block grants, 

Justice officials added that they believe the department is in a unique 

position to test, disseminate, evaluate, and foster best practices at a 

national level.

Additionally, the largest city in this county received a COPS Office Hiring 

grant to conduct community policing. Because this city received the 

COPS Office funding to conduct community policing in geographical 

areas that overlapped with areas in the county already served by JAGfunded police officers, three Justice grant awards were used to provide 

community policing to overlapping areas in the county. Officials from two 

additional counties in the state told GAO they received funding for drug 

court-assisted substance abuse treatment and mental health counseling 

through both a JAG program subaward and a grant directly from OJP’s 

Adult Drug Court Discretionary Grant Program. Officials from one of these 

counties informed GAO that they received so much Justice funding from 

the two different grant programs that they planned to return a portion to 

Justice because the funding exceeded their needs. 

OJP officials also stated that because programs are created by statute, 

they have little discretion related to grant program design and may be 

limited in the extent to which they can consolidate similar programs and 

solicitations.8

 

7

The COPS Office hiring grant awarded to this county was for fiscal year 2009. COPS 

Office hiring grants last up to 3 years and the county used the grant in fiscal years 2010 

and 2011. 

Justice officials stated that the timeline for reviewing 

8

The fiscal year 2012 Justice Congressional Budget Justification, however, recognized the

potential for consolidation by stating that “whenever possible, the President’s Budget 

proposes to consolidate existing programs into larger, more flexible programs that offer 

state, local, and tribal grantees greater flexibility in using grant funding and developing 

innovative approaches to their criminal justice needs.”
 

Page 116 GAO-12-342SP Duplication, Overlap, and Fragmentation 

applications, making recommendations on their merit, and processing 

awards each year is compressed and that it would be difficult to build in 

the extra time and level of coordination required to complete an 

intradepartmental review for potentially unnecessary duplication of 

funding prior to making awards. The officials added that it would take 

even more time if granting agencies were to attempt a pre-award 

duplication review at the subgrantee level. However, because OJP 

officials stated that previous and pending grant award information would 

be very useful when they make grant award decisions, they are exploring 

ways to make such a review more automated by leveraging their grant 

systems. 

GAO understands that the time necessary to complete annual grant 

awards makes such a review process more difficult; however, OJP 

actions to automate reviews using previous and pending grant award 

information could help overcome this challenge. Moreover, although 

statutory authorizations for grant programs may limit Justice’s discretion 

over grant program design, developing agency procedures to avoid 

unnecessary grant duplication is one of the promising practices that the 

federal Domestic Working Group Grant Accountability Project suggested 

in its Guide to Opportunities for Improving Grant Accountability.

9

In addition, Justice could improve its decision making before finalizing 

awards. By sharing information with one another about past and 

prospective grantees, Justice’s granting agencies could better ensure that 

applicants from certain communities already receiving funds from one 

program are not then inadvertently awarded funds from another program 

for the same or similar purposes. In some instances, Justice may deem it 

appropriate for large numbers of distinct grant programs to serve one 

goal, or for the same communities to benefit from multiple streams of 

grant funding. However, unless Justice considers information it has 

available, it cannot know with certainty where it’s funding is going, how it 

is being used, and whether it is awarding grant dollars in the most 

efficient way.

Moreover, while assessing its programs might be time intensive on the 

front end, such a review could yield positive dividends for the department 

over the longer term. Specifically, Justice could improve grants 

management by first understanding the areas in which individual granting 

agencies may be awarding funds for the same or similar purposes, 

whether these grant programs appropriately channel the department’s 

priorities, and whether any existing duplication is desirable. By focusing 

on how the grants align with priorities and understanding where 

coordination can be improved or the risk of unnecessary duplication 

reduced, Justice could then better target limited grant resources. 

 

9

The Domestic Working Group is comprised of 18 federal government inspectors general 

and other state and local audit organizations, and is chaired by the Comptroller General of 

the United States. 
 

Page 117 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Based on ongoing work, GAO anticipates recommending the following: 

The Attorney General of the United States should 

 conduct an assessment to better understand the extent to which 

Justice grant programs overlap with one another and determine if 

grant programs may be consolidated to mitigate the risk of 

unnecessary duplication. To the extent that Justice identifies any 

statutory obstacles to consolidating its grant programs, it should work 

with Congress to address them, as needed; and 

 direct granting agencies to coordinate with one another on a 

consistent basis to review potential or recent grant awards, including 

subgrant awards reported by Justice prime grant awardees, to the 

extent possible, before awarding grants. This could help ensure an 

accurate understanding of Justice resources already provided to 

applicants and the communities they serve, as well as knowledge of 

those applicants proposing to carry out the same or similar activities 

with funds from one or more of the granting agencies’ programs. 

Justice should also take steps to establish written policies and 

procedures to govern this coordination and help ensure that it occurs. 

GAO provided a draft of this report section to Justice for review and 

comment. Justice provided technical comments, which were incorporated 

as appropriate. In technical comments, Justice stated that using funding 

from multiple grant programs may be necessary to fully implement law 

enforcement projects in light of limited local and federal resources. GAO 

acknowledges that there may be cases where funding in this manner is 

warranted, but without an assessment of the extent of overlap across 

Justice grant programs, combined with consistent and routine grant 

award coordination, there is an increased risk of unnecessary duplication 

in grant awards. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted to be published as a separate product in 2012. To 

identify the total number of Justice grant solicitations for fiscal year 2010, 

GAO reviewed the lists posted on the OJP, COPS Office, and OVW 

websites and confirmed the currency of the information with Justice 

officials. To determine whether these solicitations were announcing grant 

funding available for similar purposes, GAO first established 10 

categories of criminal justice areas and then sorted the solicitations into 

each. GAO developed these 10 categories after reviewing comparable 

justice areas identified within OJP’s Crimesolutions.gov website, which 

OJP officials asserted also covers COPS Office and OVW programs; 

OJP’s Fiscal Year 2010 Program Plan; and other materials from the 

COPS Office and OVW, such as justice program themes from their 

Actions Needed and 

Potential Financial or 

Other Benefits 

Agency Comments 

and GAO’s Evaluation 

How GAO Conducted 

Its Work 
 

Page 118 GAO-12-342SP Duplication, Overlap, and Fragmentation 

respective websites.10

GAO also visited or conducted phone interviews with officials from 11 

states, including the five largest and five smallest state recipients of JAG 

funding.

After identifying solicitations with similar scopes, 

GAO reviewed a sample of successful grant applications that were 

awarded under the similar solicitations to identify and assess specific 

examples of how the recipients planned to use funds from multiple 

programs in the same or similar manner. The sample GAO reviewed is 

not generalizable to all Justice grant programs because GAO did not 

review all grant applications, including subgrants, but it provides evidence 

of the potential for unnecessary duplication. GAO also reviewed agency 

policies, procedures, and guidance on grant program design and award, 

such as the COPS Office Program Development Team charter and 

template, and the OJP Grant Managers Manual. Further, GAO 

interviewed Justice officials from the three granting agencies to obtain 

additional information on grant program design and award processes, and 

the extent to which the three agencies coordinate and share information. 

11 These officials represent the state administering agencies 

responsible for distributing JAG and other Justice formula block grant 

funds to subrecipients in California, Florida, New York, North Dakota, 

Pennsylvania, South Dakota, Rhode Island, Tennessee, Texas, Vermont, 

and Wyoming. These officials provided their views regarding the type and 

timeliness of information on grant awards and subawards they provide to

and receive from Justice. GAO selected these 11 states based on the 

amount of JAG funding they receive and the existence of other recipients 

in their communities receiving Justice discretionary grants for potentially 

similar purposes. The results of these contacts are not generalizable to all 

states, but provide insight into how Justice grant funds are used locally 

and into the communication between states and Justice. Finally, GAO 

compared agency grant design and award practices against Standards 

for Internal Control in the Federal Government and promising practices 

identified in the Domestic Working Group Grant Accountability Project’s 

Guide to Opportunities for Improving Grant Accountability. Appendix III 

lists the programs GAO identified that may have similar or overlapping 

objectives, provide similar services or be fragmented across government 

missions. Overlap and fragmentation may not necessarily lead to actual 

duplication, and some degree of overlap and duplication may be justified.

 

10OJP reports that its Crimesolutions.gov website uses rigorous research to inform 

practitioners and policy makers about what works in criminal justice, juvenile justice, and 

crime victim services. Though the categories on the website were not intended to 

categorize federal funding programs or exhaustively categorize every aspect of the 

criminal justice system, according to Justice officials, they do address the areas relevant 

to practitioners’ and researchers’ work. 

11Illinois was among the top five highest state recipients of JAG funding. However, state 

officials did not respond to GAO inquiries. Therefore GAO substituted Pennsylvania, which 

was the sixth largest recipient. In addition, Tennessee was not within these two categories 

but provided additional insight. 
 

Page 119 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Information Technology: Continued Attention Needed to Accurately 

Report Federal Spending and Improve Management. GAO-11-831T. 

Washington, D.C.: July 14, 2011.

Federal Grants: Improvements Needed in Oversight and Accountability 

Processes. GAO-11-773T. Washington, D.C.: June 22, 2011.

Recovery Act: Department of Justice Could Better Assess Justice 

Assistance Grant Program Impact. GAO-11-87. Washington, D.C.: 

October 15, 2010.

Juvenile Justice: A Time Frame for Enhancing Grant Monitoring 

Documentation and Verification of Data Quality Would Help Improve 

Accountability and Resource Allocation Decisions. GAO-09-850R. 

Washington, D.C.: September 22, 2009.

Grants Management: Additional Actions Needed to Streamline and 

Simplify Processes. GAO-05-335. Washington, D.C.: April 18, 2005.

For additional information about this area, contact David C. Maurer at 

(202) 512-9627, or maurerd@gao.gov. 

Related GAO 

Products

Contact Information
 

Page 120 GAO-12-342SP Duplication, Overlap, and Fragmentation 

17. Homeland Security Grants

The Department of Homeland Security needs better project information and coordination among four 

overlapping grant programs.

From fiscal years 2002 through 2011, the federal government 

appropriated over $37 billion to a variety of Department of Homeland 

Security (DHS) homeland security preparedness grant programs.1

As GAO reported in March 2011, DHS could benefit from examining its 17 

preparedness grant programs and coordinating their application 

processes; developing measurable capability requirements and 

evaluation criteria; and eliminating redundant reporting requirements.

Of this 

amount, the DHS’s Federal Emergency Management Agency (FEMA) 

allocated about $20.3 billion to grant recipients through four programs: 

the State Homeland Security Program, the Urban Areas Security 

Initiative, the Port Security Grant Program, and the Transit Security Grant 

Program. Through these grant programs, DHS has sought to enhance the 

capacity of states, localities, and other entities—such as ports or transit 

agencies—to prevent, respond to, and recover from a terrorism incident.

2

GAO also reported in February 2012 on 4 of these 17 grant programs— 

the State Homeland Security Program, the Urban Areas Security 

Initiative, the Port Security Grant Program, and the Transit Security Grant 

Program—and found that multiple factors contributed to the risk of FEMA 

funding unnecessarily duplicative projects. These factors include overlap 

among grant recipients, goals, and geographic locations, combined with 

the limited project information that FEMA had available regarding grant 

funding levels, grant recipients, and grant purposes.3

GAO has previously reported that overlap among government programs 

or activities can be harbingers of unnecessary duplication.4 The four DHS

grant programs that GAO reported on in February 20125

 

1

This total is based on Congressional Research Service data and GAO analysis, and 

includes firefighter assistance grants and emergency management performance grants. 

See Congressional Research Service, Department of Homeland Security Assistance to 

States and Localities: A Summary of Issues for the 111th Congress, R40246 (Washington, 

D.C.: Apr. 30, 2010).

––the State 

2

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

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

3

GAO, Homeland Security: DHS Needs Better Project Information and Coordination 

Among Four Overlapping Grant Programs, GAO-12-303 (Washington, D.C.: February 28, 

2012).

4

GAO-11-318SP. 

5

GAO-12-303. 

Why This Area Is 

Important

What GAO Found
 

Page 121 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Homeland Security Program, the Urban Areas Security Initiative, the Port 

Security Grant Program, and the Transit Security Grant Program—have 

multiple areas of overlap. The grant programs have similar goals and fund 

similar activities, such as equipment and training, in overlapping 

jurisdictions. For instance, each state and eligible territory receives a 

legislatively mandated minimum amount of State Homeland Security 

Program funding to help ensure that all geographic areas develop a basic 

level of preparedness, while the Urban Areas Security Initiative grants 

explicitly target urban areas most at risk of terrorist attack.6

Further, depending on the program, other federal stakeholders in addition 

to FEMA are involved in the administration or coordination of some, but 

not all, of the four programs. The table below illustrates overlap in the 

purposes and types of projects funded by the four grant programs.

However, 

many jurisdictions within designated Urban Areas Security Initiative 

regions also apply for and receive State Homeland Security Program 

funding. Similarly, port stakeholders in urban areas could receive funding 

for equipment such as patrol boats through both the Port Security Grant 

Program and the Urban Areas Security Initiative, and a transit agency 

could purchase surveillance equipment with Transit Security Grant 

Program or Urban Areas Security Initiative funding.

Federal Agencies, Purpose, and Project Type Involved in Select Homeland Security Grants

State Homeland 

Security Grant Program 

Urban Areas Security 

Initiative 

Port Security Grant 

Program 

Transit Security Grant 

Program 

Primary federal 

agencies involved 

Federal Emergency 

Management Agency

Federal Emergency 

Management Agency

Federal Emergency 

Management Agency/ 

U.S. Coast Guard

Federal Emergency 

Management Agency/ 

Transportation Security 

Administration

Purpose of the grant 

program 

The State Homeland 

Security Program

provides funding to 

support state and local 

efforts to prevent, protect 

against, respond to, and 

recover from acts of 

terrorism and other 

catastrophic events.

The Urban Areas Security 

Initiative provides funding 

to high-risk urban areas to 

build and sustain regional 

capabilities to prevent, 

protect, respond to, and 

recover from acts of 

terrorism. 

The Port Security Grant 

Program provides funding 

to port stakeholders to 

mitigate against risks 

associated with potential 

terrorist attacks by 

enhancing capabilities to 

detect, prevent, respond 

to and recover from 

terrorist attacks. 

The Transit Security 

Grant Program provides 

funds to public transit 

agencies to protect critical 

surface transportation 

infrastructure and the 

traveling public from acts 

of terrorism and to 

increase the resilience of 

transit infrastructure.

Types of projects 

funded

• Planning

• Organization

• Equipment

• Training

• Exercises 

• Planning

• Organization

• Equipment

• Training

• Exercises 

• Maritime domain 

awareness efforts

• Planning

• Equipment

• Training

• Exercises 

• Supporting port 

resiliency and 

recovery

• Capital infrastructure 

projects

• Operational activities

• Planning

• Equipment

• Training

• Exercises 

Source: Federal Emergency Management Agency grant guidance.

 

6

See 6 U.S.C. §§ 604, 605. 
 

Page 122 GAO-12-342SP Duplication, Overlap, and Fragmentation 

As GAO reported in February 2012, FEMA made award decisions for all 

four programs with differing levels of information which contributes to the 

risk of funding unnecessarily duplicative projects. While GAO understands 

that some overlap may be desirable to provide multiple sources of funding, 

a lack of visibility over grant award details around these programs 

increases the risk of unintended and unnecessary duplication. Some of the 

factors that contributed to the differences in the information available 

include different administrative processes and information requirements. 

With respect to administrative differences, FEMA delegates some 

administrative duties to stakeholders for the State Homeland Security 

Program, the Urban Areas Security Initiative and the Port Security Grant 

Program, thereby reducing its administrative burden according to FEMA 

officials. However, this delegation also contributes to FEMA having less 

visibility over some grant applications, and in particular those funded by the 

State Homeland Security Program and the Urban Areas Security Initiative. 

These two programs are administered by state administrative agencies;

7

Differences in information requirements also affect the level of information 

that FEMA has available for making grant award decisions. For example, 

for the State Homeland Security Program and Urban Areas Security 

Initiative, states and eligible urban areas submit investment justifications 

for each program with up to 15 distinct investment descriptions that 

describe general proposals in wide-ranging areas such as “critical 

infrastructure protection.”

however, some administrative functions are further delegated to 

subrecipients such as local governments or other entities. In contrast, 

Transit Security Grant Program awards are made directly to the final grant 

recipients and this more direct award structure, among other factors, allows 

FEMA to better track these grant awards. In delegating significant grants 

administration duties to the state administrative agencies for the larger 

State Homeland Security Program and Urban Areas Security Initiative 

programs, FEMA officials recognize the trade-off between decreased 

visibility over grant funding, subrecipients, and specific project-level data in 

exchange for their reduced administrative burden.

8

 

7

A designated state administrative agency is responsible for managing the State 

Homeland Security Program and Urban Areas Security Initiative programs at the state 

level. This management includes processing project applications prior to submitting them 

to FEMA, “passing though” federal funds to regional or local entities, and ensuring that 

local grant recipients comply with various statutory and grant requirements.

Each investment justification encompasses 

multiple specific projects to different jurisdictions or entities, but projectlevel information, such as a detailed listing of subrecipients or equipment 

costs, is not required by FEMA. In contrast, Port Security Grant Program 

8

Investment justifications are one component of the State Homeland Security Program, 

the Urban Areas Security Initiative, the Port Security Grant Program, and the Transit 

Security Grant Program applications for grant funding. They provide narrative information 

on proposed activities (investments) that will be accomplished with the grant funds and 

are described in more detail later in this report. The investment justifications must 

demonstrate how proposed investments address gaps and deficiencies in current 

capabilities, and also demonstrate adherence to program guidance. 
 

Page 123 GAO-12-342SP Duplication, Overlap, and Fragmentation 

and Transit Security Grant Program applications require specific 

information on individual projects such as detailed budget summaries. As 

a result, FEMA has a much clearer understanding of what is being 

requested and what is being funded by these programs.

FEMA has studied the potential utilization of more specific project-level

data for making grant award decisions, especially for the State Homeland 

Security Program and Urban Areas Security Initiative.9 Specifically, a May 

2011 FEMA report recommended that the agency modify the investment 

justification format for the Urban Areas Security Initiative and the State 

Homeland Security Program applications to include a detailed project 

list.10

Specifically, GAO reviewed the type of information that FEMA would have 

available at the applications stage if it implemented the May 2011 report

recommendation. GAO’s analysis of 1,957 projects,

This project list would contain information that is currently collected 

later in the grant cycle in the post-award phase. However, while GAO's 

analysis of selected grant projects determined that this additional 

information was sufficient for identifying potentially unnecessary 

duplication for nearly all of the projects it reviewed, the information did not 

always provide the FEMA with sufficient detail to identify and prevent the 

risk of unnecessary duplication.

11

 

9

In August 2009, FEMA established the Reporting Requirements Working Group to 

compile a list of select grant reporting activities, collect grant stakeholder feedback, and 

make recommendations regarding future data collection policies. FEMA utilized the 

working group’s analysis and recommendations in a May 2011 Report to Congress.

using post-award 

information as recommended in the report, determined that over 1,800 of 

the projects representing about 90 percent of the overall funding had the 

detail needed to determine whether they were unnecessarily duplicative. 

However, 140 projects, or 9.2 percent of the overall funding associated 

with the 1,957 projects––about $183 million––lacked sufficient detail to 

determine whether they were unnecessarily duplicative or had involved 

coordination during the state’s planning or selection processes to prevent 

any unnecessary duplication. For example, in one instance GAO 

identified overlap in the descriptions of the project types and titles of State 

Homeland Security Program, Urban Areas Security Initiative, and Port 

Security Grant Program grants that funded critical infrastructure 

improvements in a single port area. This overlap suggested that 

duplication could be occurring among the grant programs, and warranted 

further analysis.

10See FEMA, Redundancy Elimination and Enhanced Performance for Preparedness 

Grants Act: Initial Report to Congress (Washington, D.C.: May 23, 2011) for their findings 

and recommendations.

11We reviewed investment justification and Biannual Strategy Implementation Report 

information––The Biannual Strategy Implementation Report is a reporting requirement 

submitted by states to FEMA regarding the progress of certain grants––for the 1,957 grant 

projects awarded through the four grant programs to five urban areas: Houston, Jersey 

City/Newark, New York City, San Francisco, and Seattle for fiscal years 2008 through 

2010.
 

Page 124 GAO-12-342SP Duplication, Overlap, and Fragmentation 

After gathering additional information from state and local grant 

recipients, however, GAO determined that none of the projects it 

reviewed were duplicative. While implementing the May 2011 report 

recommendation to better utilize more specific project-level data would be 

a step in the right direction, the Director of FEMA’s Grants Preparedness 

Division reported in September 2011 that FEMA had not yet determined 

the specifics of future data requirements related to the report’s 

recommendation. GAO was able to ascertain that over 90 percent of the 

projects it reviewed had sufficient detail to determine that the projects 

were not likely duplicative. However, GAO believes that more detailed 

project information could be of value to FEMA in its grant review process 

since the information that would be gathered and considered, if the 

report’s recommendation were implemented, would not always allow for 

the necessary differentiation between projects funded by the four grant 

programs. Moreover, DHS’s Office of Inspector General has also 

concluded in recent years that FEMA should utilize more specific projectlevel data in making grant award decisions, especially for the State 

Homeland Security Program and Urban Areas Security Initiative, in order 

to identify and mitigate potential duplication.12

Another effort that FEMA has initiated to improve its grant information is 

the phase-in of a new consolidated grants management system—the 

Non-Disaster Grants system. Agency officials stated that this system, 

once completed, will help FEMA manage all of its preparedness grants, 

and has an explicit goal of enhancing project-level data collection. In 

addition, FEMA anticipates that the Non-Disaster Grants system will 

consolidate data from multiple systems and facilitate greater utilization 

and sharing of information. However, according to FEMA documentation, 

the agency has not yet determined all of its specific data needs for the 

system. As FEMA continues to develop the Non-Disaster Grants system, 

it will be important to ensure that it collects the level of data needed, as 

appropriate, to compare projects across grant programs to mitigate the 

risk of funding unnecessarily duplicative projects. GAO recognizes that 

collecting more detailed project information through the new system could 

involve additional costs. However, collecting additional information with 

this level of detail could help better position FEMA to ensure that it is 

using its resources effectively.

GAO also reported in February 2012 that FEMA lacks a process to 

coordinate application reviews across the four grant programs. FEMA’s 

Grants Program Directorate has divided the administration of the grant 

programs into two separate branches: The Urban Areas Security Initiative 

and State Homeland Security Program are administered by a Homeland 

Security Grant Program branch, while the Port Security Grant Program 

and Transit Security Grant Program are administered by a Transportation 

 

12Department of Homeland Security Office of Inspector General, Efficacy of DHS Grant 

Programs, OIG-1069 (Washington, D.C.: Mar. 22, 2010).
 

Page 125 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Infrastructure Security branch. The result of this structure is that grant 

applications are reviewed separately by program and are not compared 

across each other to determine where possible unnecessary duplication 

may occur. Similar findings were also reported by the DHS Inspector 

General in March 2010.

As noted earlier, each grant program GAO reviewed has similar goals, 

allowable costs, and geographic proximity. As a result, these four 

programs share applicants as state and local entities seek to maximize 

grant dollars for their projects; however, FEMA does not compare 

applications, including the investment justifications, for these overlapping 

grant programs. As a result, neither FEMA nor an independent third party 

is positioned to determine where unnecessary duplication may occur.

Because the applications for the four grant programs are being reviewed 

by two separate divisions, yet have similar allowable costs, GAO and the 

DHS Inspector General concluded that coordinating the review of grant 

projects internally would give FEMA more complete information about 

applications across the four grant programs. This additional information 

could help FEMA identify and mitigate the risk of unnecessary duplication 

across grant applications. A FEMA Grants Program Directorate Section 

Chief noted that the primary reasons for the current lack of coordination 

across programs are the sheer volume of grant applications that need to 

be reviewed and FEMA’s lack of resources to coordinate the grant 

application review process. GAO recognizes the challenges associated 

with reviewing a large volume of grant applications, but to help reduce the 

risk of funding unnecessarily duplicative projects, FEMA could benefit 

from exploring opportunities to coordinate project reviews across grant 

programs while also taking into account the large volume of grant 

applications it must process.

In addition, from fiscal year 2010 to 2012, appropriations for DHS’s

preparedness grant programs declined from $3.02 billion to $1.35 

billion—or about 55 percent.13 Further, the consolidated appropriations 

act for fiscal year 2012 combined funding for DHS’s preparedness grant 

programs into a single appropriation and provided the Secretary of 

Homeland Security with the discretion to distribute this funding amongst 

the suite of preparedness grant programs.14

 

13 This total is comprised of preparedness grant programs in FEMA’s state and local 

programs account, which does not include firefighter assistance grants and emergency 

management performance grants.

Specifically, the 

appropriations for these four programs declined by about $487 million—or 

about 20 percent—from fiscal year 2010 to 2011. However, the fiscal year 

2012 funding levels for these four programs are unclear at this time 

because the Secretary of Homeland Security has not yet determined how 

to distribute available funding amongst the grant programs. Given the 

14See H.R. Rep. No. 112-331, at 175-77 (2011) (Conf. Rep.).
 

Page 126 GAO-12-342SP Duplication, Overlap, and Fragmentation 

significant overlap in these grant programs and the risk of unnecessary 

duplication, requiring additional information on FEMA’s efforts to identify 

and eliminate overlap may be helpful to the Congress as it makes future 

decisions regarding preparedness grant funding.

The State Homeland Security Program, Urban Areas Security Initiative, 

Port Security Grant Program, and Transit Security Grant Program have 

similar goals and fund similar activities in overlapping jurisdictions. In a 

constrained budget environment, it is important for FEMA to have the 

information it needs about projects funded through these programs and to 

coordinate their administration to maximize their impacts on improving 

homeland security and avoid the risk of any unnecessary duplication. 

Although reviewing a large volume of grant applications is challenging, 

these reviews are important to better ensure that FEMA is able to identify 

and prevent any potential unnecessary duplication, and that limited grant 

resources are used effectively.

GAO recommended in its February 2012 report that to help reduce the 

risk of unnecessary duplication by strengthening the administration and 

oversight of these programs, the FEMA Administrator should

• take steps, when developing the Non-Disaster Grants system and 

responding to the FEMA May 2011 report recommendations on data 

requirements, to ensure that FEMA collects project information with 

the level of detail needed to better position the agency to identify any 

potential unnecessary duplication within and across the four grant 

programs, weighing any additional costs of collecting this data; and

• explore opportunities to enhance FEMA’s internal coordination and 

administration of the programs in order to identify and mitigate the 

potential for any unnecessary duplication.

In addition to these recommendations to DHS from GAO’s February 2012 

report, Congress may also want to consider

• requiring DHS to report on the results of its efforts to identify and 

prevent unnecessary duplication within and across the State 

Homeland Security Program, Urban Areas Security Initiative, Port 

Security Grant Program, and Transit Security Grant Program, and 

considering these results when making future funding decisions for 

these programs.

GAO provided a draft of this report section to DHS for review and 

comment. DHS provided technical comments, which were incorporated 

as appropriate.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 127 GAO-12-342SP Duplication, Overlap, and Fragmentation 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. GAO took several 

actions to determine how FEMA awarded grant funds and how funds 

were distributed. GAO interviewed officials at DHS and FEMA and visited 

five urban areas that contained grant recipients for all four grant programs 

and were among the highest annual grant recipients in fiscal year 2010 

due to their risk profile. In each of these locations, GAO interviewed 

officials responsible for administering the program (state and local 

officials for the State Homeland Security Program/Urban Areas Security 

Initiative; fiduciary agents for the Port Security Grant Program; and transit 

agency officials for Transit Security Grant Program). GAO also met with 

grant recipients and members of the local coordination or project 

selection groups (e.g., Urban Area Working Group for the Urban Areas 

Security Initiative). Additionally, GAO reviewed grant guidance, legislation 

and prior GAO and Department of Homeland Security Inspector General 

reports; analyzed grant awards; and reviewed state and national plans 

related to homeland security grant programs. Appendix III lists the 

programs GAO identified that may have similar or overlapping objectives, 

provide similar services or be fragmented across government missions. 

Overlap and fragmentation may not necessarily lead to actual duplication, 

and some degree of overlap and duplication may be justified.

Homeland Security: DHS Needs Better Project Information and 

Coordination among Four Overlapping Grant Programs. GAO-12-303. 

Washington, D.C.: February 28, 2012.

Port Security Grant Program: Risk Model, Grant Management, and 

Effectiveness Measures Could Be Strengthened. GAO-12-47. 

Washington, D.C.: November 17, 2011.

Urban Area Security Initiative: FEMA Lacks Measures to Assess How 

Regional Collaboration Efforts Build Preparedness Capabilities. 

GAO-09-651. Washington, D.C.: July 2, 2009.

Transit Security Grant Program: DHS Allocates Grants Based on Risk, 

but Its Risk Methodology, Management Controls, and Grant Oversight 

Can Be Strengthened. GAO-09-491. Washington, D.C.: June 8, 2009.

Homeland Security: DHS Improved its Risk-Based Grant Programs’ 

Allocation and Management Methods, But Measuring Programs’ Impact 

on National Capabilities Remains a Challenge. GAO-08-488T. 

Washington, D.C.: March 11, 2008.

For additional information about this area, contact David C. Maurer at 

(202) 512-9627 or maurerd@gao.gov.

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 128 GAO-12-342SP Duplication, Overlap, and Fragmentation 

18. Federal Facility Risk Assessments

Agencies are making duplicate payments for facility risk assessments by completing their own assessments, 

while also paying the Department of Homeland Security for assessments that the department is not 

performing. 

Since the 1995 bombing of the Alfred P. Murrah Federal Building in 

Oklahoma City, Oklahoma, and the September 11, 2001, terrorist attacks, 

the federal government has made significant changes in its approach to 

protecting federal facilities and the more than 1 million employees and 

members of the public that work in and visit these facilities annually. 

However, federal facilities continue to be vulnerable to terrorist attacks 

and other acts of violence, as evidenced by the 2010 attacks on the 

Internal Revenue Service (IRS) building in Austin, Texas, and the federal 

courthouse in Las Vegas, Nevada, which resulted in loss of life. These 

attacks highlight the importance of protecting federal facilities by, among 

other things, conducting timely and comprehensive risk assessments, 

which can help decision makers identify and evaluate potential threats so 

that countermeasures can be implemented to help prevent or mitigate the 

facilities’ vulnerabilities to those threats.

The Department of Homeland Security’s (DHS) Federal Protective 

Service (FPS) is the primary federal agency responsible for providing 

physical security and law enforcement services—including conducting 

risk assessments—for the approximately 9,000 federal facilities owned or 

leased by the General Services Administration (GSA).1 Risk assessments 

for federal facilities, which FPS refers to as facility security assessments, 

are to be completed every 3 to 5 years according to DHS’s Interagency 

Security Committee (ISC) standards.2

 FPS’s assessments are to include 

a full examination of the facility, including a review of access points to the 

facility and the security of the facility’s perimeter, such as closed circuit 

television monitoring and lighting. Its risk assessment process entails 

gathering and reviewing facility information; conducting and recording 

interviews with tenant agencies; assessing the threats, vulnerabilities, and 

consequences associated with a facility; and recommending appropriate 

countermeasures in accordance with ISC standards to mitigate

vulnerabilities to tenant agencies.

 

1

GAO is referring to facilities that are under GSA’s control and custody as GSA-owned or 

leased facilities.

2

The ISC, composed of representatives from 50 federal agencies and departments, was 

established under Executive Order 12977 to enhance the quality and effectiveness of 

security and protection of buildings and facilities in the United States occupied by federal 

employees for nonmilitary activities. 

Why This Area Is 

Important
 

Page 129 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO has found that there is duplication in the federal government’s 

approach to assessing risks at some of the 9,000 federal facilities 

managed by GSA. As GAO reported in June 2008 and as it has recently 

found, multiple federal agencies are expending additional resources to 

assess their own facilities; although, according to an FPS official, the 

agency received $236 million from federal agencies for risk assessments 

and other security services in fiscal year 2011. For example, an official 

from IRS said that IRS completed risk assessments based on concerns 

about risks unique to its mission for approximately 65 facilities that it also 

paid FPS to assess. Additionally, an official from the Federal Emergency 

Management Agency (FEMA) stated that FEMA has assessed its own 

facilities for several years because of dissatisfaction with the security 

levels FPS has assigned to its facilities, and Environmental Protection 

Agency (EPA) officials said that EPA has conducted its own assessments 

based on concerns with the quality and thoroughness of FPS’s 

assessments.3

According to an FPS official, FPS planned to use its Risk Assessment 

and Management Program (RAMP) to complete assessments of about 

700 federal facilities in fiscal year 2010 and 2,500 facilities in fiscal year 

2011. However, since November 2009, according to an FPS official, the 

agency has only completed four risk assessments using RAMP, which 

does not provide adequate assurance that FPS is utilizing an effective 

risk management approach to help protect federal facilities and may 

contribute to more agencies completing their own assessments. RAMP 

was intended to provide FPS with the capability to assess risks at federal 

facilities based on threat, vulnerability, and consequence; and track 

countermeasures to mitigate those risks. As GAO reported in July 2011, 

FPS experienced cost overruns, schedule delays, and operational issues 

with developing RAMP and as a result the agency could not use it to 

complete risk assessments. Without risk assessments that identify threats 

and vulnerabilities and the resources required to achieve security goals, 

FPS has only limited assurance that programs will be prioritized and 

resources will be allocated to address existing and potential security 

threats in an efficient and effective manner. GAO recommended in July 

2011 that FPS develop interim solutions for completing risk assessments 

while addressing RAMP’s challenges. FPS agreed with this 

recommendation and is in the process of developing an interim 

assessment tool.

EPA officials also said that the agency’s assessments are 

conducted by teams of contractors and EPA employees, cost an 

estimated $6,000, and can take a few days to a week to complete. An 

official from the U.S. Army Corps of Engineers told GAO that it duplicates 

FPS’s assessments at some of its regional facilities because the agency 

follows U.S. Army force protection regulations, rather than the security 

requirements followed by FPS.

 

3

FPS is responsible for coordinating with tenant agencies to determine a facility’s security

level, which ranges from I (lowest risk level) to V (highest risk level).

What GAO Found
 

Page 130 GAO-12-342SP Duplication, Overlap, and Fragmentation 

As noted above, FPS charged federal agencies $236 million in basic 

security fees for risk assessments and security services in fiscal year 

2011, although FPS has completed few risk assessments using RAMP.4

As GAO reported in May 2011, FPS does not know how much of the 

basic security fee is used for completing risk assessments of federal 

facilities. Nonetheless, FPS increased the basic security fee from $.66 in 

fiscal year 2011 to $.74 per square foot in fiscal year 2012. GAO 

recommended in May 2011 that FPS make information on the estimated 

costs of key activities, as well as the basis for these cost estimates, 

readily available to affected parties to improve the transparency of the 

process for setting and using the fees.

GAO has found that multiple federal agencies are incurring additional 

costs by completing their own assessments while paying FPS to complete 

risk assessments for the same facilities. However, DHS has not taken any 

actions to address the duplication and it is not clear whether FPS’s 

planned risk assessment tool will help minimize duplication. Achieving the 

financial and other benefits that may result from reducing duplication and 

increased cost that occurs in assessing risks at federal facilities will 

require additional effort on the part of DHS and other key stakeholders.

GAO recommended in July 2011 that the Secretary of DHS 

• direct the Director of FPS to develop interim solutions for completing 

risk assessments while addressing RAMP’s challenges. 

GAO recommended in May 2011 that the Director of FPS 

• make information about the estimated costs of key activities and the 

basis for these estimates available to affected parties to improve 

transparency.

In addition, DHS should 

• work with federal agencies to determine their reasons for duplicating 

the activities included in FPS’s risk assessments and identify 

measures to reduce this duplication.

 

4

In addition to risk assessments, the $236 million in basic security fees funds security 

services including ongoing review of facility countermeasures to ensure they are 

functioning as designed; assistance with emergency planning and exercises; response to 

criminal incidents and reports of suspicious activity; patrol of facilities to deter and detect 

criminal activity; and awareness training to inform tenants how to prevent and react to 

events in the facility.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 131 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO provided a draft of this report section to DHS for review and 

comment. DHS agreed with GAO’s previous two recommendations and 

has begun action on both. DHS did not provide comments on GAO’s 

newly identified action needed. DHS also provided technical comments, 

which were incorporated as appropriate. In its response, DHS stated that 

although FPS has only completed four risk assessments using RAMP, the 

agency is collecting data, through site visits, interviews of facility 

occupants, and evaluation of countermeasures, which will be used to 

generate risk assessments when its interim assessment tool is 

implemented in spring 2012. As part of its routine audit work, GAO will 

track agency action to address these recommendations and report to 

Congress.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section and additional work 

GAO conducted to be published as a separate product in 2012. To

update that information and identify continuing issues related to 

duplication and overlap in risk assessments for federal facilities, GAO 

interviewed officials from FPS, EPA, FEMA, GSA, Immigration and 

Customs Enforcement, IRS, U.S. Army Corps of Engineers, and the 

Department of Veterans Affairs.

Federal Protective Service: Actions Needed to Resolve Delays and 

Inadequate Oversight Issues with FPS’s Risk Assessment and 

Management Program. GAO-11-705R. Washington, D.C.: July 15, 2011.

Budget Issues: Better Fee Design Would Improve Federal Protective 

Service’s and Federal Agencies’ Planning and Budgeting for Security.

GAO-11-492. Washington, D.C.: May 20, 2011.

Homeland Security: The Federal Protective Service Faces Several 

Challenges That Raise Concerns About Protection of Federal Facilities.

GAO-08-914T. Washington, D.C.: June 18, 2008.

Homeland Security: The Federal Protective Service Faces Several 

Challenges That Hamper Its Ability to Protect Federal 

Facilities.GAO-08-683. Washington, D.C.: June 11, 2008.

For additional information about this area, contact Mark Goldstein at (202)

512-2834 or goldsteinm@gao.gov and Susan J. Irving at (202) 512-6806 

or irvings@gao.gov. 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 132 GAO-12-342SP Duplication, Overlap, and Fragmentation 

19. Information Technology Investment 

Management 

The Office of Management and Budget, and the Departments of Defense and Energy need to address 

potentially duplicative information technology investments to avoid investing in unnecessary systems.

The Office of Management and Budget (OMB) has reported that the 

federal government spends billions of dollars on information technology 

(IT) investments each year. In fiscal year 2011, there were approximately 

7,200 investments totaling at least $79 billion. The Department of 

Defense (DOD) reported the largest number of information technology 

(IT) investments (2,383 investments at $37 billion), followed by the 

Department of Energy (Energy) (876 investments and $2 billion).

According to OMB’s annual budget guidance (beginning with fiscal year 

2004), agencies are required to map each IT investment to a functional 

category and sub-category within the Federal Enterprise Architecture.1

These categorizations, known as a primary function and subfunction are 

intended to enable OMB and others to analyze investments with similar 

functions, as well as identify and analyze potentially duplicative 

investments across agencies.

As GAO reported in September 2011, in their fiscal year 2011 budget 

submissions to OMB on IT spending, agencies reported the greatest 

number of IT investments in the information and technology management 

category (1,536 investments), followed by supply chain management (777 

investments), and human resources management (622 investments).2

 

1

The Federal Enterprise Architecture is intended to provide federal agencies and other 

decision makers with a common frame of reference or taxonomy for informing agencies’ 

individual enterprise architecture efforts and their planned and ongoing investment 

activities, and to do so in a way that identifies opportunities for avoiding duplication of 

effort and launching initiatives to establish and implement common, reusable, and 

interoperable solutions across agency boundaries.

Similarly, planned expenditures on investments were greatest in the 

information and technology management category, at about $35.5 billion. 

The figure below depicts the total number of investments governmentwide 

per function.

2

GAO, Information Technology: OMB Needs to Improve Its Guidance on IT Investments, 

GAO-11-826 (Washington, D.C.: Sept. 29, 2011).

Why This Area Is 

Important

What GAO Found
 

Page 133 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Number of IT Investments Governmentwide by Primary Function, as of July 2011 (fiscal year 2011 planned expenditures, in 

billions)

GAO reported that OMB provides guidance to agencies on how to report 

on their IT investments, but this guidance does not ensure complete 

reporting or facilitate the identification of duplicative investments. 

Specifically, agencies differ on what investments they include as an IT 

investment; for example, 5 of the 10 agencies GAO reviewed consistently 

consider investments in research and development systems as IT, and 5 

do not. As a result, federal agencies’ annual IT investments are likely 

greater than the $79 billion reported in fiscal year 2011. In addition, 

OMB’s guidance to federal agencies requires each investment to be 

mapped to a single functional category. This limits OMB’s ability to 

identify duplicative investments both within and across agencies because 

similar investments may be organized into different categories. For 

example, GAO reported on a DOD financial management system that 

was identified in a different functional category—supply chain 

management.3

GAO also reported that OMB and federal agencies have undertaken 

several initiatives to address potentially duplicative IT investments. For 

example, OMB has efforts under way to consolidate similar functions 

through its Federal Enterprise Architecture initiative, which was developed 

in 1999. This initiative was intended to provide federal agencies with a 

common construct for their architectures and thereby facilitate the 

 

3

GAO, Financial Management Systems: OMB's Financial Management Line of Business 

Initiative Continues but Future Success Remains Uncertain, GAO-09-328 (Washington, 

D.C.: May 7, 2009). 
 

Page 134 GAO-12-342SP Duplication, Overlap, and Fragmentation 

coordination of common business processes, and system investments 

among federal agencies. In 2004, we reported that the Federal Enterprise 

Architecture was a work in progress and was still evolving.4

More recently, GAO conducted a review to examine the three largest 

categories of IT investments within DOD, Energy, and the Department of 

Homeland Security (DHS). Specifically, as GAO reported in February 

2012, although DOD, Energy, and DHS use various investment review 

processes to identify duplicative investments, GAO found that 37 of 

GAO’s sample of 810 investments were potentially duplicative at DOD 

and Energy (see table below).

To this point, 

OMB’s Chief Architect reported that comprehensive changes to the Federal 

Enterprise Architecture are underway and planned for fiscal year 2012. In 

addition, most of the agencies GAO reviewed established guidance for 

ensuring new investments are not duplicative with existing systems. 

However, agencies do not routinely assess operational systems to 

determine if they are duplicative. Therefore, GAO reported that until 

agencies routinely assess their IT investment portfolios to identify and 

reduce duplicative systems, the government’s current situation of having 

hundreds of similar IT investments will continue to exist.

5 These investments account for about $1.2 

billion in IT spending for fiscal years 2007 through 2012, for these two 

agencies. To identify these potentially duplicative investments, GAO 

reviewed the description of each investment’s purpose within specific 

functional categories and subcategories to identify similarities among 

related investments within each agency. This formed the basis of 

establishing groupings of similar investments. GAO discussed the 

groupings with each of the selected agencies, and GAO obtained further 

information from agency officials and reviewed and assessed agencies’ 

rationales for having multiple systems that perform similar functions. For 

example, GAO identified four DOD Navy personnel assignment 

investments—one system for officers, one for enlisted personnel, one for 

reservists, and a general assignment system—each of which is 

responsible for managing similar functions. The Department of the Navy 

is implementing an executive oversight board and a centralized review 

process of IT investments that officials reported will examine these 

investments to determine if actual duplication exists. The table below 

summarizes 12 groups of potentially duplicative investments by purpose 

and agency, which GAO identified.

 

4

GAO, Information Technology: The Federal Enterprise Architecture and Agencies’ 

Enterprise Architectures Are Still Maturing, GAO-04-798T (Washington, D.C.: May 19, 

2004).

5

GAO, Information Technology: Departments of Defense and Energy Need to Address 

Potentially Duplicative Investments, GAO-12-241. Washington, D.C.: February 17, 2012.
 

Page 135 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Potentially Duplicative Investments for DOD and Energy, as of January 2012

Dollars in millions

Department Branch/bureau Purpose

Number of 

investments

Planned or actual 

spending fiscal 

years 2007-2012 

DOD Air Force Contract Management 5 $41

Army Personnel Assignment Management 2 12

Navy Acquisition Management 4 407

Aviation Maintenance and Logistics 2 85

Contract Management 5 17

Housing Management 2 5 

Personnel Assignment Management 4 28

Promotion Rating 2 3 

Workforce Management 3 109

DOD-enterprisewide Civilian Personnel Management 2 504

Energy Energy Programs Back-end Infrastructure 3 1 

Energy Programs & Environmental 

and Other Defense Activities

Electronic Records and Document 

Management

3 7 

Total 37 $1,219

Source: GAO analysis of agency data.

While GAO did not identify any potentially duplicative investments at DHS 

within GAO’s sample, DHS officials have independently identified several 

duplicative investments and systems. Specifically, DHS officials have 

identified and, more importantly, reduced duplicative functionality in four 

investments, including a personnel security investment, time and 

attendance investment, human resources investment, and an information 

network investment. DHS also has plans to further consolidate systems 

within these investments by 2014, which is expected to produce 

approximately $41 million in cost savings. DHS officials have also 

identified 38 additional systems that they have determined to be 

duplicative. For example, officials identified multiple personnel action 

processing systems that could be consolidated.

Officials from the three agencies offered a variety of reasons for the 

potential duplication, such as decentralized governance within the 

department and a lack of control over certain facilities. Further 

complicating agencies’ ability to identify and eliminate duplicative 

investments is that investments are, in certain cases, misclassified by 

function. For example, DHS’s Federal Emergency Management 

Agency—Minor Personnel/Training Systems investment was initially 

categorized within the Employee Performance Management subfunction, 

but DHS agreed that this investment should be assigned to the Human 

Resources Development subfunction. Proper categorization is necessary 

in order to analyze and identify duplicative investments, both within and 

across agencies. GAO reported that until DOD, Energy, and DHS, 

correctly categorize their investments, they are limiting their ability to 

identify opportunities to consolidate or eliminate duplicative investments.
 

Page 136 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO also reported that DHS had taken action to improve its processes 

for identifying and eliminating duplicative investments. For example, 

through reviewing portfolios of IT investments, DHS had identified much, 

and eliminated some, duplicative functionality in certain investments—as 

previously discussed. Additionally, DOD and Energy had recently initiated 

specific plans to address potential duplication in many of the investments 

GAO identified—such as plans to consolidate or eliminate systems. While 

these efforts could eventually yield results, DOD’s and Energy’s initiatives 

had not yet led to the consolidation or elimination of duplicative 

investments or functionality. For example, while DOD and Energy had 

documented milestones for improving their IT investment review 

processes, officials did not provide examples of duplicative investments 

that they had consolidated or eliminated. Therefore, GAO reported that 

until DOD and Energy demonstrate, through existing transparency 

mechanisms, that they are making progress in identifying and eliminating 

duplicative investments, it will remain unclear whether they are avoiding 

investment in unnecessary systems.

To better ensure the agencies avoid investing in duplicative investments, 

GAO recommended in September 2011 that the Director of OMB

• clarify guidance to federal agencies in reporting on their IT 

investments by specifying whether certain types of systems should be 

included;

• require federal agencies to report the steps they take to ensure that 

their IT investments are not duplicative as part of their annual budget 

and IT investment submissions; and

• revise guidance to federal agencies on categorizing IT investments to 

ensure that the categorizations are clear and allow agencies to 

choose secondary categories.

Additionally, GAO recommended in February 2012 that the Secretaries of 

DOD and Energy should direct their Chief Information Officers to 

• utilize existing transparency mechanisms to report on the results of 

their efforts to identify and eliminate, where appropriate, each 

potentially duplicative investment GAO identified, as well as any other 

duplicative investments.

GAO also recommended in February 2012 that the Secretaries of DOD, 

Energy, and DHS should direct their Chief Information Officers to

• correct the miscategorizations for the investments GAO identified and 

ensure that investments are correctly categorized in agency 

submissions.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 137 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO provided a draft of its September 2011 report to OMB for review and 

comment. OMB disagreed with the first recommendation and agreed with 

the second and third recommendations. Specifically, OMB officials do not 

plan to implement the first recommendation, because they believe 

guidance already exists on categorizing and identifying IT investments. 

However, GAO believes that the recommendation is appropriate because 

the existing guidance does not address key categories of IT investments 

where GAO found inconsistencies among agencies. OMB officials stated 

that the agency plans to address the second and third recommendations 

through updated guidance and the annual budget process.

GAO provided a draft of its February 2012 report to OMB, DOD, Energy, 

and DHS for review and comment. OMB provided technical comments 

that GAO incorporated, where appropriate. DOD and DHS generally 

agreed with the recommendations, while Energy agreed with the first 

recommendation, but not the second. Specifically, Energy disagreed that 

two of the four investments GAO identified were miscategorized, 

explaining that their categorizations reflect funding considerations. 

However, OMB guidance indicates that investments should be classified 

according to their intended purpose. Consequently, GAO believes the 

recommendation is warranted.

GAO provided a draft of this report section to OMB for review and 

comment. OMB provided technical comments, which were incorporated 

as appropriate.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. GAO analyzed IT 

investment data and OMB’s guidance to federal agencies on IT 

investments, interviewed officials at the 10 federal agencies with the largest 

IT spending in fiscal year 20106

 

6

The 10 federal agencies are the Departments of Agriculture, Commerce, Defense, Health 

and Human Services, Homeland Security, Justice, Transportation, the Treasury, and

to understand how they implement OMB 

guidance, and analyzed reports and interviewed officials on efforts to 

address duplicative investments. GAO also selected three of the largest 

agencies with respect to number of investments—DOD, Energy, and DHS 

to identify potentially duplicative investments. GAO analyzed a subset of 

investment data from OMB’s IT budget data to identify investments with 

similar functionality. Specifically, GAO reviewed 810, or 11 percent, of the 

approximately 7,200 IT investments federal agencies report to OMB. 

GAO’s review represents approximately 24 percent of DOD’s IT portfolio in 

terms of the number of investments that they report to OMB, 19 percent of 

Energy’s, and 16 percent of DHS’s. GAO then reviewed the name and 

narrative description of each investment’s purpose to identify similarities 

among related investments within each agency (GAO did not review 

Veterans Affairs, and the National Aeronautics and Space Administration.

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 138 GAO-12-342SP Duplication, Overlap, and Fragmentation 

investments across agencies). This formed the basis of establishing 

groupings of similar investments. GAO discussed the groupings with each 

of the selected agencies, and GAO obtained further information from 

agency officials and reviewed and assessed agencies’ rationales for having 

multiple systems that perform similar functions. Appendix III lists the 

programs GAO identified that may have similar or overlapping objectives, 

provide similar services or be fragmented across government missions. 

Overlap and fragmentation may not necessarily lead to actual duplication, 

and some degree of overlap and duplication may be justified.

Information Technology: Departments of Defense and Energy Need to 

Address Potentially Duplicative Investments, GAO-12-241. Washington, 

D.C.: February 17, 2012.

Information Technology: OMB Needs to Improve Its Guidance on IT 

Investments. GAO-11-826. Washington, D.C.: September 29, 2011.

Information Technology: OMB’s Dashboard Has Increased Transparency 

and Oversight, but Improvements Needed. GAO-10-701. Washington, 

D.C.: July 16, 2010. 

Information Technology: Management and Oversight of Projects Totaling 

Billions of Dollars Need Attention. GAO-09-624T. Washington, D.C.: April 

28, 2009.

Information Technology: OMB and Agencies Need to Improve Planning, 

Management, and Oversight of Projects Totaling Billions of Dollars. 

GAO-08-1051T. Washington, D.C.: July 31, 2008.

Information Technology: Further Improvements Needed to Identify and 

Oversee Poorly Planned and Performing Projects. GAO-07-1211T. 

Washington, D.C.: September 20, 2007.

Information Technology: Improvements Needed to More Accurately 

Identify and Better Oversee Risky Projects Totaling Billions of Dollars. 

GAO-06-1099T. Washington, D.C.: September 7, 2006.

Information Technology: Agencies and OMB Should Strengthen 

Processes for Identifying and Overseeing High Risk Projects. 

GAO-06-647. Washington, D.C.: June 15, 2006.

Information Technology: OMB Can Make More Effective Use of Its 

Investment Reviews. GAO-05-276. Washington, D.C.: April 15, 2005.

For additional information about this area, contact David A. Powner at 

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

Related GAO 

Products 

Contact Information
 

Page 139 GAO-12-342SP Duplication, Overlap, and Fragmentation 

20. Overseas Administrative Services

U.S. government agencies could lower the administrative cost of their operations overseas by increasing 

participation in the International Cooperative Administrative Support Services system and by reducing reliance 

on American officials overseas to provide these services.

As of fiscal year 2011, the U.S. government employed over 23,500 

Americans overseas, including nearly 15,000 with the Department of 

State (State), at more than 250 diplomatic and consular posts. The 

operation of these posts requires a wide variety of administrative support 

services for overseas personnel, such as building maintenance, vehicle 

operations, and travel services, among others. U.S. government agencies 

may obtain these services through the International Cooperative 

Administrative Support Services (ICASS) system, the principal means by 

which the U.S. government provides and shares the cost of common 

services. ICASS is an interagency system established in 1997 for 

distributing the cost of administrative services at overseas posts and is 

intended to ensure that each agency bears the cost of its overseas 

presence. The ICASS Executive Board, chaired by State and comprised 

of senior representatives from participating agencies, sets the strategic 

vision and policy for ICASS.

State is the principal—and most often the only—administrative service 

provider at most posts worldwide, and its personnel provide virtually all 

ICASS services. The cost of ICASS, which totaled over $2 billion in fiscal 

year 2011, is shared with over 40 participating federal agencies, of which 

State, the U.S. Agency for International Development (USAID), and the 

Departments of Agriculture, Commerce, Defense, Health and Human 

Services, Homeland Security, and Justice are the largest, accounting for 

nearly 95 percent of all ICASS costs. Participation is mostly voluntary, as 

agencies may obtain any or all of 31 different services at each overseas 

post or opt out of ICASS by providing services for themselves or obtaining 

them from another source.

As GAO reported in September 2004, since the establishment of ICASS, 

many agencies had not signed up for ICASS services and decided 

instead to provide similar services for their own staff independently. GAO 

found that this resulted in duplicative administrative systems that limited 

ICASS’s ability to achieve economies of scale and deliver administrative 

services efficiently.

Since 2004, State and other agencies operating overseas have made 

limited progress in reducing the cost of administrative support services 

overseas. Agencies continue to provide many services independently, 

despite economies of scale available through greater participation in 

ICASS. Furthermore, State, the primary provider of ICASS services, has 

not implemented other cost containment measures that would significantly 

reduce the need to employ American administrative staff overseas.

Why This Area Is 

Important

What GAO Found
 

Page 140 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Opting out of ICASS results in potential duplication of administrative 

services and increased costs to the U.S. government. GAO’s analysis of 

ICASS data from 2011 shows that agencies continue to obtain 

administrative support services outside of ICASS at overseas posts, 

duplicating services provided through the ICASS system. GAO found that 

when customer agencies had a choice to obtain services outside of 

ICASS, they did so about one-third of the time, on average. ICASS 

participation rates vary widely by agency, but individual agency rates 

have remained relatively constant since 2005, with the exception of 

USAID. USAID has experienced a marked increase in participation since 

it began consolidating its administrative operations with State in 2005.

GAO directly observed duplication of administrative services during site 

visits to four overseas missions. For example, at each post visited, GAO 

found that instead of participating in the ICASS-managed motor pool, 

several agencies operated or maintained their vehicles independently. In 

addition, several agencies procured their own appliances or shipped their 

own furniture, declining to participate in ICASS furniture and appliance 

pools, where this would be done collectively by ICASS staff. According to 

the financial management officer in Manila, this not only reduces the 

opportunity to realize lower procurement costs through larger bulk 

purchases, it entails other hidden costs, including increased labor and 

wear and tear on the property, as furniture and appliances are removed 

and reinstalled when agency staff move in and out of embassy-managed 

residences. He noted that over a 6-month period in 2010, ICASS service 

providers had to remove and reinstall furniture and appliances at 

embassy-managed residences 67 times as a result of agency officials 

being replaced in a home by officials from a different agency. Such 

additional work would not have been necessary if all agencies subscribed 

to one furniture and appliance pool, as this property would have remained 

in the home where it was originally installed, regardless of the occupant.

GAO’s analysis of ICASS cost and workload data confirms that State and 

other agencies participating in ICASS have realized savings through 

economies of scale. For all 28 ICASS services GAO analyzed, GAO 

found that as ICASS workloads increased—for example, through 

increased participation in ICASS services or growth in staff posted 

overseas—service provision became more efficient and costs per unit of 

output decreased (see table below). However, GAO was unable to 

estimate the specific cost implications for new ICASS customers, as other 

agencies that had opted out of ICASS could not provide GAO with 

comparable cost data to those which ICASS collects.
 

Page 141 GAO-12-342SP Duplication, Overlap, and Fragmentation 

ICASS Participation Rates for 2011 and Potential Savings through Economies of 

Scale for Selected Administrative Services

Administrative service

Percentage of 

agencies 

obtaining service 

through ICASS

Estimated change in 

unit cost with 10 

percent increase 

in workload

Property managementa 70.6% -9.1%

Furniture, furnishings, and appliance 

pools

57.5 -8.4

Pouch services 50.2 -7.0

Travel services 70.7 -6.2

Photocopying services 28.0 -6.2

Shipment and customs 66.2 -6.1

Administrative supply 56.5 -5.6

Procurement services 75.4 -5.6

Motor pool services 45.1 -4.8

Source: GAO analysis of ICASS data. 

a

Includes inventory management, warehousing, and issuance of office and residential furniture, 

furnishings, and appliances; does not include real property. 

According to the results of GAO’s survey of agency representatives, 

decisions to opt out of ICASS services are based on various factors, the 

most frequently cited of which were concerns about cost. GAO’s survey 

results indicated that some agency representatives who obtained a specific 

service outside of ICASS believed that doing so was less expensive than 

obtaining this service through ICASS. However, several respondents 

indicated that their decisions to opt out of ICASS were not based on any 

formal cost analyses. Agencies also chose not to participate in ICASS for a 

variety of other reasons. In some cases, agency representatives said that 

they could obtain some services from their headquarters more efficiently 

than through ICASS. In other cases, officials indicated that they would be 

unable to fulfill their agency’s mission if they relied on ICASS services. For 

example, some Department of Homeland Security officials said they 

needed to maintain their own vehicles to have immediate, 24 hours-a-day 

access for them to conduct investigations. Also, several USAID and 

Department of Agriculture officials noted that their missions require them to 

take extended trips to the field that the ICASS motor pool is sometimes not 

able to accommodate.

Another frequently cited reason for opting out of ICASS was concern 

about the quality of ICASS services. While results from the annual ICASS 

survey and GAO’s survey of U.S. government agency representatives 

show overall satisfaction with the quality of ICASS services generally, 

some dissatisfaction with ICASS performance still exists, particularly 

among USAID staff. Officials from USAID and other agencies have 

indicated that performance problems could affect their ability to achieve 

their respective mission efficiently and effectively in some cases. In 

particular, USAID officials have cited the unavailability of ICASS motor 

pool vehicles for travel to distant project sites as a major impediment to its 

ability to monitor development programs. While agencies may have valid 
 

Page 142 GAO-12-342SP Duplication, Overlap, and Fragmentation 

justifications for not participating in ICASS services, they generally do not 

document their rationales or formally share them with ICASS service 

providers or other customer agencies. Nor do State or ICASS 

systematically request such analyses or document the reasons why 

agencies choose not to subscribe to an ICASS service.

The voluntary nature of ICASS has permitted the continuation of 

duplicative services, as agencies often make decisions about participating 

in ICASS based on their own costs and not the costs to the U.S. 

government as a whole. GAO recommended in September 2004 that the 

ICASS Executive Board encourage greater ICASS participation. The 

board agreed and has taken some steps to reduce duplication of 

administrative services, particularly between State and USAID. However, 

according to ICASS officials, experience has shown that board members 

do not necessarily have the incentive to require their agencies to 

participate in ICASS. In this context, congressional action may be 

necessary to increase participation in ICASS.

One of ICASS’s primary goals is to contain or reduce administrative 

costs. Yet State, as the primary ICASS service provider, has made limited 

progress in containing costs by reducing the need for American 

administrative staff overseas. GAO recommended in September 2004 

that, in addition to pursuing the elimination of duplicative administrative 

support structures, the ICASS Executive Board seek to contain ICASS 

cost by reengineering administrative processes and employing innovative 

managerial approaches through competitive sourcing, regionalization of 

services, improved technology, and adoption of other best practices 

developed by agencies and other posts. GAO further noted that State had 

undertaken several initiatives to increase the efficiency of ICASS 

services, primarily by reducing the need for administrative staff overseas.

However, according to ICASS management officials, State has 

discontinued these efforts without demonstrating significant progress in 

containing costs. For example, State did not fully implement a pilot effort 

to streamline services by requiring ICASS service providers and ICASS 

Councils to rationalize administrative staffing levels. Moreover, State did 

not execute its plans to relocate some administrative support activities 

from overseas to the Florida Regional Center in Fort Lauderdale, which 

State estimated in 2004 would save ICASS customers up to $140 million 

over 5 years. According to State and ICASS management officials, State 

discontinued these efforts because it determined that the potential cost 

savings did not outweigh the administrative burden of fully implementing 

them. Furthermore, they indicated that State has not undertaken any 

other comparable streamlining efforts that would lower costs significantly.

State has implemented a wide variety of smaller scale innovations that 

have increased the efficiency of ICASS service delivery and reduced 

costs. For example, State established a “post support unit” to provide 

vouchering services to more than 90 posts worldwide from three central 

locations. State also implemented a global network energy management 

program, which has reportedly reduced energy costs by almost $900,000 
 

Page 143 GAO-12-342SP Duplication, Overlap, and Fragmentation 

in its first 10 months. Other than this initiative, State has not identified the 

specific cost impacts of these innovations. State anticipates future cost 

savings from innovative approaches to procuring air freight pouch and 

mail services and information technology.

The ICASS Executive Board has had limited power to effectuate 

reengineering and innovation in administrative processes, as State 

maintains control over virtually all of these processes as both the primary 

provider and customer of ICASS services. Officials from nearly every 

agency GAO met with expressed concern about State’s failure to contain 

the cost of the ICASS services it provides. In particular, agency officials in 

Washington and at the overseas posts GAO visited commonly 

complained that State employed too many American staff overseas to 

provide administrative services instead of relying on much less expensive 

locally employed staff or outsourcing to local firms.1

Furthermore, State has not sought to maximize the cost-effectiveness of 

ICASS services by ensuring that the most appropriate agency deliver 

these services at all posts. In some instances of duplication GAO 

observed, GAO noted that USAID appeared to have more expertise in 

providing a particular service than the existing State ICASS provider, 

potentially making USAID a reasonable alternate ICASS service provider. 

For example, in Nairobi, USAID operates a copy center for its own staff 

inside the embassy compound, offering more specialized services, 

including digitization, than the ICASS copy center provides.

State’s Foreign Affairs Handbook recognizes that an agency other than 

State may be better positioned to be the principal provider of specific 

services for themselves and other agencies at a given post. It allows for 

the use of these alternate service providers in cases where an agency 

has a sufficiently large administrative support capability at a location and 

agrees to provide services to other agencies at that post. However, in 

2006, State and USAID, in the interest of simplifying and expediting the 

consolidation of their administrative operations overseas, adopted a 

policy effectively restricting the establishment of new alternate ICASS 

service providers.

As a result, in 2012, only seven posts had such a provider for one or 

more ICASS service, potentially limiting opportunities for ICASS to 

achieve greater efficiency and effectiveness. In 2010, Task Force 11, a 

joint State-USAID group supporting the development of the Quadrennial 

Diplomacy and Development Review,2

 

1

In 2004, we found that the per capita labor cost of an American direct hire staff was 

almost eight times higher than that of a local hire.

recommended that posts consider 

2

Department of State and the U.S. Agency for International Development, Leading 

Through Civilian Power: The First Quadrennial Diplomacy and Development Review

(Washington, D.C.: Dec. 15, 2010).
 

Page 144 GAO-12-342SP Duplication, Overlap, and Fragmentation 

the use of alternate service providers in order to reduce costs. Task Force 

11 also proposed that State and USAID establish a Joint Management 

Board and formulate a consolidation policy that considers the use of 

alternate providers. However, the Joint Management Board, created in 

August 2011, has not yet established such a policy.

To contain costs and reduce duplication of administrative support 

services overseas, GAO recommended in January 2012 that Congress 

may wish to consider

• requiring agencies to participate in ICASS services unless they 

provide a business case to show that they can obtain these services 

outside of ICASS without increasing overall costs to the U.S. 

government or that their mission cannot be achieved within ICASS. 

GAO also recommended in January 2012 that the Secretary of State 

should

• increase the cost-effectiveness of ICASS services by continuing to 

reengineer administrative processes and seek innovative managerial 

approaches, including those that would reduce the reliance on 

American officials overseas to provide these services.

Furthermore, where agencies are able to demonstrate, through a 

compelling business case, that they can provide a service more efficiently 

than the existing State ICASS provider without adverse effects on the 

overall government budget, GAO recommended in January 2012 that the 

Secretary of State and the Administrator of USAID should 

• allow the creation of new ICASS service providers, in lieu of State, 

that could provide administrative services to the other agencies at 

individual posts.

GAO provided a draft of its January 2012 report to State, USAID, and the 

Departments of Agriculture, Commerce, Defense, Health and Human 

Services, Homeland Security, and Justice for review and comment. State, 

USAID, and the Departments of Agriculture, Commerce, and Homeland 

Security provided written comments. The Departments of Defense, Health 

and Human Services, and Justice provided technical comments, which 

were incorporated as appropriate. State and USAID generally agreed with 

GAO’s recommendations. However, while State agreed that continued 

efforts are needed to increase the cost-effectiveness of ICASS services, it 

did not agree that such actions have not been undertaken or that such 

efforts would substantially reduce the need for the American management 

staff abroad. GAO added information about State’s other cost-reduction 

efforts to the draft, noting that they were of a smaller scale than those State 

had indicated in 2004 that it would undertake. Given the relatively high cost 

of posting American staff overseas compared to engaging staff locally, 

GAO believes that even minor modifications in staffing could have 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 145 GAO-12-342SP Duplication, Overlap, and Fragmentation 

significant cost implications and should be thoroughly explored, in close 

coordination with ICASS-participating agencies.

The Departments of Agriculture, Commerce, and Homeland Security took 

issue with GAO’s finding that nonparticipation in ICASS services reflects 

potential duplication of administrative services overseas, and with GAO’s 

suggestion that Congress consider requiring agencies to participate in 

ICASS services unless they provide a business case to justify opting out. In 

particular, these agencies noted that ICASS customers have a variety of 

valid reasons for not participating in ICASS services and expressed 

concern that developing business cases to justify nonparticipation would be 

overly burdensome. GAO believes that, while agencies may have valid 

reasons for not participating in some ICASS services, the voluntary nature 

of ICASS has permitted agencies to opt out of the system without 

conducting rigorous cost analyses. Without such analyses, agencies are 

making decisions about participating in ICASS based on their own costs—

or perceptions of cost—and not necessarily the overall cost to the U.S. 

government. GAO believes that if conducted in close coordination with the 

ICASS Service Center and other participating agencies, preparing business 

cases need not be overly burdensome and could lead to significant, longterm savings for the U.S. government that would justify the additional effort. 

As part of its routine audit work, GAO will track the extent to which progress 

has been made to address the identified actions and report to Congress.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. GAO analyzed data 

and documentation on ICASS participation and costs from 2000 through 

2011; interviewed cognizant staff at the 8 agencies with the largest 

overseas presence; and surveyed representatives from these agencies at 

posts around the world. GAO staff conducted fieldwork in Japan, Kenya, 

the Philippines, and Rwanda, where they observed administrative 

services, met with embassy management officials, and conducted focus 

groups of ICASS customers. GAO performed its work from August 2010 

to January 2012.

Embassy Management: State Department and Other Agencies Should 

Further Explore Opportunities to Save Administrative Costs Overseas. 

GAO-12-317. Washington, D.C.: January 31, 2012.

New Embassy Compounds: State Faces Challenges in Sizing Facilities 

and Providing for Operations and Maintenance Requirements. 

GAO-10-689. Washington, D.C.: July 20, 2010.

Embassy Management: Actions Are Needed to Increase Efficiency and 

Improve Delivery of Administrative Services. GAO-04-511. Washington, 

D.C.: September 7, 2004.

For additional information about this area, contact Michael Courts at (202) 

512-8980 or courtsm@gao.gov.

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 146 GAO-12-342SP Duplication, Overlap, and Fragmentation 

21. Training to Identify Fraudulent Travel 

Documents 

Establishing a formal coordination mechanism could help reduce duplicative activities among seven different 

entities that are involved in training foreign officials to identify fraudulent travel documents.

Eliminating the threat of terrorist attacks continues to be a primary U.S. 

national security focus. According to the 9/11 Commission, constraining 

the mobility of terrorists is one of the most effective weapons in fighting 

terrorism. The U.S. government has identified four key gaps in foreign 

countries’ capacity to prevent terrorist travel overseas, including a key 

gap in our foreign partners’ ability to address the use of fraudulent travel 

documents. As a result, U.S. agencies have undertaken a variety of 

efforts to enhance our foreign partners’ capacity to identify and interdict 

fraudulent travel documents (i.e., passports and visas).

As GAO reported in June 2011, seven different U.S. government entities 

across three federal agencies are involved in providing training to foreign 

government officials to detect fraudulent travel documents.1

 

1

We were unable to determine the total amount of money spent on training foreign 

government officials to detect fraudulent travel documents because the agencies involved 

did not consistently track the cost of individual training sessions.

In delivering 

the training, agencies have similar objectives and often train the same 

populations (e.g., immigration officials and law enforcement officials) to 

develop their skills in recognizing the characteristics of altered, 

counterfeit, or other fraudulent travel documents, sometimes in the same 

country.

Why This Area Is 

Important

What GAO Found
 

Page 147 GAO-12-342SP Duplication, Overlap, and Fragmentation 

U.S. Agencies and Bureaus Involved in Providing Fraudulent Travel Document 

Recognition Training to Foreign Immigration and Law Enforcement Officials

As GAO reported in June 2011, the federal entities in the above figure 

provided the following training to foreign officials in fraudulent travel 

document recognition:

• The Bureau of Diplomatic Security within the Department of State 

(State) provided 458 instructor-led courses on fraudulent travel 

documents through their staff posted overseas and, in collaboration 

with State’s Bureau of Counterterrorism, provided an additional 12 

courses in fraudulent travel document recognition through their AntiTerrorism Assistance (ATA) program.

• Immigration and Customs Enforcement (ICE) within the Department of 

Homeland Security (DHS) provided 360 training courses, briefings, 

and outreach sessions through their attachés stationed overseas, and 

through their Office of International Affairs provided 4 additional 

courses instructed by officials traveling from Washington, D.C.

• State’s Bureau of International Narcotics and Law Enforcement 

Affairs, through the International Law Enforcement Academies, 

provided two courses specifically on fraudulent travel document 

recognition and five courses that covered this topic as part of longer, 

general law enforcement training. In addition, this State bureau 

provided funding to the U.S. Customs and Border Protection (CBP) 

within DHS for one training course and to arrange six trips of foreign 

officials to the United States through the International Visitors 

Program for this purpose and to the Organization of American States 
 

Page 148 GAO-12-342SP Duplication, Overlap, and Fragmentation 

to deliver training in fraudulent document recognition throughout the 

Western Hemisphere.

• The Transportation Security Administration within DHS funded one

fraudulent travel document training course, as part of its Aviation 

Security Sustainable International Standards Teams.

• CBP within DHS, through its Office of International Affairs, funded one

course in fraudulent document recognition for law enforcement 

officials.

• The Federal Bureau of Investigation within the Department of Justice 

did not fund or implement any such training in fiscal year 2010; 

however, in March 2011, it organized one such training session.

Officials from State’s Bureau of Counterterrorism—which coordinates and 

supports the development and implementation of all U.S. government 

policies and programs aimed at countering terrorism overseas—told GAO

they had been unaware of how many agencies and subagencies are 

involved in providing fraudulent travel document training to foreign 

officials. They added that no mechanism existed to encourage 

coordination among all the parties involved. At the country level, during 

site visits in March 2011, GAO found that agency officials at two of the 

four posts it visited did not always collaborate on the delivery of fraudulent 

travel document recognition training. As a result, some planned training 

was duplicative and did not make an effective use of limited resources.

• In Pakistan, GAO identified two agencies, State and DHS, planning to 

provide fraudulent travel document recognition training courses in April 

2011 to Pakistani officials from the same agency without coordinating 

with one another. An attaché from DHS/ICE planned one course, while 

State’s ATA program was simultaneously planning to hold two other 

fraudulent travel document courses in the same month. Meanwhile, the 

ICE attaché had been certified to be an instructor for fraudulent travel 

document recognition courses through a train-the-trainer course 

provided by ICE’s Forensic Document Laboratory. Since ATA program 

officials were unaware of the existence of this local resource, the ATA 

program was still attempting to find two instructors from ICE to travel to 

Pakistan to teach their planned courses.

• In Kenya, GAO found that representatives from two U.S. agencies, 

State and DHS, deliver fraudulent travel document training but do not 

collaborate. State provides such training through its ATA program and 

through an in-country representative of their Bureau of Diplomatic 

Security, while an in-country representative of DHS’s CBP also 

provided many such training courses. Despite these three 

representatives providing this similar training, a representative from 

one of the agencies stated that although he coordinated with other 

countries providing similar training in Kenya, he did not do so with 

other U.S. agencies.
 

Page 149 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO recommended in June 2011 that the Secretary of State should

• develop a mechanism to enhance coordination among the agencies 

involved in funding and implementing fraudulent travel document 

training overseas.

GAO provided a draft of its June 2011 report to State for review and 

comment. State agreed with GAO’s previous recommendation and 

reported that efforts to enhance such coordination have begun at the 

country level. As part of its routine audit work, GAO will track the extent to 

which progress has been made to address the identified actions and 

report to Congress. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. GAO reviewed the 

strategies and documentation of U.S. agencies funding and/or 

implementing foreign capacity-building efforts to prevent terrorist travel 

overseas, including those of State, DOD, DHS, the Department of Justice, 

and the U.S. Agency for International Development. GAO met with these 

agencies and conducted field work in Kenya, Pakistan, the Philippines, 

and Thailand. 

Combating Terrorism: Additional Steps Needed to Enhance Foreign 

Partners’ Capacity to Prevent Terrorist Travel. GAO-11-637. Washington, 

D.C.: June 30, 2011.

For additional information about this area, contact Charles Michael 

Johnson, Jr. at (202) 512-7331 or johnsoncm@gao.gov. 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO Product

Contact Information
 

Page 150 GAO-12-342SP Duplication, Overlap, and Fragmentation 

22. Coordination of Space System 

Organizations 

Fragmented leadership has led to program challenges and potential duplication in developing multibillion-dollar 

space systems.

U.S. government space systems provide a wide range of capabilities such 

as Global Positioning System, weather, climatology, meteorology, missile 

warning, and secure communications to a large number of users, including 

the Department of Defense (DOD), the intelligence community, civil 

agencies, U.S. businesses and citizens, and/or other countries. More than 

$25 billion a year is appropriated to agencies for developing space 

systems. These systems typically take a long time to develop, and often 

consist of multiple components—including satellites, ground control 

stations, terminals, and user equipment—with different program offices that 

oftentimes separately plan, acquire, and deploy individual system 

components. Moreover, the nation’s satellites are put into orbit by rockets 

that can cost more than of $100 million per launch. Given these 

components, often costing billions of dollars to acquire, recent GAO studies 

have shown that costs of space programs tend to increase significantly 

from initial cost estimates. A May 2011 GAO testimony showed that 

estimated costs for the major Defense space acquisition programs have 

increased by about $13.9 billion from initial estimates for fiscal years 2010 

through 2015, almost a 286 percent increase. NASA space programs have 

also wrestled with excessive cost growth. While many of the programs 

have provided users with important and useful capabilities, GAO and 

others have reported for a number of years that, in some cases, problems 

with these systems have been so severe that acquisitions were either 

canceled or the needed capabilities were severely delayed, and that 

fragmented leadership has been a factor in some of these problems. 

Fragmented leadership and lack of a single authority in overseeing the 

acquisition of space programs have created challenges for optimally 

acquiring, developing, and deploying new space systems. This 

fragmentation is problematic not only because of a lack of coordination 

that has led to delays in fielding systems, but also because no one person 

or organization is held accountable for balancing governmentwide needs 

against wants, resolving conflicts and ensuring coordination among the 

many organizations involved with space acquisitions, and ensuring that 

resources are directed where they are most needed. Past studies and 

reviews examining the leadership, organization, and management of 

national security space have found that there is no single authority 

responsible below the President for integrating space programs, and 

responsibilities for acquiring space systems are diffused across various 

DOD organizations—including the military services and the Missile 

Defense Agency—as well as the intelligence community and the National 

Aeronautics and Space Administration (NASA). A variety of other 

Why This Area Is 

Important

What GAO Found
 

Page 151 GAO-12-342SP Duplication, Overlap, and Fragmentation 

agencies, such as the Federal Aviation Administration, the National 

Oceanic and Atmospheric Administration (NOAA), and the Department of 

Homeland Security rely on government space systems to execute their 

missions. As indicated in these studies and reviews, each military service 

or agency that acquires space systems has its own lines of acquisition 

authority, even though many of the larger programs, such as the Global 

Positioning System and those to acquire imagery and environmental 

satellites, are integral to the execution of multiple agencies’ missions. 

With multiagency space programs, success is often only possible with 

cooperation and coordination; however, successful and productive 

coordination appears to be the exception and not the rule.

GAO previously reported on how this fragmented leadership and lack of 

coordination has contributed to problems for the development, 

acquisition, and fielding of space programs. Examples of programs 

affected and their challenges are presented in the table below. 

Selected Space Programs GAO Reviewed Where Fragmentation and Lack of Coordination Affected Development and Acquisition 

Program name Problems resulting from a lack of coordination

Global Positioning 

System (GPS) 

The GPS program is currently being modernized to replace and update the aging satellite constellation 

with new GPS satellites, which will provide warfighters with a stronger and more secure military signal. 

Moreover, there is an interagency structure in place to help coordinate requirements and resolve issues 

related to GPS. However, modernized military user equipment that DOD is concurrently developing with 

the new satellites has suffered schedule delays and is not expected to be fully fielded to all of the military 

services until 2025—10 years after the new military signal from the satellites is expected to reach full 

operational capability. GAO previously reported in April 2009 that the coordination of the satellite and user 

equipment segments is not adequately synchronized due to funding shifts and diffuse leadership in the 

program, likely leading to numerous years of missed opportunities to utilize new capabilities. DOD has 

taken some steps to better coordinate the GPS segments. DOD created the Space and Intelligence Office 

within the Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics to ensure 

that all three segments of GPS stay synchronized in the development and acquisition processes. However, 

that office does not have authority over all user equipment. DOD also conducted enterprise reviews of the 

program; however, it has not gone as far as GAO recommended to establish a single authority responsible 

for ensuring that all GPS segments, including user equipment, are synchronized to the maximum extent 

practicable.

The National Polarorbiting Operational 

Environmental Satellite 

System (NPOESS)

NPOESS was an attempt to converge defense and civil environmental monitoring requirements and avoid 

duplication through a tri-agency program office, with each participating agency (DOD, NOAA, and NASA) 

having the lead on certain activities but no single authority to adjudicate conflicts or set priorities. Along with 

technical and design challenges that arose from decisions related to requirements, the lack of an effective 

leadership structure to prioritize requirements and resolve interagency conflicts contributed to restructuring of 

NPOESS. GAO previously reported in June 2009 that the interagency program structure did not effectively

fulfill its responsibilities and did not have the ability to effectively or efficiently oversee and direct the NPOESS 

program. No authority at a level higher than the involved agencies was charged with coordinating the program 

to ensure resources were used for the greatest need, and this led to significant program delays. By the end of 

fiscal year 2010, the U.S. government had spent 16 years and over $5 billion to develop NPOESS, but had 

not launched a single satellite, resulting in a potential capability gap for weather and environmental 

monitoring. Consequently, in February 2010, citing the program’s cost overruns, schedule delays, and 

management problems, the White House Office of Science and Technology Policy announced that the 

NPOESS tri-agency structure would be eliminated and the program would be restructured by splitting 

procurements and responsibilities.a Given this restructuring, GAO recommended in May 2010 that NOAA and 

DOD establish plans to mitigate key risks in transitioning from NPOESS to the successor satellite programs, 

including ensuring effective oversight of program management, and addressing cost and schedule 

implications from contract and program changes. GAO reported that both agencies have acknowledged these 

risks, but have not yet established plans to mitigate these risks. For example, NOAA could not provide firm 

time frames for completing its management control plan and DOD never formally started its follow-on space 

weather satellite program, though it was attempting to pull together key acquisition documents. Moving 

forward, it will be important for the agencies to continue efforts to mitigate these risks in order to ensure the 

success of their respective environmental monitoring programs.
 

Page 152 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Program name Problems resulting from a lack of coordination

Space Radar The Space Radar program faced significant affordability issues, along with leadership and management 

challenges that eventually contributed to the program’s cancellation. Started in 2003, Space Radar was a 

collaborative effort between DOD and the intelligence community to provide global, all-weather, day and 

night intelligence, surveillance, and reconnaissance capabilities, particularly in denied areas. Space Radar 

was to consist of a constellation of satellites, a ground system, and a communications network that 

included ground-, air-, ship-, and space-based platforms. The initial cost estimate for Space Radar was 

between $20 and $25 billion, but the program did not have long-term funding agreements in place or an 

adjudication process for prioritizing and resolving the tasking from various users. GAO previously reported 

in August 2007 that cooperation between DOD and the intelligence community on the program could face 

challenges and an independent review found that the program lacked an effective way to resolve 

disagreements between the partners. Further, the program faced challenges including a potentially 

accelerated schedule, questions about system affordability, and difficulty defining key requirements. By 

2008, DOD and the intelligence community decided to stop developing the Space Radar program, citing 

affordability issues, even though millions of dollars had already been spent and no immediate follow-on 

effort was continued to leverage this investment.

Space Situational 

Awareness

GAO previously reported in May 2011 that Space Situational Awareness acquisition efforts experienced 

challenges due to a lack of governmentwide authority. Space Situational Awareness efforts are designed 

to mitigate threats to U.S. space systems via a variety of space- and ground-based sensors and systems 

that detect, track, and characterize space objects and space-related events, and forecast which assets 

may be at risk. DOD has responsibility, with support from the Director of National Intelligence, for the 

development, acquisition, operation, maintenance, and modernization of Space Situational Awareness 

capabilities governmentwide. The Space Situational Awareness community consists of a diverse and large 

array of stakeholders, and while the National Space Policy assigns Space Situational Awareness 

responsibility to the Secretary of Defense, the Secretary cannot direct resources to the highest priority 

systems if they belong to an agency outside DOD, or ensure that agencies are setting aside funding 

needed for Space Situational Awareness over the long term. This complicates program oversight and 

operations and presents significant challenges to executing and overseeing the Space Situational 

Awareness mission. GAO has reported that development efforts have been hampered by cost, schedule, 

and performance challenges, and that in the past 5 fiscal years DOD has not delivered significant new 

Space Situational Awareness capabilities as originally expected. GAO also reported that the new National 

Space Policy increases the number of stakeholders that must participate in the development of planning 

documents that, among other things, identify the roles to manage national security space capabilities and 

develop specific measures for improving Space Situational Awareness capabilities. While identifying roles 

and having input from more Space Situational Awareness stakeholders are positive first steps and may 

result in more inclusive and robust planning efforts, it is too early to assess the effect of these provisions 

on managing and overseeing governmentwide Space Situational Awareness efforts. 

Source: GAO analysis of Department of Defense and GAO information.

 aThe announcement accompanied the release of the President’s fiscal year 2011 budget request. 

In addition, based on preliminary ongoing work, GAO has found the 

potential for duplication among satellite operations infrastructure within 

the federal government. This preliminary work indicates that there are 

multiple stove piped ground systems and duplication of facilities and 

hardware. This preliminary work also indicates the potential for 

duplication with satellites across the government in certain mission areas, 

such as for remote sensing. GAO plans to further examine these efforts in 

more detail in the near future.

Since late 2009, DOD has taken a number of initiatives to improve 

leadership over defense space acquisitions, but these actions have not 

been in place long enough to determine whether acquisition outcomes will 

improve. To improve leadership over space acquisitions, DOD has (1) 

established the Defense Space Council to serve as the principal advisory 

forum to inform, coordinate, and resolve all DOD space issues, to include 

implementation of the National Security Space Strategy; (2) designated 

the Under Secretary of Defense for Acquisition, Technology and Logistics 
 

Page 153 GAO-12-342SP Duplication, Overlap, and Fragmentation 

(USD AT&L) to serve as the Office of the Secretary of Defense focal point 

for space programs; (3) reaffirmed the Secretary of the Air Force as the 

DOD Executive Agent for Space, to integrate and assess DOD’s overall 

space program, provide recommended adjustments to the space budget 

and facilitate increased cooperation with the Intelligence Community and 

(4) eliminated organizations believed to be redundant and/or ineffective. 

DOD officials also cite various changes at the Air Force level that better 

align and unify space acquisition. Further, the new National Space Policy 

that was issued in 2010 also takes some steps to clarifying 

responsibilities for space programs among government entities. These 

changes hold promise to strengthen unity of efforts across DOD’s space 

portfolio as they seek to streamline authority for acquisitions, establish a 

process for prioritizing investments, and develop tools to ensure greater 

coordination. However, it is too early to determine if they resolve 

fragmentation that exists within DOD and between DOD and the 

intelligence community. Moreover, they do not extend to the space 

activities across the government.

In addition, according to OMB, the administration has taken several steps 

to enhance the coordination of space activities among and between civil 

and national security agencies including (1) conducting Interagency 

Policy Committee meetings on government-wide space-related issues; (2) 

creating and supporting agency-led coordination mechanisms for specific 

space topics or programs where appropriate; and (3) tasking agencies to 

develop joint plans and responses for addressing cross-sector space 

challenges, such as improving U.S. launch infrastructure or enhancing 

space situational awareness. While these steps may help increase 

coordination among agencies, they do not appear to set funding priorities 

and it is unclear whether they will help to resolve the conflicts between 

agencies that have lead to management and acquisition problems. 

GAO has not made recommendations with regard to broader 

governmentwide leadership for space, but in previous reports GAO has 

recommended a number of changes to the leadership of specific sectors 

of the space community, including (1) assigning a single authority to 

oversee the development of the overall GPS capability, with authority to 

ensure DOD space, ground control, and user equipment are 

synchronized to the maximum extent practicable and (2) increasing 

coordination of launch vehicle acquisitions across federal agencies in 

order to increase efficiencies and cost savings. Several congressional 

commissions and other studies have also made recommendations for 

strengthening national security space authorities, including establishing a 

new Under Secretary of Defense for Space who would have authority 

over the planning and execution of the national security space program 

and a senior interagency group to focus on policy formulation and 

coordination of space activities. But these commissions did not look at the 

need for an authority that would also cover civilian agencies with space 

responsibilities.
 

Page 154 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO and others have recommended a number of changes to the 

leadership of the space community and have consistently reported that a 

lack of strong, centralized leadership has led to inefficiencies and other 

problems. But the question still looms as to what office or leadership 

structure above the department level would be effective and appropriate 

for coordinating all U.S. government space programs and setting 

priorities. Working with the National Security Council, the Director of 

Office of Management and Budget should

xassess whether a construct analogous to the Defense Space Council 

could be applied government wide or if a separate organization 

should be established that would have greater authority for setting 

priorities than individual departments and agencies as well as 

responsibility for strategic planning. Given the complexity, diversity, 

and sensitivity of the many organizations involved in space and longstanding resistance to centralized leadership structures or even 

partnerships among agencies, we realize such an action could not be 

implemented quickly and would require a phased implementation 

approach.

Having a single authority responsible for ensuring coordination and 

setting priorities between U.S. space entities could have numerous 

benefits. It could reduce the fragmentation of authority and leadership in 

the space community and thereby help ensure coordination between 

multiple players, and improve synchronization of space program 

acquisitions to help avoid the past problems of interdependent capabilities 

coming online at different times. In addition, this authority would be in a 

better position than any one department or agency to determine the best 

use of limited funds and resources by more effectively prioritizing the 

most highly needed space programs, and would have the authority to 

reduce duplication across programs. While the Defense Space Council 

could fill the role as a single high level authority within DOD, this same 

construct could be used, such as a National Space Council, to coordinate 

and set priorities across the government.

DOD has expressed mixed views on the need for clearer lines of authority 

for space. For example, DOD agreed with GAO’s recommendation in 

April 2009 to appoint a single authority to oversee the development of the 

GPS system, including space, ground control, and user equipment 

assets, to ensure that the program is well executed, resourced, and that 

potential disruptions are minimized. But it asserted that GPS’s current 

leadership structure was sufficient. Before GAO issued its May 2011 

report on space situational awareness, the administration issued the new 

National Space Policy, which has the potential to resolve concerns GAO 

identified with leadership. In responding to this assessment, DOD 

acknowledged the need for a cleaner space and acquisition leadership 

structure. DOD officials believe that space acquisition programs have 

turned a corner and are successfully deploying far more capable systems 

in almost all major space mission areas. NASA and the National 

Reconnaissance Office did not have comments on this assessment.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 155 GAO-12-342SP Duplication, Overlap, and Fragmentation 

The Office of Management and Budget agreed that coordinating space 

activities across the U.S. government has been and continues to be a 

major challenge, but is concerned that the GAO recommendation would 

add an extra layer of space bureaucracy on top of ongoing coordination 

efforts.OMB acknowledges the potential for improved coordination, but is 

concerned about additional costs and possible confusion regarding roles 

and authorities among the existing mechanisms. GAO believes that the 

recommendation is sufficiently flexible to allow for an implementation 

approach that would address these concerns. As part of GAO’s routine 

audit work, GAO will continue to track agency actions to address these 

recommendations and report to Congress.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. In previous work to 

assess DOD’s Space Situational Awareness efforts to determine the 

extent to which an integrated approach was being used to manage and 

oversee efforts to develop Space Situational Awareness capabilities, 

GAO analyzed documents and interviewed officials from 30 organizations 

within the Space Situational Awareness stakeholder community—users 

and providers of Space Situational Awareness information represented by 

DOD, the intelligence community, civil government agencies, and 

commercial industry—to examine (1) management and oversight efforts 

to develop, acquire, and manage Space Situational Awareness 

capabilities; and (2) planning activities for Space Situational Awareness 

architectures, investments, and requirements. GAO also analyzed 

documentation and interviewed officials from DOD and commercial 

industry to assess the benefits and challenges relating to DOD’s 

implementation of its Space Situational Awareness-sharing program 

(formerly the Commercial and Foreign Entities program) under which 

Space Situational Awareness information is to be shared among DOD, 

industry, and foreign entities for collision avoidance purposes. In previous 

work to assess GPS coordination efforts, GAO reviewed recent 

documentation regarding the delivery of capabilities and equipment and 

assessed the level of synchronization among satellites, ground systems, 

and user equipment.

Space Acquisitions: Development and Oversight Challenges in Delivering 

Improved Space Situational Awareness Capabilities. GAO-11-545. 

Washington, D.C.: May 27, 2011.

Space Acquisitions: DOD Delivering New Generations of Satellites, but 

Space System Acquisition Challenges Remain. GAO-11-590T. 

Washington, D.C.: May 11, 2011.

Defense Acquisitions: Assessments of Selected Weapon Programs.

GAO-11-233SP. Washington, D.C.: March 29, 2011.

How GAO Conducted 

Its Work

Related GAO 

Products 
 

Page 156 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Space Acquisitions: DOD Poised to Enhance Space Capabilities, but 

Persistent Challenges Remain in Developing Space Systems.

GAO-10-447T. Washington, D.C.: March 10, 2010.

Global Positioning System: Challenges in Sustaining and Upgrading 

Capabilities Persist. GAO-10-636. Washington, D.C.: September 15, 

2010.

Defense Acquisitions: Challenges in Aligning Space System 

Components. GAO-10-55. Washington, D.C.: October 29, 2009.

Polar-Orbiting Satellites: With Costs Increasing and Data Continuity at 

Risk, Improvements Needed in Tri-agency Decision Making. 

GAO-09-772T. Washington, D.C.: June 17, 2009.

Global Positioning System: Significant Challenges in Sustaining and 

Upgrading Widely Used Capabilities. GAO-09-325. Washington, D.C.: 

April 30, 2009.

DOD is Making progress in Adopting Best Practices for the 

Transformational Satellite Communications System and Space Radar but 

Still Faces Challenges. GAO-07-1029R. Washington, D.C.: August 2, 

2007.

For additional information about this area, contact Cristina Chaplain at 

(202) 512-4841 or chaplainc@gao.gov. Contact Information
 

Page 157 GAO-12-342SP Duplication, Overlap, and Fragmentation 

23. Space Launch Contract Costs

Increased collaboration between the Department of Defense and National Aeronautics and Space 

Administration could reduce launch contracting duplication.

The Department of Defense (DOD), the intelligence community, the 

National Aeronautics and Space Administration (NASA), and other 

government agencies rely on commercial domestic launch service 

providers to place their satellites into orbit. National policy generally 

requires that U.S. government payloads, including satellites, be launched 

on U.S. manufactured launch vehicles. National security space payloads, 

comprised of DOD, including National Reconnaissance Office (NRO) 1

DOD is considering a new space launch acquisition strategy beginning in 

2013 which will likely allow DOD to procure a set number of launch 

vehicles from ULA each year in an effort to control cost increases and 

stabilize the launch industrial base. However, awards of launch services 

from ULA by NASA—which are negotiated in a separate acquisition 

process with a different acquisition office—were not directly included in 

DOD’s planned procurements.

payloads, are primarily launched by the main U.S. launch provider, the 

United Launch Alliance (ULA), on its Delta IV and Atlas V vehicles. NASA 

payloads are launched on a variety of launch vehicles from multiple 

launch providers, including ULA. In fiscal year 2012, DOD plans to 

complete nine launches on Delta IV and Atlas V launch vehicles, at a cost 

of roughly about $1.8 billion. Similarly, in fiscal year 2012, NASA plans to 

complete two launches on ULA’s Atlas V launch vehicle, at a cost of 

about $370 million. The government plans to spend about $15 billion on 

ULA’s launch services from fiscal year 2013 through 2017. In the past few 

years, ULA’s launch costs have risen, but there are currently no 

alternative launch vehicles in the commercial sector that have been 

certified to launch the larger national security satellites. Meanwhile, 

NASA, which has more options for launch providers due to the greater 

diversity of its space programs, tolerance for launch risk, and cooperation 

with international partners, typically uses ULA to launch a few satellites 

each year—averaging about two annually in the past few years.

Space launch acquisition processes for NASA and DOD are not formally 

coordinated, duplicate one another, and may not fully leverage the 

government’s investment because the government is not acting as a 

single buyer. As GAO reported in September 2008 and September 2011, 

 

1

The NRO is responsible for research and development, acquisition, launch, deployment, 

and operation of overhead reconnaissance systems, and related data-processing facilities 

to collect intelligence and information to support national and DOD mission and other 

United States Government needs.

Why This Area Is 

Important

What GAO Found
 

Page 158 GAO-12-342SP Duplication, Overlap, and Fragmentation 

opportunities exist to reduce duplication in government contracting for 

launch services by jointly negotiating launch acquisitions, which could 

reduce the number of contracts and potentially save time and money. The 

U.S. National Space Policy2

Currently, the Air Force’s Launch and Range Systems Directorate 

ensures DOD’s access to space. The directorate develops and acquires 

expendable launch systems by awarding contracts to commercial firms; 

manages the launch integration, mission assurance, and launch 

campaigns; and provides range systems for space launch operations. In 

the past, launch services had been procured one at a time as needed. 

However, DOD is considering a new acquisition strategy, slated to begin 

in 2013, to provide ULA with a minimum order quantity for each year from 

DOD without the need to negotiate a new launch vehicle contract for each 

launch. This new strategy will cover DOD launches, but will not include 

NASA launches, which are negotiated separately by NASA under a

different contract.

directs agencies to work jointly to acquire 

space launch services, and a recently signed memorandum of 

understanding may help facilitate communication on launch acquisitions. 

However, the National Space Policy does not specifically direct agencies 

to jointly negotiate for launch services, and the changes to coordination 

resulting from the memorandum of understanding do not appear to be 

significant enough to decrease the duplication in how DOD and NASA 

procure their launch services and to leverage the combined buying power 

of DOD and NASA.

NASA’s Launch Services II contract is an indefinite delivery, indefinite 

quantity3

Since DOD and NASA negotiate for launch services separately, the 

current space launch acquisition environment may not leverage the 

government’s overall negotiating power to get the best prices for launch 

services from ULA. There is also no current way to ensure that the 

government is not paying twice for launch overhead costs through the 

contract with four launch service providers—Lockheed Martin, 

Orbital Sciences, Space Exploration Technologies, and ULA. When a 

NASA mission needs to acquire launch services, the NASA Launch 

Service Program issues orders for launch services and generally provides 

the companies a fair opportunity to compete for each order under NASA’s 

Launch Services II contract. According to launch service program 

officials, competition between the launch service providers is intended to 

generate lower prices, but ULA is currently the only provider of 

intermediate class launch vehicles. 

 

2

National Space Policy of the United States of America, 28 June 2010.

3

An indefinite delivery, indefinite quantity contract is a type of contract that provides for an 

indefinite quantity, within stated limits, of supplies or services during a fixed period of time 

under which the government places orders for individual requirements. Federal Acquisition 

Regulation (FAR), § 16.504(a).
 

Page 159 GAO-12-342SP Duplication, Overlap, and Fragmentation 

separate acquisition processes. Recently, DOD, the NRO, and NASA 

signed a memorandum of understanding outlining future cooperation in 

space launch acquisitions. In this agreement, DOD agreed to acquire five 

launch vehicle common booster cores4

Reducing duplication in awarding contracts for space launch services is 

further hindered, in part, due to the lack of a governmentwide policy for 

space launch services acquisitions. Currently, in addition to launch 

services procurements, numerous federal agencies have responsibility for 

space activities, including the Federal Aviation Administration’s oversight 

of commercial space launches; NASA’s scientific and exploration space 

activities; the DOD’s national security space launches; the State 

Department’s involvement in international trade issues; and the 

Department of Commerce’s advocacy and promotion of the industry. 

Current National Space Policy broadly states a goal to energize the 

competitive domestic space industries, to include space launch, and to 

enhance capabilities for assured access to space. A governmentwide 

launch policy could more specifically clarify the overall government’s 

priorities in developing and introducing new launch providers and could 

establish guidance for cooperation on launch services procurements 

between agencies. It could also identify and fill gaps in federal policy 

concerning the commercial space launch industry, according to senior 

Federal Aviation Administration and Department of Commerce officials.

per year for the next 5 years, and 

the NRO agreed to procure a minimum of three each year for the next 5 

years. This large acquisition was intended to help control launch vehicle 

costs and stabilize production of launch vehicles. However, the 

agreement did not include a commitment from NASA to procure a 

minimum amount of boosters or services per year, though NASA will 

continue using its Launch Services II contract to procure launch services 

on the Atlas V launch vehicle from ULA separately from DOD’s negotiated 

acquisition. NASA officials believe that they have been successful at 

awarding contracts for launch services through their separate acquisition 

process. Since NASA has a “most favored customer” contractual clause 

on its contracts with ULA to ensure that it does not pay a higher price for 

standard launch services than the lowest price charged to other ULA 

commercial or government customers, they do not have a strong 

incentive to cooperate in these procurements. Though this approach 

minimizes NASA’s launch vehicle costs, it may not necessarily ensure the 

best price for the overall government nor does it eliminate the potential for 

redundant or unnecessary overhead costs. 

According to the National Academy of Sciences, aligning the strategies of 

the various civil and national security space agencies will address many 

current issues arising from or exacerbated by the current uncoordinated, 

overlapping, and unilateral strategies. According to the academy, a 

 

4

The booster core is the main body of a launch vehicle. ULA uses common booster cores 

to build all of the Atlas V and Delta IV launch vehicles. Medium and intermediate launch 

vehicles use one core each, while the Delta IV Heavy launch vehicle requires three.
 

Page 160 GAO-12-342SP Duplication, Overlap, and Fragmentation 

process of alignment offers the opportunity to leverage resources from 

various agencies to address such shared challenges as the diminished 

space industrial base, the dwindling technical workforce, and reduced 

funding levels. According to senior Federal Aviation Administration and 

Department of Commerce officials, the need for an overall U.S. space 

launch policy, which includes commercial space launches, was being 

discussed within the Department of Transportation and across other 

departments as part of the administration’s review of national space 

activities, but the development of a national policy had not yet begun. 

Guidance on launch acquisitions will, however, be included in the updated 

National Space Transportation Policy which is currently under 

development. 

DOD, NRO, and NASA are taking steps to outline responsibilities on 

space launch services acquisitions through their recently signed 

memorandum of understanding. However, there are opportunities for the 

government to act as a single buyer to further reduce duplication in 

acquiring launch services. Specifically, the Office of Management and 

Budget should

• assess and adopt mechanisms to ensure formal coordination of the 

DOD and NASA acquisition processes for awarding launch services 

contracts with an eye toward leveraging the government's buying 

power and ensuring that launch prices are competitive for all U.S. 

government customers; and 

• determine whether the government is paying twice for any overhead 

costs, and if duplication is found, develop a way to ensure that the 

government does not pay more than once for overhead costs through 

separate acquisition processes.

In September 2011, GAO recommended that DOD examine how broader 

launch issues, such as greater coordination across federal agencies, can 

be factored into future launch acquisitions to increase efficiencies and 

cost savings. DOD concurred with this recommendation. In responding to 

this paper on duplication in launch contracting, NASA agreed that the 

goal of improving efficiency and maximizing the government’s buying 

power for intermediate launch vehicles is worthy, but believes that it is 

currently working with DOD in such a way as to achieve this goal while 

still allowing each agency to perform its assigned space-related 

responsibilities. GAO would encourage NASA to continue its coordination 

with DOD. Technical comments from NASA have been incorporated as 

appropriate.

The Office of Management and Budget agrees that clear benefits can be 

gained from avoiding unnecessary contracting duplication, and points out 

that this and prior administrations have taken steps to consolidate launch 

services. OMB also cites this administration’s current effort to develop an 

updated National Space Transportation Policy, which will include 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 161 GAO-12-342SP Duplication, Overlap, and Fragmentation 

guidance on launch acquisition. OMB believes that the flexibility of 

separate acquisition approaches can be beneficial and that the unique 

mission requirements of DOD and NASA may not be met most efficiently 

by a “one size fits all” contracting approach. In addressing OMB, DOD, 

and NASA comments, GAO modified its original suggestion that DOD and 

NASA consolidate their acquisition processes, to a suggestion where 

these agencies enhance their coordination of launch services. GAO 

continues to believe that greater coordination efforts could help to 

leverage the government’s buying power, in addition to the specific 

actions outlined above. For example, by acting as a single buyer, the 

government can better leverage its requirements for multi-year purchases 

of launch vehicles, and jointly negotiate launch acquisitions to reduce the 

number of awarded launch service contracts.

As part of its routine audit work, GAO will track the extent to which 

progress has been made to address the identified actions and report to 

Congress. All written comments are reprinted in appendix IV.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. In addition, GAO 

reviewed the March 2011 launch vehicle agreement by the Secretary of 

the Air Force, Director of the National Reconnaissance Office, and the 

Administrator of NASA. To identify important launch issues with potential 

bearing on current and future government launch acquisitions, GAO 

reviewed DOD launch studies and interviewed study leaders or 

participants in three of the five studies; GAO analyzed historical launch 

data and expected launch vehicle demand; reviewed other relevant 

government and industry reports; interviewed DOD, NASA, and 

contractor officials; and reviewed information from NRO.

Evolved Expendable Launch Vehicle: DOD Needs to Ensure New 

Acquisition Strategy is Based on Sufficient Information. GAO-11-641. 

Washington, D.C.: September 15, 2011.

Commercial Launch Vehicles: NASA Taking Measures to Manage Delays 

and Risks. GAO-11-692T. Washington, D.C.: May 26, 2011.

Commercial Space Transportation: Industry Trends and Key Issues 

Affecting Federal Oversight and International Competitiveness. 

GAO-11-629T. Washington, D.C.: May 5, 2011.

Space Acquisitions: Uncertainties in the Evolved Expendable Launch 

Vehicle Program Pose Management and Oversight Challenges. 

GAO-08-1039. Washington, D.C.: September 26, 2008.

For additional information about this area, contact Cristina Chaplain at 

(202) 512-4841 or chaplainc@gao.gov, or Gerald Dillingham, Ph.D. at 

(202) 512-2834 or dillinghamg@gao.gov. 

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 162 GAO-12-342SP Duplication, Overlap, and Fragmentation 

24. Diesel Emissions

Fourteen grant and loan programs at the Department of Energy, Department of Transportation, and the 

Environmental Protection Agency and three tax expenditures fund activities that have the effect of reducing

mobile source diesel emissions; enhanced collaboration and performance measurement could improve these 

fragmented and overlapping programs.

Diesel engines play a vital role in public transportation, construction, 

agriculture, and shipping, largely because they are more durable and 

reliable than gasoline-powered engines, as well as 25 to 35 percent more 

energy efficient. However, exhaust from diesel engines is a pervasive and 

harmful form of air pollution. Diesel exhaust contains air pollutants such as 

nitrogen oxides and particulate matter, as well as other harmful substances 

that affect public health and the environment.1 Since 1984, the 

Environmental Protection Agency (EPA) has implemented standards that 

have progressively lowered the maximum allowable amount of certain 

pollutants, including nitrogen oxides and particulate matter, from new diesel 

engines by more than 98 percent. However, the most stringent standards 

generally apply to diesel engines and vehicles built after 2007, and EPA 

estimates that over 20 million older mobile sources of diesel emissions—13 

million on-highway vehicles, 7 million non-road engines, and 47,000 

locomotive and marine engines—continue to emit higher amounts of 

harmful pollutants than newer engines.2 Programs at the Department of 

Energy (Energy), the Department of Transportation (DOT), and EPA 

address mobile source diesel emissions from these older sources by 

providing grants and loans for projects that, among other things, retrofit, 

rebuild, or replace existing diesel engines or vehicles; install devices that 

reduce idling of diesel engines; and convert diesel engines and vehicles to 

use cleaner fuels, such as natural gas or propane. From fiscal years 2007 

through 2011, these programs obligated at least $1.4 billion for such 

projects.3 In addition, three tax expenditures, which resulted in at least 

$510 million in forgone federal tax revenue in fiscal year 2010, provide 

incentives to reduce mobile source diesel emissions.

As GAO reported in February 2012, federal grant and loan funding for 

activities that reduce mobile source diesel emissions is fragmented across 

14 programs at Energy, DOT, and EPA. Thirteen of these programs 

provide grants, and 1 program—DOT’s State Infrastructure Banks 

 

1

Nitrogen oxides are regulated pollutants commonly known as NOx that, among other 

things, contribute to the formation of ozone. Particulate matter is an ubiquitous form of air 

pollution commonly referred to as soot.

2

Non-road engines are those used in machines, such as construction equipment, 

agricultural equipment, and airport service vehicles. 

3

The American Recovery and Reinvestment Act of 2009 provided about $870 million of 

this funding. All dollar amounts reported in this analysis are in nominal dollars.

Why This Area Is 

Important

What GAO Found
 

Page 163 GAO-12-342SP Duplication, Overlap, and Fragmentation 

program—provides loans.4

Overlapping Mobile Source Diesel Emissions Reduction Activities, Goals, and Eligible Recipients, by Agency and Program

Of the 14 programs, 1—EPA’s Diesel 

Emissions Reduction Act program—has a specific purpose of reducing 

mobile source diesel emissions. The remaining 13 programs focus on other 

goals or purposes, such as supporting energy efficiency projects or 

reducing petroleum use. In addition to fragmentation across three 

agencies, each of the 14 programs overlaps with at least 1 other program 

in the specific activities they fund, the program goals, or the eligible 

recipients of funding (see fig. below).

Activities Goals Eligible recipients 

Agency/Program

Retrofit vehicle or engine Rebuild vehicle or engineReplace vehicle or engineReduce vehicle idling Use cleaner fuel Reduce emissions Reduce pollution in areas not meeting air quality standardsIncrease energy efficiency Reduce fuel use State governmentsLocal governmentsLand management agencies Transit agenciesFederally recognized tribesPrivate or non-profit organizations

Energy

Clean Cities ● ● ● ● ● ● ● ● ● ● ● ●

Energy Efficiency and Conservation Block 

Grant ● ● ● ● ● ● ● ● ● ●

State Energy Program ● ● ● ● ● ● ● ●

DOTa

Federal Aviation Administration

Voluntary Airport Low Emissions ● ● ● ● ● ● ●

Federal Highway Administration

Congestion Mitigation and Air Quality 

Improvement ● ● ● ● ● ● ● ● ●

Ferry Boat Discretionary ● ● ● ● ● ● ●

State Infrastructure Banks ● ● ● ● ● ●

Federal Transit Administration

Bus and Bus Facilities ● ● ● ● ● ● ● ● ●

Clean Fuels Grant ● ● ● ● ● ● ● ● ● ● ● ●

National Fuel Cell Bus Technology 

Development ● ● ● ● ● ● ●

Transit in Parks ● ● ● ● ● ● ● ● ● ● ● ●

Transit Investments in Greenhouse Gas 

and Energy Reductionb ● ● ● ● ● ● ● ● ● ● ●

Urbanized Area Formula Grants ● ● ● ● ● ● ● ● ●

EPA

Diesel Emissions Reduction Act Program ● ● ● ● ● ● ● ● ● ● ●

Source: GAO analysis of Energy, DOT, and EPA documents and interviews.

a

In 2011, GAO reported that fragmentation of surface transportation programs led to inefficiencies. 

b

The American Recovery and Reinvestment Act of 2009 authorized this program, and the program 

received funding through fiscal year 2011. The program did not receive funding for fiscal year 2012 in 

the relevant appropriations act. 

 

4

Under DOT’s State Infrastructure Banks program, states may use allocated federal 

transportation funds to capitalize state infrastructure banks, which in turn provide loans 

and other nongrant financial assistance to eligible projects.
 

Page 164 GAO-12-342SP Duplication, Overlap, and Fragmentation 

In addition, GAO identified three tax expenditures—biodiesel producer tax 

credits, a diesel fuel emulsion excise tax credit, and an excise tax 

exemption for idling reduction devices—that provide incentives for owners 

and operators of diesel engines and vehicles to reduce emissions.5 GAO 

found overlap among the qualifying activities for the excise tax exemption 

for certain vehicle idling reduction devices and programs that fund idling 

reduction activities because the excise tax exemption and these 

programs all provide incentives to use idle reduction devices to reduce 

diesel emissions. According to Department of the Treasury estimates, in 

fiscal year 2010, the biodiesel tax credits resulted in $510 million in 

forgone federal tax revenue.6

GAO also identified several instances of duplication where more than one 

program provided grant or loan funding to the same recipient for the same 

type of activities.

The Department of the Treasury estimates 

did not include forgone revenue from the diesel fuel emulsion excise tax 

credit or the excise tax exemption for idling reduction devices because 

the department does not report estimates for tax provisions that result in 

forgone excise tax only.

7

Even with duplication among the programs, several factors make it 

difficult to precisely determine whether unnecessary duplication exists. 

First, when different programs fund the same diesel emissions reduction 

activities, it is not necessarily wasteful. For example, a transit agency 

could use funds from two different programs to replace two separate 

fleets of aging diesel buses. Second, grant recipients may leverage 

funding from more than one program to support the full cost of diesel 

In one case, a state transportation agency received 

$5.4 million from DOT’s Transit Investments in Greenhouse Gas 

Emissions Reduction program to, among other things, upgrade 37 diesel 

buses to hybrid diesel-electric buses, $3.5 million from DOT’s Congestion 

Mitigation and Air Quality Improvement program to replace diesel buses 

with four hybrid diesel-electric buses, and $2.3 million from DOT’s Clean 

Fuels Grants program to replace four diesel buses with hybrid electric 

buses. In another case, a nonprofit organization received $1.1 million 

from EPA’s Diesel Emissions Reduction Act program to install emission 

reduction and idle reduction technologies on 1,700 trucks, as well as $5.6 

million from a state infrastructure bank established under DOT’s program 

to equip trucks and truck fleets with emission control and idle reduction 

devices.

 

5

Biodiesel fuel is an alternative to petroleum-based transportation fuel. U.S. biodiesel is 

made from soybeans and other plant oils, such as cottonseed and canola; animal fats, 

such as beef tallow, pork lard, and poultry fat; and recycled cooking oils. A diesel fuel 

emulsion is a mixture of diesel, water, and additives. 

6

The biodiesel tax credits include an income tax credit, as well as an excise tax credit for 

the production and use of biodiesel. 

7

GAO did not determine whether the federal agencies that provided this funding were 

aware of each other’s actions. 
 

Page 165 GAO-12-342SP Duplication, Overlap, and Fragmentation 

emissions reduction projects. In some cases, grant recipients have used 

funding from multiple agencies, in addition to local matching funds, to 

support the cost of large projects that include multiple diesel emissions 

reduction activities. GAO previously reported that leveraging is generally 

recognized favorably by public and private sector officials, but leveraging 

funds from multiple agencies can be inefficient because agencies may 

incur costs for duplicative administrative activities.8

The overall effectiveness of federal funding for activities that reduce 

mobile source diesel emissions may be limited because agencies 

generally do not collaborate. According to Energy, DOT, and EPA 

officials, the three agencies consult one another on broad issues such as 

available emissions reduction technology or emissions standards, but 

these efforts do not involve collaboration on diesel-related issues. This is 

partially due to the differing purposes and goals of each program, which 

often do not directly relate to reducing diesel emissions. However, GAO 

previously reported that, although federal programs have been designed 

for different purposes or targeted for different population groups, 

coordination among programs with related responsibilities is essential to 

efficiently and effectively meet national concerns.

Third, agencies were 

often unable to provide information necessary to determine whether and 

to what extent unnecessary duplication exists among the programs. For 

example, several agencies reported that they do not track costs for 

administrative functions at the program level.

9

GAO also previously reported that uncoordinated program efforts can 

waste scarce funds, confuse and frustrate program customers, and limit 

the overall effectiveness of the federal effort. A focus on results as 

envisioned by the Government Performance and Results Act implies that 

federal programs contributing to the same or similar results should closely 

coordinate to ensure that goals are consistent, and, as appropriate, 

program efforts are mutually reinforcing.10 Also, the GPRA Modernization 

Act of 2010 established a new, cross-cutting, and integrated framework 

for achieving results and improving government performance.11

In addition, few agencies collect performance information on their diesel 

emissions reduction activities. Specifically, EPA collects performance 

information on the amount and type of diesel emissions reductions each 

project achieves, Energy’s three programs and three of DOT’s programs 

collect some performance information related to diesel emissions 

 

 

8

GAO, Leveraging Federal Funds for Housing, Community, and Economic Development,

GAO-07-768R (Washington, D.C.: May 25, 2007). 

9

GAO, The Government Performance and Results Act: 1997 Governmentwide 

Implementation Will Be Uneven, GAO/GGD-97-109 (Washington, D.C.: June 1997).

10The Government Performance and Results Act (GPRA) of 1993, Pub. L. No. 103-62 

(1993).

11Pub. L. No. 111-352 (2011).
 

Page 166 GAO-12-342SP Duplication, Overlap, and Fragmentation 

reductions, and the remaining seven DOT programs do not collect 

performance information related to diesel emissions. This is partially 

because 13 of the 14 programs that fund these activities have purposes 

other than reducing diesel emissions. However, the information that 

would result from enhanced collaboration and outcome measurement is 

needed to determine if fragmentation, overlap, and duplication have 

resulted in ineffective or inefficient programs.

To help ensure the effectiveness and accountability of federal funding that 

reduces diesel emissions, the Secretaries of Energy and DOT as well as 

the Administrator of EPA should

consistent with existing law, establish a strategy for collaboration in 

reducing mobile source diesel emissions.

This strategy should help agencies (1) determine the performance 

measures needed, as appropriate, to assess the collective results of 

federal funding for activities that reduce diesel emissions and (2) identify 

and address any unnecessary duplication, including the effects of the 

relevant tax expenditures, among other things. In undertaking this effort, 

agencies could also assess opportunities for administrative cost savings. 

GAO will monitor the agencies’ efforts on these issues.

GAO provided a draft of this report section to Energy, DOT, and EPA. 

Energy provided technical comments, which were incorporated as 

appropriate. In its comments, Energy questioned several of the findings 

but agreed with the action needed that GAO identified. Specifically, 

Energy stated that the findings mischaracterize the agency as having a 

statutory responsibility for diesel emissions reductions. The findings do 

not contain such a statement. Rather, they identify 14 programs, including 

3 Energy programs, that fund activities with the effect of reducing diesel 

emissions and state that programs with related responsibilities should 

coordinate their efforts. Energy also stated that the findings 

mischaracterize Energy as not collaborating with other government 

agencies. The findings state that Energy collaborates with other agencies 

on broad issues but does not collaborate on diesel-related issues. In 

addition, Energy stated that the findings mischaracterize the agency as 

sharing redundant national goals with DOT and EPA. The findings do not 

discuss Energy's national goals, their relationship to those of other 

agencies, or whether they are redundant. Rather, the findings (1) focus 

on Energy programs that fund activities that result in diesel emissions 

reductions and (2) demonstrate that these programs share similar goals 

with DOT and EPA programs that fund the same activities. Specifically, 

each of these programs shares some goals, such as reducing emissions, 

increasing energy efficiency, and reducing fuel use.

DOT did not provide comments on the draft findings. In its comments on a 

draft of the February 2012 report, DOT questioned several of the report's 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 167 GAO-12-342SP Duplication, Overlap, and Fragmentation 

key findings and the report's recommendation that Energy, DOT, and 

EPA establish a strategy for collaboration among their programs that 

reduce mobile source diesel emissions. Specifically, DOT stated that 

GAO inaccurately described the Federal Transit Administration’s 

programs as funding diesel emissions reduction activities. The report 

identifies Federal Transit Administration activities that reduce diesel 

emissions, including replacing existing diesel vehicles and installing 

devices that reduce idling of diesel engines, and identifies six Federal 

Transit Administration programs that fund these same activities. In 

addition, DOT questioned the evidence underlying our finding of 

fragmentation among the federal programs within our review. DOT stated 

that GAO identified independent programs with varying objectives that, in 

some cases, include similar activities. As GAO reported, fragmentation 

occurs when more than one federal agency, or more than one 

organization within an agency, is involved in the same broad area of 

national need. The report clearly identifies fragmentation, overlap, and 

duplication among the 14 federal programs that fund diesel emissions 

reduction activities. Consistent with our established definition of 

fragmentation and our evidence, GAO stands by its finding that federal 

grant and loan funding for activities that reduce diesel emissions is 

fragmented across 14 programs. 

Regarding GAO’s recommendation that Energy, DOT, and EPA establish 

a strategy for collaboration among their programs that reduce mobile 

source diesel emissions, DOT agreed that collaboration can be useful but 

questioned its usefulness in this context. As GAO reported, while the 

programs GAO reviewed have been designed for different purposes, 

coordination among programs with related responsibilities and that fund 

the same activities is essential to the efficient and effective use of 

resources. Further, uncoordinated programs can waste scarce funds and 

limit the overall effectiveness of federal spending. GAO therefore 

continues to believe that the recommendation is warranted. DOT also 

stated that the report does not effectively demonstrate that the 

recommended action will produce cost-effective investments appropriate 

for DOT that do not potentially duplicate efforts elsewhere in the 

government. GAO continues to believe that establishing a strategy for 

collaboration is an appropriate investment that would help ensure the 

effectiveness and accountability of federal funding for activities that 

reduce diesel emissions. As the report notes, such a strategy should help 

agencies identify and address any unnecessary duplication. 

EPA did not provide specific comments on the draft findings. However, in 

commenting on a draft of our February 2012 report, EPA stated that it 

agreed with GAO’s findings and relevant recommendation.

The information contained in this analysis is based on findings from the 

report listed in the related GAO products section. To determine the total 

amount of federal funding for mobile source diesel emissions reduction 

activities in fiscal year 2010, GAO obtained and analyzed funding data 

from Energy, DOT, and EPA. Appendix III lists the programs GAO 

How GAO Conducted 

Its Work
 

Page 168 GAO-12-342SP Duplication, Overlap, and Fragmentation 

identified that may have similar or overlapping objectives, provide similar 

services or be fragmented across government missions. Overlap and 

fragmentation may not necessarily lead to actual duplication, and some 

degree of overlap and duplication may be justified.

Diesel Pollution: Fragmented Federal Programs that Reduce Mobile 

Source Emissions Could Be Improved. GAO-12-261. Washington, D.C.: 

February 7, 2012.

For additional information about this area, contact David C. Trimble at 

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

Related GAO Product

Contact Information
 

Page 169 GAO-12-342SP Duplication, Overlap, and Fragmentation 

25. Environmental Laboratories

The Environmental Protection Agency needs to revise its overall approach to managing its 37 laboratories to 

address potential overlap and fragmentation and more fully leverage its limited resources.

From monitoring air quality and testing drinking water to responding to 

environmental disasters, the Environmental Protection Agency’s (EPA) 

laboratory enterprise produces scientific research, technical support, and 

analytical services that underpin many of the policies and regulations the 

agency implements to protect human health and our nations’ 

environment. In the present atmosphere of constrained budgets, EPA, 

along with its state partners, will need to more effectively use its scientific 

and laboratory resources and effectively integrate these activities to 

ensure the agency is best positioned to fulfill its core mission, including 

responsibilities for responding to a large-scale environmental incident. 

EPA’s laboratory enterprise includes 37 laboratories that are housed in 

about 170 buildings and facilities located in 30 cities across the nation.

As GAO reported in July 2011, EPA has an uncoordinated approach to 

managing its laboratory enterprise—including the scientific work, 

workforce, and facilities—and identified the potential for missed costsavings opportunities, due in part to fragmentation and overlap of 

activities. However, GAO was not able to calculate the cost associated 

with this potential fragmentation and overlap—or the corresponding 

savings from reducing fragmentation and overlap—because EPA did not 

have sufficiently complete and reliable operating cost data for its 

laboratories. EPA also lacked information on the number of federal and 

contract employees working in its 37 laboratories and the related costs 

associated with its laboratory workforce. GAO’s report found that EPA’s 

uncoordinated approach is due in part to the lack of a top science official 

with the responsibility or authority to coordinate, oversee, and make 

management decisions regarding major scientific activities throughout the 

agency—including the work of all 37 laboratories.

EPA’s laboratories operate under the direction of 15 different senior 

officials using 15 different organizational and management structures. 

EPA has also not fully addressed recommendations from a 1994 

independent evaluation by the MITRE Corporation to consolidate and 

realign its laboratory facilities and workforce1

 

1

MITRE Corporation, Center for Environment, Resources, and Space, Assessment of the 

Scientific and Technical Laboratories and Facilities of the U.S. Environmental Protection 

Agency (McLean, Va.: May 1994). 

—even though this 

evaluation found that the geographic separation of laboratories hampered 

their efficiency and technical operations and that consolidation and 

realignment could improve planning and coordination issues that have 

Why This Area Is 

Important

What GAO Found
 

Page 170 GAO-12-342SP Duplication, Overlap, and Fragmentation 

hampered its science and technical community for decades. We found 

that these problems are evident today and MITRE’s past 

recommendations may still be relevant.

Scientific work. EPA does not have a planning process that integrates and 

coordinates scientific work throughout the agency, including potentially 

overlapping functions performed by its 37 laboratories. Consequently, EPA 

has a limited ability to know if scientific activities are being unintentionally

duplicated among the laboratories or if opportunities exist to collaborate 

and share scientific expertise, equipment, and facilities across EPA’s 

fragmented laboratory enterprise. For example, many of EPA’s 10 regional 

laboratories provide the same or similar types of analytical and technical 

support functions, such as routine and specialized testing of air samples. In 

addition, the agency’s nine program laboratories provide their respective 

program offices2

In addition to potential overlap in the work performed by these two 

laboratories, the fragmentation across the laboratory enterprise may fail 

to provide the agency with opportunities for laboratories to share subject 

matter expertise and scientific equipment. For example, both the Office of 

Air and Radiation and ORD laboratories utilize the same kind of 

specialized equipment, called truck dynamometers, yet each separately 

requested funding in fiscal years 2010 and 2011 that totaled over $4 

million to expand or modify their facilities for emissions testing. While the 

agency funded only one of the two potentially duplicative requests, the 

net result is that the second laboratory’s facility and equipment needs 

were not met. In addition to potential lost opportunities to share facilities 

and equipment, the agency may also be missing opportunities to share 

expertise, such as technical knowledge pertaining to the use of 

specialized equipment. 

with research and analytical services that may overlap 

with research and development performed by the Office of Research and 

Development’s (ORD) 18 laboratories. For example, an Office of Air and 

Radiation program laboratory located in Michigan does emissions testing, 

while a separate ORD laboratory located in North Carolina does emissions 

testing research.

In addition, to support the implementation of both state and federal 

environmental statutes, various state agencies and public universities 

operate over 70 separate environmental laboratories (see fig. below) that 

may perform functions similar to those performed by EPA laboratories. 

Similar to the work of some EPA regional laboratories, state 

environmental laboratories conduct regular testing of air, water, soil, food, 

and other media for signs of contamination. State laboratories also 

perform analytical and method development functions that may be similar 

to those performed by ORD laboratories. EPA has partnered with some 

 

2

The four national program offices that operate laboratories are the Office of Air and 

Radiation, the Office of Enforcement and Compliance Assurance, the Office of Chemical 

Safety and Pollution Prevention, and the Office of Solid Waste and Emergency Response.
 

Page 171 GAO-12-342SP Duplication, Overlap, and Fragmentation 

state laboratories for specific programs, but to fully leverage these state 

scientific resources EPA will first need to integrate and coordinate the 

activities of its own laboratories agencywide.

Potential Overlap among Federal and State Environmental Laboratories

Workforce. EPA does not use a comprehensive planning process for 

managing its laboratories’ workforce and may be missing opportunities to 

work across organizational boundaries to integrate, share, or coordinate 

laboratory workforces that perform potentially overlapping functions. For 

example, many of the 10 regional laboratories provide the same or similar 

core analytical capabilities—including a full range of routine and 

specialized chemical and biological testing of air, water, soil, sediment, 
 

Page 172 GAO-12-342SP Duplication, Overlap, and Fragmentation 

tissue, and hazardous waste—but each region independently determines 

and attempts to address its individual workforce needs. EPA also lacks 

basic demographic information needed to know how many scientific and 

technical employees it has working in its laboratories, where they are 

located, what functions they perform, or what specialized skills they may 

have. In addition, the agency does not have a workload analysis for the 

laboratories to help determine the optimal numbers and distribution of 

staff throughout the enterprise. GAO believes that such information is 

essential for EPA to prepare a comprehensive laboratory workforce plan 

to achieve the agency’s mission with limited resources.

Facilities. EPA manages its laboratory facilities in a way that may fail to 

achieve operating efficiencies that could be gained by colocating 

laboratories with overlapping activities and facility needs. EPA manages 

laboratories on a site-by-site basis and does not make capital 

improvement or other decisions for each site in the context of all the 

agency’s laboratory properties. Because decisions regarding laboratory 

facilities are made independently of one another, opportunities to improve 

operating efficiencies can be lost. For example, GAO found cases where 

laboratories that were previously colocated moved into separate space 

without considering the potential benefits of remaining colocated. In one 

case, GAO found that the relocation increased some operating costs 

because the laboratories then had two facility managers and two security 

contracts and associated personnel because of different requirements for 

the leased facility.

Moreover, EPA lacks sufficiently complete and reliable data to make 

informed decisions for managing its laboratory facilities. Among other 

things, EPA lacks reliable information on laboratory usage, which is 

needed to inform both capital investment and property disposal decisions. 

For example, EPA does not have reliable data on space utilization 

because its data are either out of date or not based on objective criteria 

such as public and commercial space usage benchmarks. Instead, EPA 

measures laboratory usage on the basis of subjective interviews with 

local laboratory officials.

To improve cohesion and efficiency in the management and operation of 

EPA’s laboratories, GAO recommended in July 2011 that the 

Administrator of EPA

• ensure that the agency includes alternative approaches for organizing 

the laboratories’ workforce and infrastructure, including options for 

sharing and consolidation as part of any future studies of EPA 

laboratory enterprise, such as the long-term study requested in the 

President’s fiscal year 2012 budget.

To address potentially overlapping laboratory activities and achieve 

efficiencies by sharing workforce expertise, GAO recommended in July 

2011 that the Administrator of EPA

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 173 GAO-12-342SP Duplication, Overlap, and Fragmentation 

• establish a top-level science official with the authority and 

responsibility to coordinate, oversee, and make management 

decisions regarding major scientific activities throughout the agency, 

including the work of all program, regional, and Office of Research 

and Development laboratories;

• develop an overarching issue-based planning process that reflects the 

collective goals, objectives, and priorities of the laboratories’ scientific 

activities; and

• develop a comprehensive workforce planning process for all 

laboratories that is based on reliable workforce data and reflects 

current and future agency needs in overall number of federal and 

contract employees, skills, and deployment across all laboratory 

facilities.

To identify opportunities to reduce costs associated with maintaining a 

footprint of 170 laboratory buildings and facilities that support 

organizations with potentially overlapping functions, facility, and 

equipment needs, GAO recommended in July 2011 that the Administrator 

of EPA

• improve physical infrastructure and real property planning and 

investment decisions by

• managing individual laboratory facilities as part of an interrelated 

portfolio of facilities;

• ensuring that master plans and other facility information are up-todate and that analysis of the use of space is based on objective 

benchmarks; and

• improving the completeness and reliability of operating cost and 

other data needed to manage EPA’s real property and report to 

external parties.

GAO provided a draft of its July 2011 report to EPA for review and 

comment. EPA generally agreed with GAO’s recommendations. In 

November 2011, EPA noted that current efforts to reduce the federal 

budget deficit require EPA to more effectively use its laboratory enterprise 

to help ensure that its scientific activities respond to the agency’s highestpriority needs. The agency also acknowledged the demand for sharing 

facilities and equipment, as well as expertise and human resources. EPA 

agreed that it should (1) include alternate approaches for organizing the 

laboratory workforce and infrastructure in any future studies of its 

laboratories, such as the long-term study for which the agency requested 

$2 million in the President’s fiscal year 2012 budget; (2) develop an 

overarching planning process that better reflects the collective goals, 

objectives, and priorities of its laboratories; (3) develop a comprehensive 

workforce-planning process for its laboratories; (4) improve physical 

Agency Comments 

and GAO’s Evaluation
 

Page 174 GAO-12-342SP Duplication, Overlap, and Fragmentation 

infrastructure and real property planning and investment decisions by 

managing laboratory facilities as part of an interrelated portfolio of 

facilities; (5) maintain up-to-date master plans that include objective 

benchmarks; and (6) improve the completeness and reliability of

operating cost and other data needed to manage its real property.

In response to our recommendation to establish a top-level science 

official with the authority and responsibility to coordinate, oversee, and 

make management decisions regarding major scientific activities 

throughout the agency, EPA proposed to increase the responsibilities of 

its science advisor. However, it is not clear that this will fully address the 

issue and it may ultimately introduce additional challenges for EPA. We 

note that in 2000, the National Research Council reported “no single 

individual could reasonably be expected to direct a world-class research 

program in ORD while also trying to improve scientific practices and 

performance throughout the rest of the agency,” stating that “these jobs 

are inherently different.” The Council cautioned that “assigning agencywide scientific authority to the assistant administrator for ORD might 

produce a conflict of responsibilities, because many decisions about 

science in the regulatory programs could affect ORD’s budget or favor 

ORD’s research over research done elsewhere.” EPA managers need to 

ensure that there is sustained attention on these issues in order to assure 

its efforts are carried out and achieve the intended results. 

GAO also provided a draft of new information included in this report 

section that was not previously reported in the July 2011 report, such as 

information pertaining to state environmental laboratories, to EPA for 

review and comment. EPA provided technical comments, which were 

incorporated as appropriate. 

As part of its routine audit work, GAO will track the extent to which progress 

has been made to address the identified actions and report to Congress. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. Information regarding 

state environmental laboratories is based on analysis of a May 2011 

Environmental Council of States Green Report, a 2007 report on the 

capability and capacity of state environmental laboratories conducted by 

the Association of Public Health Laboratories, and information obtained 

from state environmental laboratory websites and EPA’s Environmental 

Response Laboratory Network website. 

Environmental Protection Agency: To Better Fulfill Its Mission, EPA 

Needs a More Coordinated Approach to Managing Its Laboratories. 

GAO-11-347. Washington, D.C.: July 25, 2011.

For additional information about this area, contact David C. Trimble at 

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

How GAO Conducted 

Its Work

Related GAO Product

Contact Information
 

Page 175 GAO-12-342SP Duplication, Overlap, and Fragmentation 

26. Green Building

To evaluate the potential for overlap or fragmentation among federal green building initiatives, the Department 

of Housing and Urban Development, the Department of Energy, and the Environmental Protection Agency 

should lead other federal agencies in collaborating on assessing their investments in more than 90 initiatives to 

foster green building in the nonfederal sector.

Economic, environmental, and health concerns have spurred interest in 

“green building”—construction and maintenance practices designed to 

make efficient use of resources, reduce environmental problems, and 

provide long-term financial and health benefits through lower operating 

costs and better indoor air quality. These practices are intended to help 

address issues posed by traditional construction and maintenance 

practices for buildings. According to the Department of Energy (Energy), 

in 2008, buildings in the United States consumed almost 40 percent of the 

nation’s energy and emitted about 39 percent of its carbon dioxide, a 

greenhouse gas recognized as a major contributor to climate change. 

Also, Energy reports that the approximately 30 million to 35 million tons of 

construction, renovation, and demolition waste produced annually in the 

nation account for about 24 percent of municipal solid waste, although 

most of this waste could be recycled. Furthermore, according to the 

Environmental Protection Agency (EPA), exposure to indoor air 

pollutants, such as radon and formaldehyde, can lead to harmful health 

effects, from headaches to respiratory diseases.

In response to concerns about energy consumption, among other things, 

federal laws and executive orders have directed agencies to reduce 

energy consumption and meet other green building requirements in 

federally owned or leased buildings. For buildings not subject to these 

requirements because they are owned or leased by private, state, local, 

or tribal entities, laws have also directed federal agencies to foster green 

building. GAO refers to these entities and their buildings as the 

“nonfederal sector,” which accounts for most of the nation’s buildings.

As GAO reported in November 2011, there are 94 federal initiatives GAO 

identified to foster green building in the nonfederal sector. In conducting 

its work, GAO sent questionnaires to the 11 agencies implementing the 

initiatives identified. As the table below indicates, 3 of the 11 agencies—

the Department of Housing and Urban Development (HUD), EPA, and 

Energy—implement about two-thirds of these initiatives.

Why This Area Is 

Important

What GAO Found 
 

Page 176 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Number of Initiatives That Foster Green Building in the Nonfederal Sector, by 

Federal Agency

Agency Number of initiatives

HUD 29

EPA 18

Energy 17

U.S. Department of Agriculture 8 

Department of the Treasury 8 

Department of Transportation 5 

National Institute of Standards and Technology 3 

Department of Education 2 

Small Business Administration 2 

Department of Defense 1 

Department of Health and Human Services 1 

Total 94

Source: GAO analysis of agency information and questionnaire responses.

According to GAO’s analysis of agency questionnaire responses, the 94 

initiatives GAO identified share the broad goal of fostering green building.

Specifically:

• All of the initiatives foster at least one of six green building elements 

GAO identified (see table below). Three-quarters of the initiatives 

foster more than one element, and 21 initiatives across seven

agencies foster all six elements.

Federal Initiatives Fostering Green Building Elements in the Nonfederal Sector 

Green building element 

Number of initiatives 

fostering each element 

Energy conservation or efficiency 83

Indoor environmental quality 60

Water conservation or efficiency 51

Integrated design (collaborative planning at all stages of 

a building’s life)

48

Sustainable siting or location 43

Environmental impact of materials 39

Source: GAO analysis of questionnaire responses.

Note: Numbers total more than 94 because many initiatives foster more than one element. 

In addition, GAO identified similarities among these federal initiatives that 

indicate potential overlap:

• Many initiatives provide similar types of assistance, mostly through 

grants (47 initiatives) and technical assistance (45 initiatives) but also 

through other types of assistance, such as loans (9 initiatives), tax 

credits (5 initiatives), and tax deductions (3 initiatives).
 

Page 177 GAO-12-342SP Duplication, Overlap, and Fragmentation 

• Agencies reported that they expect the initiatives to directly benefit 

many of the same types of recipients, such as individual property 

owners or renters (55 initiatives), local governments (49 initiatives), 

businesses (47 initiatives), nonprofit organizations (45 initiatives), and 

state governments (42 initiatives).

The 94 initiatives may vary greatly in the scale of their funding. GAO 

requested funding information for all initiatives, but the information 

agencies provided was incomplete and unreliable for the purposes of 

describing the size of green building initiatives. Agency officials stated 

that many of the initiatives are part of broader programs and, as such, the 

agencies do not track green building funds separately from other program 

activities, even for initiatives that have as a component the direct fostering 

of green building. As a result, GAO did not report funding information for 

the initiatives in its November 2011 report. 

About one-third of the 94 initiatives GAO identified have goals and 

performance measures specific to green building and about two-thirds do 

not; therefore, the results of most initiatives and their related investments in 

green building are unknown. Agency officials reported various reasons for 

not having goals and measures, such as challenges in gathering reliable 

performance data. As GAO previously reported, leading organizations 

commonly define clear goals and related outcomes, measure performance 

to gauge progress, and use performance information to assess the results 

of their efforts and the related investment.1 Achieving results for the nation 

increasingly requires that federal agencies work together to identify ways to 

deliver results more efficiently and in a way that is consistent with their 

multiple demands and limited resources.2

GAO identified some instances in which agencies have begun to 

collaborate to assess results. For example, under the Partnership for 

Sustainable Communities, the Department of Transportation, EPA, and 

HUD plan to adopt a common set of performance measures for HUD’s 

Community Challenge Planning Grants Program, which makes funds 

available to state and local governments and other entities to promote 

affordable communities through green building, among other activities. 

Furthermore, Energy chairs the Interagency Energy Management Task 

Force, which includes 10 of the 11 agencies implementing the 94 initiatives 

GAO identified. Since 1988, this task force has served as the interagency 

group for collaborating on green building in the federal sector, measuring 

progress, and acting as a forum for addressing challenges to green building 

Agencies and programs working 

collaboratively can often achieve more public value than when they work in 

isolation. 

 

1

GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). 

2

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 
 

Page 178 GAO-12-342SP Duplication, Overlap, and Fragmentation 

and developing common solutions for the federal sector. However, GAO 

did not identify a governmentwide effort to collaborate on green building 

issues, including shared goals and common performance measures, for the 

nonfederal sector that is comparable to the task force’s efforts for the 

federal sector. Without such an effort, agencies with green building 

initiatives for the nonfederal sector may be missing opportunities to, among 

other things, identify the potential for inefficient or costly duplication, 

overlap, or fragmentation across these initiatives, and to reach agreement 

on governmentwide goals and measures for assessing the overall progress 

of their efforts to foster green building in the nonfederal sector.

Without comprehensive information about each individual initiative’s 

progress toward fostering green building, and without collaboration across 

federal agencies to establish green building goals and ways to measure 

progress, Congress, agency heads, and the public have incomplete 

information about the results of individual and overall federal efforts to 

foster green building in the nonfederal sector and the efficiency of these 

efforts. Governmentwide collaboration to identify performance information 

could, among other things, help inform efforts to evaluate the potential for 

inefficient or costly duplication and overlap across the more than 90 

federal initiatives—implemented by 11 agencies—to foster green building 

in the nonfederal sector. To help assess the results of investments in 

individual federal initiatives to foster green building in the nonfederal 

sector, as well as their combined results, GAO recommended in 

November 2011 that the Secretaries of Energy and HUD as well as the 

Administrator of EPA

• lead an effort with other agencies that are implementing green 

building initiatives to collaborate on identifying performance 

information, such as shared goals and common performance 

measures, for green building initiatives for the nonfederal sector.

Such an effort could help identify opportunities for enhancing efficiency 

and reducing costs to administer these initiatives.

GAO provided a draft of its November 2011 report for review and 

comment to the U.S. Department of Agriculture, the Department of 

Defense, the Department of Education, Energy, the Department of Health 

and Human Services, HUD, the Department of Transportation as well as 

EPA, the Department of the Treasury’s Internal Revenue Service, the 

National Institute of Standards and Technology, and the Small Business 

Administration. Energy, HUD, and EPA agreed with the 

recommendation. HUD, the U.S. Department of Agriculture, the 

Department of Defense, the Department of Education, the Department of 

Transportation, the Internal Revenue Service, and the Small Business 

Administration provided concurrence or technical comments which were 

incorporated as appropriate. The Department of Health and Human 

Services and the National Institute of Standards and Technology did not 

provide comments on this issue. As part of its routine audit work, GAO 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 179 GAO-12-342SP Duplication, Overlap, and Fragmentation 

will track the extent to which progress has been made to address the 

identified actions and report to Congress.

The information contained in this analysis is based on the report listed in 

the related GAO product section. Appendix III lists the initiatives GAO 

identified that may have similar or overlapping objectives, provide similar 

services or be fragmented across government missions. Overlap and 

fragmentation may not lead to actual duplication, and some degree of 

overlap and duplication may be justified.

Green Building: Federal Initiatives for the Nonfederal Sector Could 

Benefit from More Interagency Collaboration. GAO-12-79. Washington, 

D.C.: November 2, 2011.

For additional information about this area, contact Frank Rusco at (202) 

512-3841 or ruscof@gao.gov or David J. Wise at (202) 512-2834 or 

wised@gao.gov. 

How GAO Conducted 

Its Work

Related GAO Product

Contact Information
 

Page 180 GAO-12-342SP Duplication, Overlap, and Fragmentation 

27. Social Security Benefit Coordination

Benefit offsets for related programs help reduce the potential for overlapping payments but pose administrative 

challenges.

Social Security provides old age benefits to millions of Americans, 

forming the foundation of retirement income. However, Social Security is 

more than a retirement program: it also provides benefits to survivors and 

other dependents, as well as to disabled workers. In 2011, over 60 million 

Americans received $770 billion in Social Security benefits. While Social 

Security provides benefits to many different groups, and beneficiaries 

may receive benefits from more than one social safety net program,

Social Security’s design helps reduce overlap with other programs. The 

Social Security programs are subject to several provisions that offset 

benefits for individuals who receive both Social Security benefits and 

similar benefits under another program.1

As GAO reported in March 2011, the Social Security Administration (SSA) 

needed accurate information from state and local governments on 

retirees who receive pensions from employment not covered under Social 

Security to fairly and accurately apply two public pension offsets—the 

Government Pension Offset, which generally applies to spouse and 

survivor benefits, and the Windfall Elimination Provision, which applies to 

retired and disabled worker benefits. GAO continues to believe that it is 

important to apply the Government Pension Offset and Windfall 

Elimination Provision consistently and equitably and reiterates its earlier 

recommendation that Congress consider giving the Internal Revenue 

Service the authority to collect the information that SSA needs on 

government pension income to administer the Government Pension 

Offset and Windfall Elimination Provision accurately and fairly. In this 

report, we focus on other offsets—workers’ compensation offsets.

However, ensuring that these 

provisions offset benefits appropriately and accurately can pose 

administrative challenges.

 

1

For some of these programs, the calculation of the offset is not a significant issue. 

Supplemental Security Income (SSI) provides financial assistance to eligible individuals 

who are age 65 or older, blind or disabled, and who have limited income and resources. 

While SSI provides benefits to individuals with disabilities, the Disability Insurance (DI) 

program, also administered by SSA, uses the same definition of disability as SSI. SSI is a 

means-tested program, and the amount of the DI benefit is considered as income when 

determining whether an individual with a disability also qualifies for SSI. While individuals 

who receive SSI and DI have their SSI benefit offset based on the amount of their DI 

benefit, the appropriate offset calculation is not an issue since SSA administers both 

programs. Social Security also allows a person to receive both SSI and Temporary 

Assistance for Needy Families payments, but Temporary Assistance for Needy Families 

benefits are also considered income for SSI purposes, and will reduce the SSI payment. 

Other assistance received, such as from the Supplemental Nutrition Assistance Program 

and home energy assistance, is not considered income for SSI and thus does not offset 

the amount of the benefit received.

Why This Area Is 

Important
 

Page 181 GAO-12-342SP Duplication, Overlap, and Fragmentation 

The Social Security program’s workers’ compensation offsets reduce the 

potential for overlapping payments to beneficiaries who also receive 

workers’ compensation benefits. However, the lack of reliable information 

on receipt of workers’ compensation can result in these offset provisions 

not being administered fairly or equitably. Adequately addressing this 

issue offers the potential for cost savings by reducing overpayments.

Workers’ compensation consists of a complex array of programs that 

provide benefits to persons injured while working or who suffer 

occupational diseases. Employers provide workers’ compensation 

insurance for their employees and report work-related injuries to the state 

workers’ compensation agency. Although workers’ compensation 

programs exist in all states, the programs are not federally mandated, 

administered, or regulated.2 Workers’ compensation beneficiaries may 

also be eligible for federal program benefits, such as Social Security 

Disability Insurance (DI) and Supplemental Security Income (SSI). For 

these other programs, the law often limits access or reduces benefits for 

those receiving workers’ compensation. For example, if a person receives 

both DI and workers’ compensation benefits, and together these benefits 

exceed 80 percent of the injured worker’s average current earnings, SSA 

generally reduces the DI benefit.3

In a prior report, GAO found that SSA’s administration of the workers’ 

compensation offset provision continued to be undermined by the lack of 

reliable information identifying the receipt of workers’ compensation 

benefits by DI beneficiaries, causing payment errors.4

 

2

See 

No national 

reporting system identifies workers’ compensation beneficiaries. Instead, 

SSA largely relies on applicants and beneficiaries to report their receipt of 

workers’ compensation benefits and any changes that occur in the benefit 

amounts—an approach that makes it very difficult for SSA to make 

accurate benefit payments. GAO recommended that the Commissioner of 

Social Security and the Administrator of the Centers for Medicare & 

Medicaid Services test the extent to which sharing information that 

identifies persons who are or may be receiving workers’ compensation 

GAO-01-367 for more information. Also, workers’ compensation benefits are 

generally exempt from federal income taxes, so the IRS does not have any data on receipt 

of workers’ compensation benefits.

3

This offset was enacted in response to concern about individuals receiving excessive 

benefits as a result of receiving DI and workers’ compensation benefits concurrently. An

exception to the offset was made, however, for such individuals if they resided in states 

whose laws already reduce their workers’ compensation benefits (making a reduction in DI 

benefits unnecessary). Such state provisions are referred to as reverse offsets, and in 

these cases, SSA does not offset the DI benefit if it recognizes the state provision. The 

reverse offset exception only applies to state provisions that were in effect on February 

18, 1981.

4

In February 2011, the SSA Office of Inspector General found payment errors and 

estimated there were about $4 million in payments with errors resulting in underpayments 

and about $3.8 million in payments with errors resulting in overpayments related to the 

workers’ compensation offset.

What GAO Found
 

Page 182 GAO-12-342SP Duplication, Overlap, and Fragmentation 

benefits improves the accuracy of their benefit payment.5

For federal workers, the Federal Employees’ Compensation Act (FECA) 

program provides wage loss compensation and payments for medical 

treatment to those federal employees who are injured in the performance 

of their federal duties.

GAO also 

recommended that SSA officials meet with representatives from the 

workers’ compensation insurance industry to determine whether a viable 

voluntary reporting process could be established that would provide the 

government with information that periodically identifies workers’ 

compensation beneficiaries. In response, SSA met with the Centers for 

Medicare & Medicaid Services and representatives of the workers’ 

compensation insurance industry. Since these meetings, SSA has been 

able to do some data sharing with states, but on a very limited basis due 

to systems limitations. Additionally, the workers’ compensation insurance 

data held by privately-owned organizations is not available. Therefore, 

GAO continues to believe that this problem should be addressed.

6

As GAO reported in February 2008, the FECA program is vulnerable to 

improper payments. Some overpayments occur because Labor’s Office of 

Workers’ Compensation Programs (OWCP), which administers the 

program, does not regularly verify whether claimants are receiving SSA 

retirement benefits, for which FECA benefits are to be reduced. GAO 

recommended that OWCP take steps to ensure that wage-losscompensation payments for claimants covered by the federal retirement 

system are appropriately reduced by the amount of their SSA benefits 

that are attributable to their federal service. In response to our 

recommendation, OWCP reported that it has implemented an automated 

request to be sent to SSA when a claimant reaches retirement eligibility 

age to identify cases in which FECA payments should be reduced due to 

the receipt of Social Security retirement benefits. If this system functions 

as planned, it has the potential to reduce overpayments. Further, in 

October 2010, the SSA Office of Inspector General found that improper 

payments resulted when recipients’ FECA compensation was not 

A claimant can receive both FECA and SSA 

retirement benefits, although the claimant’s FECA wage-losscompensation payment is to be reduced by the amount of SSA retirement 

benefits attributable to federal service. Similarly, a claimant can receive 

both FECA and SSA disability benefits, although in such cases SSA is 

required to reduce the level of disability benefits it pays if the combined 

benefits exceed a certain amount.

 

5

Prior to July 2001, the Centers for Medicare & Medicaid Services was known as the 

Health Care Financing Administration. Throughout this report, we refer to the agency as 

Centers for Medicare & Medicaid Services, even when describing initiatives taken prior to 

its name change.

6

5 U.S.C. § 8101 et seq.
 

Page 183 GAO-12-342SP Duplication, Overlap, and Fragmentation 

recorded or accounted for in the calculation of their DI and SSI benefits.7

The Office of Inspector General projected that there were approximately 

$43 million in estimated DI overpayments and approximately $603,140 in 

SSI overpayments, based on a sample of beneficiaries who received 

FECA compensation any time from June 2002 to April 2010.

In response to prior recommendations, SSA has taken steps to explore 

the possibilities of sharing information with states and the workers’ 

compensation insurance industry to identify persons who might be 

receiving workers’ compensation benefits. While some information 

sharing has taken place, GAO continues to believe that additional 

opportunities exist to share information. While obtaining information from 

states is difficult, these efforts may help identify workers’ compensation 

beneficiaries so that benefits can be appropriately and accurately offset.

GAO provided a draft of this report section to the Department of Labor 

and the Social Security Administration for review and comment. Labor did 

not provide comments. SSA provided technical comments, which were 

incorporated as appropriate. As part of their comments, SSA indicated 

that as recently as 2011, they submitted draft legislation to Congress to 

require state and local governments, and any other entities that 

administer workers compensation and private disability plans, to provide 

SSA with information on payments to individuals under such plans.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

audit work GAO conducted.

Federal Workers’ Compensation: Better Data and Management 

Strategies Would Strengthen Efforts to Prevent and Address Improper 

Payments. GAO-08-284. Washington, D.C.: February 26, 2008.

Supplemental Security Income: Progress Made in Detecting and 

Recovering Overpayments, but Management Attention Should Continue.

GAO-02-849. Washington, D.C.: September 16, 2002.

SSA Disability: Enhanced Procedures and Guidance Could Improve 

service and Reduce Overpayments to Concurrent Beneficiaries. 

GAO-02-802. Washington, D.C.: September 5, 2002.

 

7

Social Security Administration, Office of Inspector General, Federal Employees 

Receiving Both Federal Employees’ Compensation Act and Disability Insurance 

Payments, A-15-09-19008 (Baltimore, Md.: Oct. 14, 2010).

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 
 

Page 184 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Workers’ Compensation: Action Needed to Reduce Payment Errors in 

SSA Disability and Other Programs. GAO-01-367. Washington, D.C.: 

May 4, 2001.

For additional information about this area, contact Charles Jeszeck at 

(202) 512-7215 or jeszeckc@gao.gov. Contact Information
 

Page 185 GAO-12-342SP Duplication, Overlap, and Fragmentation 

28. Housing Assistance

Examining the benefits and costs of housing programs and tax expenditures that address the same or similar 

populations or areas, and potentially consolidating them, could help mitigate overlap and fragmentation and 

decrease costs.

The federal government has played a major role in supporting housing 

since the 1930s. It funds programs that assist homebuyers, renters, and 

state and local governments. The goals of these efforts include 

encouraging homeownership and providing affordable rental housing for 

low-income families. Millions of Americans have benefited, whether by 

taking out a federally guaranteed mortgage, deducting mortgage interest 

or real estate taxes from income, or receiving a rental subsidy. In fiscal 

year 2010, the federal government incurred about $170 billion for 

obligations for housing-related programs and estimated revenue forgone 

for tax expenditures.1 Tax expenditures represent $132 billion (about 78 

percent) and may be viewed as spending programs channeled through 

the tax system because they are federal revenue forgone due to 

exclusions, credits, deductions, deferrals, and preferential rates.2

In the current housing crisis, support for homeownership has expanded 

dramatically with nearly all mortgage originations having direct or indirect 

federal support. The Department of the Treasury (Treasury) and the 

Board of Governors of the Federal Reserve System (Federal Reserve) 

together invested more than $1.67 trillion in Fannie Mae and Freddie 

Mac, the government-sponsored enterprises, which issue and guarantee 

mortgage-backed securities. Specifically, Treasury purchased about $221 

billion of mortgage-backed securities issued by Fannie Mae and Freddie 

Mac and about $183 billion of senior preferred stock, and the Federal 

Reserve purchased $1.27 trillion in the debt and securities of Fannie Mae 

and Freddie Mac. The ultimate costs of these efforts are not yet known. 

The federal role also expanded through programs such as the Home 

Affordable Modification Program and the First-Time Homebuyer Credit. 

 

1

The total does not include other types of emergency assistance. For loan programs, 

these obligations represent the expected credit subsidy costs for loan commitments made 

in fiscal year 2010. These estimates are revised in subsequent years and the ultimate cost 

will not be known until the loans mature. The amount of obligations we reported for fiscal 

year 2010 may include funds appropriated in the American Recovery and Reinvestment 

Act of 2009. 

2

Summing tax expenditure estimates does not take into account interactions between 

individual provisions. This total also does not include the exclusion of imputed net rental 

income. Imputed net rental income is the amount that owner-occupiers would have paid to 

rent a home, less nondeductible costs such as depreciation and maintenance expense. It 

is not subject to tax. The Department of the Treasury lists the exclusion of imputed net 

rental income as a tax expenditure and estimated the expenditure at $41 billion for fiscal 

year 2010. However, the Joint Committee on Taxation does not list the exclusion as a tax 

expenditure because it views measuring and taxing net imputed rental income as 

administratively infeasible. 

Why This Area Is 

Important
 

Page 186 GAO-12-342SP Duplication, Overlap, and Fragmentation 

However, fiscal and budget realities call into question continued 

maintenance of 160 different efforts with similar goals and sometimes 

parallel delivery systems.

Twenty different entities administer 160 programs, tax expenditures, and 

other tools GAO identified that supported homeownership and rental 

housing in fiscal year 2010 (see fig. below).3

 

3

See appendix III for the list of programs, tax expenditures, and other tools that supported 

homeownership and rental housing in fiscal year 2010 and their related budgetary 

information. Many of these programs/activities incurred no obligations in fiscal year 2010 

for a number of reasons, such as the program/activity was not part of the federal budget or 

was inactive during the year.

For example, 39 programs, 

tax expenditures, and other tools provide assistance for buying, selling, or 

financing a home, such as the single-family guaranteed loan program of 

the Department of Housing and Urban Development’s (HUD) Federal 

Housing Administration (FHA), the Department of Agriculture’s (USDA) 

Rural Housing Service (RHS), and the Department of Veterans Affairs 

and the capital gains exclusion on home sales administered by Treasury’s 

Internal Revenue Service (IRS). Eight programs and tax expenditures 

provide assistance for rental property owners, such as separate projectbased rental assistance programs provided by HUD and RHS and 

accelerated depreciation on rental housing administered by the IRS. 

Program overlap can occur when agencies and programs address the 

same or similar needs or target similar populations, and can result in 

fragmentation.

What GAO Found
 

Page 187 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Housing Activities/Programs by Purpose and Agency in Fiscal Year 2010

a

Some activities may have multiple purposes. 

b

Activities undertaken only by the Federal Reserve, not other regulators. 

As GAO reported in September 2000, overlap exists between products 

offered and markets served by USDA’s RHS, HUD, and others, and GAO 

questioned the need for maintaining separate programs for rural areas. 

GAO recommended that Congress consider requiring USDA and HUD to 

examine the benefits and costs of merging programs and cited RHS’s and 

FHA’s single-family guaranteed loan and multifamily portfolio management 

programs. In response, USDA noted that such a merger could be 

detrimental and result in rural areas losing a federal voice. In addition, HUD 

noted that without legislative changes, any efforts to merge the programs 

likely would result in a more cumbersome delivery system. The House 

Committee on Financial Services held hearings in 2011 considering a 

proposal that would move management of rural housing programs to HUD.

GAO’s ongoing work has shown increased evidence that some RHS and 

FHA programs can be consolidated. For instance, RHS relies on more in-
 

Page 188 GAO-12-342SP Duplication, Overlap, and Fragmentation 

house staff to oversee its single-family and multifamily loan portfolio of 

about $93 billion than HUD relies on to manage its single-family and 

multifamily loan portfolio of more than $1 trillion, largely because of 

differences in delivery structures. RHS has a decentralized structure of 

about 500 field offices that was set up to interact directly with borrowers.

RHS relies on over 1,600 full-time equivalent staff to process and service 

its direct single-family loans and grants. Since GAO’s 2000 report, the trend 

away from labor-intensive direct loans to guaranteed loans has 

accelerated. While RHS limits its direct loans to low-income households 

and its guaranteed loans to moderate-income households, FHA has no 

income limits and does not offer a comparable direct loan program. HUD 

operates about 80 field offices and primarily interacts through lenders, 

nonprofits, and other intermediaries. RHS and FHA programs both utilize 

FHA-approved lenders and underwriting processes based on FHA’s 

scorecard—an automated tool that evaluates new mortgage loans. RHS 

has about 530 full-time equivalent staff to process its single-family 

guaranteed loans. FHA relies on lenders to process its loans. Although 

FHA insures far more mortgages than RHS guarantees, FHA has just over 

1,000 full-time equivalent staff to oversee lenders and appraisers and 

contractors that manage foreclosed properties—costs for overseeing and 

disposing of such properties, were $887 million in 2010. In contrast, RHS’s 

costs for foreclosed property management are lower because RHS 

requires lenders to dispose of foreclosed properties. While the number of 

RHS field offices decreased by about 40 percent since 2000, its 

decentralized field structure continues to reflect the era in which it was 

established—the 1930s, when geographic boundaries greatly limited 

communication and transportation. These limitations have diminished and 

HUD programs can be used in all areas of the country.

Additionally, the two agencies offer examples of overlap in products offered 

(mortgage credit and rental assistance), functions performed (portfolio 

management and preservation), and geographic areas served. For instance, 

RHS and HUD guarantee single-family and multifamily loans, and offer rental 

subsidies using similar income eligibility criteria. Also, both agencies have 

been working to maintain and preserve existing multifamily portfolios. 

Although RHS may offer its products only in rural areas, it is not always the 

insurer of choice in those areas. For example, in fiscal year 2009 FHA 

insured over eight times as many single-family loans in economically 

distressed rural counties as RHS guaranteed. And, many RHS loan 

guarantees financed properties near urban areas—56 percent of singlefamily guarantees made in fiscal year 2009 were in metropolitan counties.

As shown in the figure above, Treasury and IRS provide numerous types 

of housing assistance through tax expenditures. Although often 

necessary to meet federal priorities, some tax expenditures can 

contribute to mission fragmentation and program overlap that, in turn, can 

create service gaps, additional costs, and the potential for duplication. For 

example, to qualify for a historic preservation tax credit, rehabilitation 

must preserve historic character, which may conflict with states’ efforts to 

produce energy-efficient, low-income properties with tax credits, and 

could increase project costs. Furthermore, inadequate or missing data 
 

Page 189 GAO-12-342SP Duplication, Overlap, and Fragmentation 

and difficulties in quantifying the benefits of some tax expenditures can 

impede studies of their efficiency, effectiveness, and equity.

Data represent a key challenge, as the data necessary to assess who 

benefits from tax expenditures is not always collected on tax returns 

unless IRS needs the information or collection was legislatively 

mandated. For example, although IRS collects some data on the 

mortgage interest deduction (the single-largest, housing-related tax 

expenditure), the data may not contribute to analyses of its effectiveness. 

Studies by the Joint Committee on Taxation and others differ as to the 

extent to which the mortgage interest deduction increases 

homeownership. Some studies suggest that the deduction increases 

homeownership, while others suggest that the deduction increases the 

price of housing (and higher prices are negatively associated with 

homeownership rates). Furthermore, some analyses emphasize the need 

for additional data to more effectively assess the impact of proposed 

modifications to the mortgage interest deduction on homeownership.

GAO recommended in September 2005 that the Office of Management 

and Budget (OMB) use information on outlay programs and tax 

expenditures to recommend to the President and Congress the most 

effective methods for accomplishing federal objectives. GAO concluded 

that better targeting by Congress and the executive branch of all federal 

spending and subsidy programs could save resources and increase 

economic efficiency. As discussed later, OMB disagreed with GAO’s 2005 

recommendations.

HUD and RHS have shared beneficial practices. For example, RHS 

collaborated with HUD on restructuring multifamily mortgages, underwriting 

guaranteed loans, and making properties more energy-efficient. In 2010, 

the White House’s Domestic Policy Council established a Rental Policy 

Working Group to better coordinate among HUD, USDA, and Treasury. 

The agencies have been aligning rules for rental programs, will examine 

homeownership programs, and expect to accept each other’s inspections 

and forms for housing programs. In 2011, the House Financial Services 

Subcommittee on Insurance, Housing and Community Opportunity 

developed draft legislation and hosted hearings in May and September on 

a proposal to move management of rural housing programs from USDA to 

HUD. At the May hearing, while some industry experts said the 

consolidation plan merited further discussion, others stated the proposal 

could negatively affect USDA’s efforts to deliver its other rural development 

programs. In September, the RHS Administrator testified that while she 

believed RHS and HUD shared an important commitment to meeting the 

housing needs of rural America, she opposed the draft legislation. She 

believed that RHS housing services uniquely served rural communities by 

working in “synergy” with other rural development programs.

GAO recommended in September 2000 that Congress consider requiring 

USDA and HUD to examine the benefits and costs of merging those 

programs that serve similar markets and provide similar products. 

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 190 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Further, GAO noted that as a first step, the Congress could consider 

requiring RHS and HUD to explore merging their single-family insured 

lending programs and multifamily portfolio management programs, taking 

advantage of the best practices of each and ensuring that targeted 

populations are not adversely affected.

The agencies have been working to align certain requirements of the various 

multifamily housing programs. In addition, in February 2011, the 

Administration reported to Congress that it would establish a task force to 

evaluate the potential for coordinating or consolidating the housing loan 

programs at HUD, USDA, and VA. According to HUD, a benchmarking effort 

associated with the task force was recently begun. GAO’s ongoing work 

considers options for consolidating these programs and GAO expects to 

make additional recommendations. 

GAO recommended in September 2005 and reiterated in March 2011 that 

coordinated reviews of tax expenditures with related spending programs 

could help policymakers reduce overlap and inconsistencies and direct 

scarce resources to the most-effective or least-costly methods to deliver 

federal support. Coordinated reviews of support of housing, which 

consists of tax expenditures and federal programs and regulations, could 

be useful. Specifically, GAO recommended in September 2005 and 

March 2011 that 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 

information; and (4) identifying resources needed for tax expenditure 

reviews; and

• require that tax expenditures be included in executive branch budget 

and performance review processes.

OMB, citing methodological and conceptual issues, disagreed with GAO’s 

2005 recommendations. To date, OMB has not used its budget and 

performance review processes to systematically review tax expenditures 

and promote integrated reviews of related tax and spending programs. 

However, in its fiscal year 2012 budget guidance, OMB instructed 

agencies, where appropriate, to analyze how to better integrate tax and 

spending policies with similar objectives and goals. The GPRA 
 

Page 191 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Modernization Act of 2010 also envisions such an approach for selected 

crosscutting areas.4 Such analysis could help identify redundancies.

GAO provided a draft of this report section to USDA, HUD, Department of 

Veterans Affairs, Treasury, the Internal Revenue Service, OMB, Federal 

Housing Finance Agency, Federal Reserve, Federal Deposit Insurance 

Corporation, Office of the Comptroller of the Currency, Consumer 

Financial Protection Bureau, Federal Financial Institutions Examination 

Council, and the Farm Credit Administration for review and comment. The 

Department of Veterans Affairs and the Consumer Financial Protection 

Bureau provided no comments. All other agencies provided technical 

comments, which were incorporated as appropriate. USDA reiterated the 

position that its rural agencies and programs, including the delivery 

system, serve a unique purpose and are vital to the rural communities 

they serve. In addition, USDA noted its recent efforts to streamline and 

improve the effectiveness of federal programs that serve rural 

communities, as part of the agency’s involvement in the President’s Rural 

Council. OMB stated that it agrees that savings might be achieved from 

the partial consolidation of guaranteed loan programs across agencies, 

but noted that any savings may be limited because USDA’s decentralized 

field offices support more than loan guarantee programs. OMB also 

indicated that they will identify tax expenditures which support the 

achievement of a limited number of cross-agency priority goals along with 

the fiscal year 2013 President’s Budget, as required by the GPRA 

Modernization Act of 2010. 

The information in this submission is based on findings from the products 

listed in the related GAO products section and additional work GAO 

conducted. GAO reviewed prior reports as well as collected and analyzed 

preliminary information from housing industry, USDA, and HUD officials, 

on examples of overlap or fragmentation in products offered, functions 

performed, and geographic areas served by various federal housing 

programs. GAO developed a catalog of direct spending programs, tax 

expenditures, and other activities used by federal agencies and financial 

regulators to support rental housing and homeownership, and identified 

what is known about the purpose, cost, eligibility, and populations served. 

GAO reviewed the Catalog of Federal Domestic Assistance, agency 

program documentation, and previous studies by the Congressional 

Research Service, Congressional Budget Office, and other housing 

 

4

The GPRA Modernization Act of 2010 established a new, crosscutting, and integrated 

framework for achieving results and improving government performance. It requires OMB 

to coordinate with agencies to establish outcome-oriented goals covering a limited number 

of crosscutting policy areas and to develop a governmentwide performance plan for 

making progress toward achieving those goals. The executive branch and Congress could 

use this process to identify and address program areas where strengthened interagency 

coordination is needed to better achieve results as well as areas of fragmentation, 

overlap, and duplication. 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 192 GAO-12-342SP Duplication, Overlap, and Fragmentation 

groups, and interviewed agency officials. GAO also reviewed the fiscal 

year 2012 President’s Budget, agencies’ budget justification, the Joint 

Committee on Taxation’s estimates of tax expenditures, and a 

compendium of tax expenditures prepared by the Congressional 

Research Service to obtain information on obligations, full-time 

equivalents, credit subsidy costs, administrative costs, and revenue loss 

estimates incurred by the federal government in administering housing 

programs. Appendix III lists the programs GAO identified that may have 

similar or overlapping objectives, provide similar services or be 

fragmented across government missions. Overlap and fragmentation may 

not necessarily lead to actual duplication, and some degree of overlap 

and duplication may be justified.

Federal Housing Administration: Improvements Needed in Risk 

Assessment and Human Capital Management. GAO-12-15. Washington, 

D.C.: November 7, 2011.

Tax Administration: Expanded Information Reporting Could Help IRS 

Address Compliance Challenges with Forgiven Mortgage Debt. 

GAO-10-997. Washington, D.C.: August 31, 2010.

Home Mortgage Interest Deduction: Despite Challenges Presented by 

Complex Tax Rules, IRS Could Enhance Enforcement and Guidance. 

GAO-09-769. Washington, D.C.: July 29, 2009.

Real Estate Tax Deduction: Taxpayers Face Challenges in Determining 

What Qualifies; Better Information Could Improve Compliance. 

GAO-09-521. Washington, D.C.: May 13, 2009.

Government Performance and Accountability: Tax Expenditures 

Represent a Substantial Federal Commitment and Need to Be 

Reexamined. GAO-05-690. Washington, D.C.: September 23, 2005.

Rural Housing Service: Overview of Program Issues. GAO-05-382T. 

Washington, D.C.: March 10, 2005.

Elderly Housing: Federal Housing Programs That Offer Assistance for the 

Elderly. GAO-05-174. Washington, D.C.: February 14, 2005.

Rural Housing: Changing the Definition of Rural Could Improve Eligibility 

Determinations. GAO-05-110. Washington, D.C.: December 3, 2004.

Rural Housing Service: Opportunities to Improve Management, 

GAO-03-911T. Washington, D.C.: June 19, 2003.

Rural Housing: Options for Optimizing the Federal Role in Rural Housing 

Development. GAO/RCED-00-241. Washington, D.C.: September 15, 2000.

For additional information about this area, contact Mathew Scirè at 

(202) 512-8678 or sciremj@gao.gov or James White at (202) 512-9110 or 

whitej@gao.gov. 

Related GAO 

Products 

Contact Information
 

Page 193 GAO-12-342SP Duplication, Overlap, and Fragmentation 

29. Early Learning and Child Care

The Departments of Education and Health and Human Services should extend their coordination efforts to 

other federal agencies with early learning and child care programs to mitigate the effects of program 

fragmentation, simplify children’s access to these services, collect the data necessary to coordinate operation 

of these programs, and identify and minimize any unwarranted overlap and potential duplication.

Millions of children under the age of 5 participate each year in federally 

funded preschool and other early learning programs or receive federally 

supported child care in a range of settings. Federal programs that funded 

early learning and child care as an explicit purpose received at least 

$13.3 billion in federal funding in fiscal year 2010.1 Research supports the 

importance of providing high-quality early learning experiences during 

children’s formative years.2 Furthermore, as GAO reported in May 2010, 

research indicates that having reliable, high-quality child care is also 

critical to sustaining parents’ ability to work. Federal support for early 

learning and child care developed over time to meet emerging needs. 

However, GAO previously reported that multiple federal agencies 

administer this important investment through numerous programs. This is 

perhaps a consequence of the different historical origins of early learning 

and child care programs, creating fragmentation of efforts, some overlap 

of goals or activities, and potential confusion among families and other 

program users.

The federal investment in early learning and child care is fragmented in 

that it is administered through 45 programs that provide or may support 

related services to children from birth through age 5, as well as five tax 

provisions that subsidize private expenditures in this area.3

 

1

Fiscal year 2010 is the latest date for which actual obligations have been reported, and 

funding data for two programs were not reported in budget justifications but obtained from 

federal agencies. This figure includes funding for the 12 programs GAO identified as 

having an explicit purpose of providing early learning or child care for children. It does not 

include federal programs with other purposes that permit the use of funds for early 

learning and child care as an allowable activity or that provide supporting services such as 

food and nutrition. For example, the figure does not include funding for two multipurpose 

block grants—the Social Services Block Grant and Temporary Assistance for Needy 

Families (TANF)—or for Title I Grants to Local Educational Agencies.

The programs 

are concentrated within the Departments of Education (Education) and 

Health and Human Services (HHS)—the principal administrators of the 

federal government’s early learning and child care programs—but are 

also administered by the Departments of Agriculture, the Interior, Justice, 

2

J. Shonkoff and D. Phillips, Eds, From Neurons to Neighborhoods: The Science of Early 

Childhood Development (Washington, D.C.: National Academy Press, 2000). 

3

In identifying these programs, the criteria GAO used were that these programs (1) fund or 

support early education or child care services, (2) are provided to children under age 5, 

and (3) deliver services in an educational or child care setting.

Why This Area Is 

Important

What GAO Found
 

Page 194 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Labor, Housing and Urban Development (HUD), the General Services 

Administration (GSA), and the Appalachian Regional Commission. Some 

of these programs overlap in that they have similar goals for children 

under the age of 5 and are targeted to similar groups of children. For 

example, five programs, administered by Education and HHS, provide 

school readiness services to low-income children, and programs in both 

Education and the Interior provide funding for early learning services for 

Indian children. 

Among the 45 programs, 12 have an explicit program purpose of 

providing early learning or child care services.4 GAO reported in January 

2000 that although individual programs may differ in the exact services 

provided, the distinction between early learning and child care has blurred 

over time as policymakers seek to make educationally enriching care 

available to young children. As seen in the table below, all 12 programs 

serve children under the age of 5, and some also serve older children; 

however, they vary in targeted child population. Furthermore, they vary 

substantially in funding levels. For example, 9 of the 12 programs 

obligated less than $500 million each in fiscal year 2010, while the largest

program, Head Start, obligated $7.2 billion in that year.5

Purposes and Targeted Populations of Federal Programs That Have Early Learning or Child Care as an Explicit Program 

Purpose 

Program name 

by federal 

agency

Specific child population targets

Explicit program purpose Age group Other population limits

Early learning 

services

Child care 

services

Children under 

5 primarily

Larger age 

group, including 

children under 5

Lowincome 

children

Children 

with 

disabilities

Other 

targeted 

populations

Department of Education

Child Care 

Access Means 

Parents in 

School

• • • •

Indian EducationGrants to Local 

Educational 

Agencies

• • •

Race to the Top 

– Early Learning 

Challenge • • •

 

4

GAO considers a program as having an explicit early learning or child care purpose when 

the program objectives in the Catalog of Federal Domestic Assistance or other agency 

documents refer to early learning or child care. 

5

This figure excludes American Recovery and Reinvestment Act of 2009 funds. Pub. L. 

No. 111-5. See appendix III for information on fiscal year 2010 program obligations for 

early learning and child care programs.
 

Page 195 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Program name 

by federal 

agency

Specific child population targets

Explicit program purpose Age group Other population limits

Early learning 

services

Child care 

services

Children under 

5 primarily

Larger age 

group, including 

children under 5

Lowincome 

children

Children 

with 

disabilities

Other 

targeted 

populations

Special 

Education-Grants 

for Infants and 

Families 

• • • •

Special 

EducationPreschool Grants • • •

State Fiscal 

Stabilization 

Fund - Education 

State Grants, 

Recovery Act

• • •

Striving Readers 

Comprehensive 

Literacy • • •

Department of Health and Human Services

Child Care and 

Development 

Block Granta • • •

Child Care 

Mandatory and 

Matching Funds 

of the Child Care 

and 

Development 

Funda

• • •

Head Start • • • •

Department of the Interior

Indian Child and 

Family Education 

(FACE) • • •

General Services Administration

The General 

Services 

Administration’s 

Child Care 

Program

• • •

Source: GAO analysis of Catalog of Federal Domestic Assistance and federal agency program information.

Note: All programs included in this table are those for which early learning or child care is explicitly 

described as a program purpose, according to GAO’s analysis of Catalog of Federal Domestic 

Assistance and other agency information. It does not include additional programs that either support 

early learning or child care or that allow such services. All programs GAO identified are listed in 

appendix III.

a

In combination, Child Care and Development Block Grant funds and Child Care Mandatory and 

Matching Funds are referred to as the Child Care and Development Fund. 

However, the majority of the 45 programs GAO identified do not have the 

explicit purpose of delivering early learning or child care services, but 

rather permit use of funds for this purpose or provide supportive services 

to facilitate such care.
 

Page 196 GAO-12-342SP Duplication, Overlap, and Fragmentation 

• Some programs are multipurpose block grants for which early learning 

or child care is not a primary purpose but which are nevertheless 

known to provide significant funding for child care. For example, the 

Temporary Assistance for Needy Families block grant accounted for 

$3.5 billion in child care funding in fiscal year 2009.

• Other programs may allow funds to be used for early learning or child 

care, but these are not among their primary goals and such uses do 

not typically represent a significant portion of available program funds. 

For example, the Department of Justice has one program to help 

victims of violence that can provide child care as a short-term, 

ancillary service, and Title I Grants to Local Educational Agencies, an 

Education grant, spent about 2 percent of total obligations on early 

education programs in fiscal year 2009.

• Some programs provide supportive services that can facilitate early 

learning or child care. For example, the Department of Agriculture has 

four programs whose primary purpose is to provide food and nutrition 

services to mostly school-age low-income children, though preschool 

children also receive program services in some cases.6

In addition to these federally funded programs, five federal tax provisions 

support early education and care by forgoing tax revenue to subsidize the 

private purchase of child care services. Some tax provisions are for 

families and some are for employers that provide child care at the 

workplace. These five tax expenditures accounted for at least $3.1 billion 

of forgone tax revenue for the U.S. Treasury in fiscal year 2010.7 The 

revenue that the government forgoes through tax expenditures can be 

viewed as spending channeled through the tax system, contributing to 

mission fragmentation and program overlap. As GAO previously reported 

in September 2005, coordinated reviews of tax expenditures and related 

programs may reduce fragmentation and overlap.8

 

6

GAO has described the fragmentation and overlap of these and other nutrition assistance 

programs in Domestic Food Assistance: Complex System Benefits Millions, but Additional 

Efforts Could Address Potential Inefficiency and Overlap among Smaller Programs, 

While it may be 

possible for some families to receive benefits through both tax provisions 

GAO-10-346 (Washington, D.C.: Apr. 15, 2010). 

7

Two of the five tax expenditures—Exclusion Of Benefits Provided Under Cafeteria Plans 

and Exclusion of Income Earned by Voluntary Employees Beneficiary Associations—

include revenue used for health care and other benefits besides child care. 

8

In September 2005, GAO recommended that the Office of Management and Budget 

(OMB), in consultation with the Secretary of the Treasury, develop and implement a 

framework to review tax expenditures. In March 2011, GAO reported that OMB, in its fiscal 

year 2012 budget guidance, instructed agencies, where appropriate, to analyze how to 

better integrate tax and spending policies that have similar goals and objectives. See 

Government Performance and Accountability: Tax Expenditures Represent a Substantial 

Federal Commitment and Need to Be Reexamined, GAO-05-690 (Washington, D.C.: 

Sept. 23, 2005), and Opportunities to Reduce Potential Duplication in Government 

Programs, Save Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: 

Mar. 1, 2011).
 

Page 197 GAO-12-342SP Duplication, Overlap, and Fragmentation 

and federal early learning and child care programs in a particular year, 

many families eligible to participate in federal programs may not have tax 

liabilities due to their low incomes and would not benefit from these tax 

provisions.9

Although some programs fund similar types of services for similar 

populations, differing program structures, eligibility requirements, and 

data limitations create obstacles to assessing whether actual duplication 

exists among these programs.

• Programs are differently structured, administered, and regulated. For 

example, the two largest programs—funded under Head Start and the 

Child Care and Development Fund (CCDF)—differ significantly in their 

structure.10

• The nature of eligibility requirements also differs among programs, 

even for similar subgroups of children, such as those from low-income 

families. For example, Head Start serves primarily low-income 

children under the age of 5 whose families have incomes at or below 

the official federal poverty guidelines, while CCDF funds services to 

children under age 13 whose parents are working or in school and 

who may earn up to 85 percent of state median income.

Head Start was created in part to support children’s early 

development by offering comprehensive, community-based services 

to meet multiple needs and, as such, provides federal grants directly 

to community-based public and private service providers. CCDF, 

created under welfare reform, helps states reduce dependence on 

public assistance by subsidizing child care to support parents’ 

involvement in the workforce and provides grants to states, which they 

in turn generally provide as subgrants to counties or other local 

entities for distribution to parents.

• For some programs, relevant programmatic information is sometimes 

not readily available. For example, Education and HHS officials were 

unable to provide GAO with information on the number of children 

served for several programs. As GAO previously reported in 2005 and 

September 2011, HHS did not collect data on working families who 

receive child care assistance directly funded by TANF, and GAO 

suggested that Congress may wish to require this data collection.

 

9

These tax provisions primarily benefit families with higher incomes than those eligible for 

CCDF or Head Start. For example, more than half of the beneficiaries of the Child and 

Dependent Care Tax Credit earned incomes of at least $50,000 annually in fiscal year 

2009. In contrast, the Child Care and Development Fund generally limits eligibility to 

families at or below 200 percent of the federal poverty guidelines (that is, about $37,000 or 

less for a family of 3 in 2011), and Head Start eligibility is closer to 100 percent of the 

poverty guidelines. 

10Preliminary fiscal year 2009 data are the latest available for number of children served 

under CCDF. 
 

Page 198 GAO-12-342SP Duplication, Overlap, and Fragmentation 

• Inadequate or missing data, as well as difficulties quantifying the 

benefits of some tax expenditures, can make it difficult to study the 

efficiency of these expenditures.11

To the extent that programs in different agencies have similarities, 

fragmentation and program overlap can create an environment in which 

programs may not serve children and families as efficiently and effectively 

as possible. The existence of multiple programs can also create added 

administrative costs, such as costs associated with determining eligibility 

and meeting varied reporting requirements. However, despite some 

overlap in program purposes and targets, it is likely that service gaps exist, 

since these programs generally are not designed as entitlements that serve 

all eligible children. For example, as GAO previously reported in May 2010, 

about one-third or fewer of potentially eligible children received child care 

subsidies from CCDF, Temporary Assistance for Needy Families, and the 

Social Services Block Grant between fiscal years 2004 and 2007, 

according to GAO’s review of several HHS estimates. HHS has identified 

improving program access and quality as high-priority performance goals 

for both Head Start and child care programs.

Coordinating the administration and evaluation of early learning and child 

care programs can help mitigate the effects of program fragmentation and 

overlap and potentially help bridge service gaps; however, there is 

currently no federal interagency workgroup that coordinates early learning 

and child care efforts across all federal agencies with such programs. 

Education and HHS have numerous coordinating initiatives and 

agreements with each other, within their departments, and in support of 

state and local coordination. For example, Education and HHS formed an 

interagency policy board in August 2010 whose goals included improving 

the quality and effectiveness of Education and HHS early learning 

programs; increasing the coordination of research, technical assistance 

and data systems; and, in an advisory role, maximizing resources. In 

2009, HHS established an executive-level liaison office to coordinate 

interagency efforts, and Education proposed establishing a similar 

coordination office in 2011. Education and HHS have also collaborated in 

jointly administering the Race to the Top - Early Learning Challenge. In 

addition, the two departments have supported early learning and child 

care coordination at the state and local levels, such as through State 

Advisory Councils on Early Childhood Education and Care and other 

early childhood programs.12

 

11As GAO noted in earlier work, tax returns generally do not collect information necessary 

to assess how often a tax expenditure is used and by whom unless the IRS needs the 

information or collection is legislatively mandated. See 

HHS has also established workgroups and 

GAO-05-690. 

12The Improving Head Start for School Readiness Act of 2007 required the governor of 

each state to designate or establish State Advisory Councils, and funds provided under 

the American Recovery and Reinvestment Act of 2009 were used to support them. Pub. L. 

No. 110-134, § 11(b) (codified at 42 U.S.C. § 9837b(b)(1)(A)) and Pub. L. No. 111-5, 123 

Stat. 115, 178. 
 

Page 199 GAO-12-342SP Duplication, Overlap, and Fragmentation 

collaborative efforts with several other individual federal departments, 

such as Agriculture, Defense, and HUD, to increase the availability and 

quality of child care or for other goals. However, these workgroups do not 

bring multiple agencies together, and GSA, the Departments of the 

Interior, Justice, Labor, and the Appalachian Regional Commission also 

have programs with some child care component that are not part of 

broader cross-agency initiatives but could likely benefit from the expertise 

of Education and HHS. 

The GPRA Modernization Act of 2010 (GPRAMA) could serve as a 

vehicle for furthering interdepartmental coordination of early learning and 

child care. The Act established a new, cross-cutting, and integrated 

framework for achieving results and improving government 

performance.13 Among other things, each agency is to identify the 

various federal organizations and activities—both within and external to 

the agency—that contribute to its goals, and describe how the agency is 

working with other agencies to achieve its goals as well as any relevant 

crosscutting goals. The executive branch and Congress could use this 

process to identify and address program areas where strengthened 

interagency coordination is needed to better achieve results as well as 

areas of fragmentation, overlap and duplication.

As the principal administrators of the federal government’s early learning 

and child care programs, and consistent with Education’s and HHS’s 

identification of early learning access and quality as priorities, the 

Secretaries of Education and HHS should 

• deepen and extend their ongoing coordination efforts by including all 

the federal agencies that provide or support early learning or child 

care services in an inter-departmental workgroup that focuses on this 

population. 

Using the GPRAMA framework, workgroup goals could include mitigating 

the effects of program fragmentation (for example, through simplifying 

children’s access to these services), identifying and managing service 

gaps, meeting data requirements for the coordinated operation and 

evaluation of these programs, and identifying and minimizing any 

unwarranted overlap. These efforts could also provide a vehicle to 

conduct a coordinated analysis of child care tax expenditures and 

program spending.

GAO provided a draft of this report section to Education, HHS, and OMB. 

HHS provided written comments. Education and OMB, as well as HHS, 

provided technical comments, which were incorporated as appropriate. 

 

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

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 200 GAO-12-342SP Duplication, Overlap, and Fragmentation 

All three agencies agreed on the importance of further coordination of the 

federal programs supporting early learning and child care. Education 

explicitly agreed with GAO’s recommended action and identified an 

existing interagency workgroup as a means of coordinating early learning 

and child care services. This group currently focuses primarily on services 

for youth from early to late adolescence. HHS acknowledged but did not 

explicitly agree or disagree with the specific action GAO recommended, 

while OMB questioned the need for a new interagency working group and 

the efficiency of including agencies whose programs are not explicitly 

designed to deliver early learning or child care services. GAO believes 

that agencies with some, but not extensive, investment in early learning 

or child care might benefit greatly from such inclusion to reduce any 

effects of fragmentation. Extending interagency coordination could be 

efficiently accomplished through an existing workgroup on early learning 

and child care, for example, by establishing a subcommittee with 

representation from the additional agencies. GAO has modified the 

recommended action to clarify that inclusion of these additional agencies 

does not necessarily entail establishing a new federal interagency 

workgroup. 

HHS also highlighted information on its ongoing coordination efforts and 

noted concerns with the report’s treatment of specific issues. Specifically, 

HHS stated that the report did not fully explore how program services 

may be complementary rather than duplicative, take into account that 

many states jointly administer flexible funding streams to provide services 

to children and families, or adequately explain the distinction between 

federally funded early learning and child care programs and federally 

funded programs that permit the use of funds for the provision of child 

care. As noted in this report, the complexity of the current service delivery 

system, combined with data limitations, form significant obstacles to 

assessing the extent to which services are complementary or duplicative. 

GAO’s report acknowledges the role that states play in coordinating these 

programs but, as HHS’s comments indicate, the extent to which states 

coordinate the administration of early learning and child care funding 

streams can and does vary. Moreover, the federal government also has 

an important role in program administration, necessitating a federal role in 

coordination. Further, GAO clearly distinguished between programs that 

have an explicit purpose to provide these services, like CCDF and Head 

Start, and those that permit the use of funds for these services or that 

provide supportive services to facilitate such care; however, it remains 

important to note that some of the latter group, such as Temporary 

Assistance for Needy Families nonetheless provide significant funding for 

child care. 

OMB recommended that GAO remove two programs from the list of 

programs with an explicit early learning or child care purpose; however, 

GAO did not change the program list because the programs met GAO’s 

criteria. 
 

Page 201 GAO-12-342SP Duplication, Overlap, and Fragmentation 

As part of its routine audit work, GAO will monitor the progress agencies 

make in addressing this needed action and report to Congress. All written 

comments are reprinted in appendix IV.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted. GAO searched the Catalog of Federal Domestic 

Assistance to identify federal early learning and child care programs; 

obtained supplementary information from Education, HHS, and other 

agencies; and reviewed previous GAO reports on early learning and child 

care.14 GAO did not conduct a separate legal review to identify and 

analyze relevant programs. In its work, GAO identified 45 early learning 

and child care programs that met its criteria for analysis: those that (1) 

fund or support early education or child care services; (2) are provided to 

children under age 5; and (3) deliver services in an educational or child 

care setting. GAO also identified a subset of 12 programs with early 

learning and child care as an explicit program purpose. GAO determined 

that the Catalog of Federal Domestic Assistance was sufficiently reliable 

for GAO’s purposes by confirming with federal agency officials that the 

programs identified met GAO’s criteria and obtaining information from 

agencies about any additional programs for GAO consideration. GAO 

searched the Congressional Research Service’s 2010 Tax Expenditures: 

Compendium of Background Material on Individual Provisions to identify 

five tax expenditures that met similar criteria for early learning and child 

care.15 GAO obtained and analyzed descriptions of Education and HHS 

coordination efforts for early learning and child care programs, but 

assessing the effectiveness of these two particular agencies’ coordination 

efforts was beyond the scope of this study. Appendix III lists the programs 

GAO identified that may have similar or overlapping objectives, provide 

similar services or be fragmented across government missions. Overlap 

and fragmentation may not necessarily lead to actual duplication, and 

some degree of overlap and duplication may be justified. Appendix III also

lists related tax expenditures.

 

14See the related GAO products section. 

15Those that (1) fund or support early education or child care services, (2) are obtained on 

behalf of children under 5, and (3) forgo taxes that can be used to purchase child care 

services occurring in an educational or child care setting.

How GAO Conducted 

Its Work
 

Page 202 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Temporary Assistance for Needy Families: Update on Families Served 

and Work Participation. GAO-11-880T. Washington, D.C.: September 8, 

2011.

Human Services Programs: Opportunities to Reduce Inefficiencies.

GAO-11-531T. Washington, D.C.: April 5, 2011.

Federal Education Funding: Overview of K-12 and Early Childhood 

Education Programs. GAO-10-51. Washington, D.C.: January 27, 2010.

Child Care: Multiple Factors Could Have Contributed to the Recent 

Decline in the Number of Children Whose Families Receive Subsidies.

GAO-10-344. Washington, D.C.: May 5, 2010.

Human Service Programs: Demonstration Projects Could Identify Ways to 

Simplify Policies and Facilitate Technology Enhancements to Reduce 

Administrative Costs. GAO-06-942. Washington, D.C.: September 19, 

2006.

Child Care: Additional Information Is Needed on Working Families 

Receiving Subsidies. GAO-05-667. Washington, D.C.: June 29, 2005.

GAO Update on the Number of Prekindergarten Care and Education 

Programs. GAO-05-678R. Washington, D.C.: June 2, 2005.

Head Start and Even Start: Greater Collaboration Needed on Measures 

of Adult Education and Literacy. GAO-02-348. Washington, D.C.: March 

29, 2002.

Early Education and Care: Overlap Indicates Need to Assess 

Crosscutting Programs. GAO/HEHS-00-78. Washington, D.C.: April 28, 

2000.

Early Childhood Programs: Characteristics Affect the Availability of 

School Readiness Information. GAO/HEHS-00-38. Washington, D.C.: 

February 28, 2000.

For additional information about this area, contact Kay E. Brown at (202) 

512-7215 or brownke@gao.gov. 

Related GAO 

Products 

Contact Information
 

Page 203 GAO-12-342SP Duplication, Overlap, and Fragmentation 

30. Employment for People with Disabilities

Better coordination among 50 programs in nine federal agencies that support employment for people with 

disabilities could help mitigate program fragmentation and overlap, and reduce the potential for duplication or 

other inefficiencies.

Nearly one in five people in the United States has a disability.1

For 15 years, GAO has reported on the need for better coordination 

among all disability programs to mitigate fragmentation, overlap, and 

potential for duplication. As GAO reported in September 1996, programs 

helping people with disabilities were not working together efficiently, and 

people with disabilities may have been receiving duplicate services or 

facing service gaps due to lack of coordination. Over a decade later, in 

May 2008, GAO and others recommended establishing a coordinating 

entity—perhaps under the leadership of the executive branch—to develop 

a federal strategy to integrate services and support for individuals with 

disabilities. To date, no coordinating entity has been established, and this 

lack of coordination was a factor in federal disability programs remaining 

on GAO’s high-risk list in February 2011.

In fiscal 

year 2010, the federal government obligated at least $3.5 billion in 

employment supports to help this population become more self-sufficient. 

Even so, in December 2011, the unemployment rate for people with 

disabilities was 13.5 percent, higher than the rate for people without 

disabilities (8.1 percent). Research has shown that people with disabilities 

may face multiple barriers to employment, including poor health or 

functioning; inadequate skills or training; lack of accessible workplaces or 

accommodations; and discrimination. Over the years, many programs 

across the federal government, including within the Departments of 

Education; Health and Human Services; Labor; and Veterans Affairs and 

other agencies, have been created or have evolved to address these 

barriers.

GAO identified 50 programs that, in fiscal year 2010, supported 

employment for people with disabilities and found that these programs 

were fragmented and often provided similar services to similar 

populations.2

 

1

U.S. Census Bureau, Americans with Disabilities: 2005. (Washington, D.C.: December 

2008). Data come from the Survey of Income and Program Participation, June – 

September 2005.

Among these programs, GAO included six programs that 

2

In commenting on a draft of this section, a Department of Defense official requested that 

GAO add two programs that he believed to be within the scope of this review. GAO has 

added the two programs to the list in appendix III. GAO will pursue additional information 

on these programs for a final report on employment support for people with disabilities, to 

be issued later in 2012.

Why This Area Is 

Important

What GAO Found
 

Page 204 GAO-12-342SP Duplication, Overlap, and Fragmentation 

were eliminated or are slated to end by the end of fiscal year 2012.3 The 

50 programs were administered by nine federal agencies and were 

overseen by even more congressional committees (see figure below).4

 

3

Specifically, five programs—two of which were demonstration studies of limited 

duration—had ended by December 2011 and agency officials expected one more to 

sunset by the end of fiscal year 2012. The Department of Education’s fiscal year 2012 

budget request proposed eliminating or consolidating an additional three programs into its 

Vocational Rehabilitation State Grants program in order to reduce duplication of effort and 

administrative costs, streamline program administration at the federal and local levels, and 

improve efficiency and accountability. However, funds were appropriated for all three 

programs in fiscal year 2012. GAO did not include or review programs that may have been 

created or revised after fiscal year 2010.

More than half (30) of these programs served only people with disabilities, 

while the other programs served a broader population but provided 

special consideration or gave priority in service to people with disabilities 

or their employers. The definitions of disability that programs used varied, 

and 20 percent of programs reported having no specific definition of 

disability. Fragmented programs that do not coordinate effectively could 

waste scarce funds, confuse and frustrate program beneficiaries, and limit 

the overall effectiveness of the federal effort.

4

Programs that serve wounded, ill, or injured servicemembers were included within the 

scope of analysis. 
 

Page 205 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Programs Supporting Employment for People with Disabilities, in Fiscal Year 2010, 

Were Fragmented across Nine Federal Agencies

a

The Department of Labor jointly administers the Workforce Recruitment Program with the 

Department of Defense and the Work Opportunity Tax Credit with the Internal Revenue Service. 

These programs are therefore included under both the Department of Labor and each of their 

respective agencies in the above graphic. 

Many of the 50 programs GAO identified overlapped in that they provided 

similar employment services to similar populations. GAO surveyed the 

programs and found that they provided a range of services, from 

employment counseling and job search assistance to tax credits for 

employers who hire people with disabilities. Overlap was the greatest in 

programs serving two distinct population groups—veterans and 

servicemembers; and students and young adults. GAO identified 18 

programs that limited eligibility to veterans and servicemembers, 6 that 

limited eligibility to students and young adults, and 14 programs that did 

not limit eligibility to any particular population and were potentially 

available to individuals in these groups. For example, as shown in the 

table, officials at five of the six youth programs reported that they 

provided employment counseling, assessment, and case management. 

At the same time, any youth could have received these services from nine 

other programs that did not limit eligibility to a particular population.
 

Page 206 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Programs Providing Similar Employment Services to Similar Populations, in Fiscal Year 2010

Programs that 

limited eligibility 

to servicemembers, 

veterans, and/or 

their families 

(18 total)

Programs that 

limited eligibility 

to students, 

transition age 

youth, and/or 

young adults

(6 total )a

Programs that 

limited eligibility 

to other 

populations or 

disabilities 

(12 total)b

Programs 

that served 

all people 

with 

disabilities 

(14 total)

Total 

programs 

offering each 

service (50 

total) 

Employment-related information 

dissemination 

17 5 10 10 42

Employment counseling, assessment, 

and case management

15 5 10 9 39

Job readiness skills 16 5 9 8 38

Job search or job placement activities 15 5 9 8 37

Job recruitment and referrals 15 5 9 7 36

Assistive technology and workplace 

accommodations 

12 4 10 10 36

Job development 14 4 9 7 34

Job retention training 13 4 9 7 33

Support and services to employers of 

people with disabilities

13 3 8 8 32

On-the-job training 10 4 9 7 30

Occupational or vocational training 11 3 8 6 28

Work experience 12 5 6 4 27

Entrepreneurship training and support 10 3 7 6 26

Vocational rehabilitation 10 1 9 5 25

Supported employment 9 1 8 6 24

Assistance in earning a high school 

diploma or its equivalent 

6 5 5 6 22

Remedial academic, English language 

skills, or basic adult literacy 

6 4 5 4 19

Tax expenditures related to workers with 

disabilities 

2 0 0 0 2 

Source: GAO survey of federal programs that support employment for people with disabilities.

a

Although the Job Corps program is generally limited to youth, eligible people with disabilities can 

participate in the program at any age. Therefore, GAO included the Job Corps program in the 

category, “programs that served all people with disabilities.” 

b

Some programs within this category limited eligibility to similar populations, such as recipients of 

Social Security Disability Insurance and Supplemental Security Income, while others were unique in 

limiting eligibility to certain populations. For example, one program in this category limited eligibility to 

Native Americans, another limited eligibility to people who are blind, and a third limited eligibility to 

people with disabilities and their families engaged in production agriculture. 

Some programs that provided similar services to similar populations had 

a greater potential for duplication than others. For example, the 

Department of Labor’s Disabled Veterans’ Outreach Program and the 

Local Veterans’ Employment Representatives program both reported that 

they provided job search and placement services to veterans with 

disabilities, among other similar services. Labor officials said that the 

veterans’ employment representatives were intended to reach out to 

employers and the disabled veterans’ outreach specialists were intended 

to work with job seekers. However, as GAO reported in May 2007, staff 
 

Page 207 GAO-12-342SP Duplication, Overlap, and Fragmentation 

often performed the same roles in one-stop career centers and, in some 

cases, the roles were carried out by the same staff member. A recent law 

gave states the flexibility—subject to the approval of the Secretary of 

Labor—to consolidate these two programs in order to promote more 

efficient provision of services.5

In contrast, some overlapping programs have meaningful differences in 

their specific eligibility criteria or program design that could reduce their 

potential for duplication. For example, the Department of Labor’s 

YouthBuild program provides disadvantaged youth with education and 

employment skills necessary in high-demand occupations, such as 

construction trades; whereas the Workforce Recruitment Program for 

College Students with Disabilities places college students and recent 

graduates with disabilities in jobs and internships with primarily federal 

employers. In addition, while GAO identified two employment-related tax 

expenditures that affect veterans, the programs’ approaches differed. The 

Work Opportunity Tax Credit provides a tax credit to employers who hire 

individuals from target groups, including disabled veterans, while VA’s 

Compensated Work Therapy program exempts disabled veterans from 

paying federal taxes on income earned through the program. Finally, 

certain programs that provide similar services may have less potential for 

duplication because they may not have the capacity to serve all who 

apply. For instance, officials from seven programs reported a waiting list 

for their services.

Better coordination or streamlining of agency roles and responsibilities may 

address fragmentation and potential duplication or unmet needs, but 

officials that GAO surveyed reported limited coordination among the 50 

programs. GAO asked respondents to indicate whether their program 

coordinated with any of the other programs surveyed. In 8 percent of 

cases, two programs mutually reported coordinating. However, in most 

cases, respondents either reported not coordinating or inconsistently 

reported coordinating with other programs. For example, although the 

Department of Education’s Vocational Rehabilitation Services program 

reported coordinating with the Department of Health and Human Services’ 

Medicaid 1915(c) Home and Community Based Services Waiver program 

and the Department of Labor’s Disabled Veterans’ Outreach Program, only 

one of these two programs—the waiver program—reported coordinating 

with the Vocational Rehabilitation Services program. GAO plans to conduct 

additional work on the extent of coordination among selected programs as 

part of a more detailed report on programs that support employment for 

people with disabilities.

As GAO reported in October 2006, interagency collaboration can be 

enhanced when agencies work toward a common goal, establish 

complementary strategies for achieving that goal, and use common 

 

5

VOW to Hire Heroes Act of 2011, Pub. L. No. 112-56, § 241(c), 125 Stat. 712, 728. 
 

Page 208 GAO-12-342SP Duplication, Overlap, and Fragmentation 

performance measures when appropriate.6 Although 82 percent (41) of 

the 50 programs tracked at least one employment-related outcome 

measure, the measures varied across programs. Twenty-two programs 

reported that they did not track or monitor any outcome measures 

specifically for people with disabilities—mostly those that did not limit 

eligibility to this population. Only six programs monitored whether they 

helped reduce participants’ reliance on federal cash benefits. In August 

2007, experts at a GAO forum recommended that the federal government 

establish a set of program outcome indicators to measure the success of 

federal disability programs. An important consideration in developing such 

measures is the challenge of comparing outcomes while accounting for 

variations in the type and severity of participants’ disabilities.

The federal government spends several billion dollars each year to help 

people with disabilities retain or obtain employment, a relatively small 

sum compared to the amount the government spends on providing cash 

benefits and other assistance to this population. Despite this federal 

investment, the unemployment rate among people with disabilities 

remains relatively high and very few Social Security disability 

beneficiaries earn enough to terminate federal cash assistance. While a 

low return-to-work rate among Social Security disability beneficiaries is 

not necessarily surprising, given that eligibility for the program is based 

on the inability to work, some beneficiaries can and do work. Even small 

shifts in the employment rate of disability beneficiaries could mean 

substantial savings to the federal government, which is particularly 

significant since the Social Security Administration’s Disability Insurance 

trust fund is expected to be exhausted by 2018. In this context, the 

number of programs providing similar employment services to people with 

disabilities raises questions about the efficiency and effectiveness of the 

current structure of federal disability programs. In its February 2011 highrisk update, GAO reported that an overall federal strategy and 

governmentwide coordination among programs is needed to align 

disability policies, services, and supports. At the same time, the GPRA 

Modernization Act of 2010 (GPRAMA) established a new, cross-cutting, 

and integrated framework for achieving results and improving government 

performance.7 It requires the Office of Management and Budget (OMB) to 

coordinate with agencies to establish outcome-oriented goals covering a 

limited number of crosscutting policy areas and to develop a 

governmentwide performance plan for making progress toward achieving 

those goals.

 

6

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 

7

Pub. L. No. 111-352, 124 Stat. 3866 (2011).

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 209 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Consistent with that effort, to improve performance through greater 

coordination among the many federal programs that support employment 

for people with disabilities, OMB should

• consider establishing measurable, governmentwide goals for 

employment of people with disabilities. Given the number of federal 

agencies and approaches involved in supporting employment for 

people with disabilities, governmentwide goals could help spur greater 

coordination and more efficient and economical service delivery in 

overlapping program areas. To determine whether these goals are 

being met, agencies should establish related measures and indicators 

and collect additional data to inform these measures. 

Establishing governmentwide goals and measures for employment of 

people with disabilities is a critical first step in developing an overall 

federal strategy to align disability policy, services, and supports—a 

recommendation GAO first made to Congress in May 2008.

It is difficult to recommend specific areas for cost savings or streamlining 

because there are, at present, limited data available to determine which 

programs are achieving positive outcomes for people with disabilities in 

the most cost-effective way. Nevertheless, to achieve the greatest 

efficiency and effectiveness, OMB should 

• continue to work with executive agencies that administer overlapping 

programs to determine whether program consolidation might result in 

administrative savings and more effective and efficient delivery of 

services. Executive agencies should seek any necessary statutory 

authority to consolidate programs if there would be sufficient savings 

to merit such an action.

GAO provided a draft of this report section to OMB and the nine federal 

agencies that administer the programs within the scope of this report for 

review and comment. The Departments of Education and Veterans’ 

Affairs (VA) had no comments. The Departments of Agriculture (USDA), 

Defense (DOD), Labor, Health and Human Services (HHS); the Internal 

Revenue Service; OMB; the Social Security Administration (SSA); and 

the U.S. AbilityOne Commission provided technical comments, which 

were incorporated or summarized and discussed below, as appropriate. 

Labor provided written comments. All written comments are reprinted in 

appendix IV. 

In response to GAO’s recommendations, OMB noted that, in fiscal year 

2012, the Administration’s Domestic Policy Council will conduct an 

internal review of ways to improve the effectiveness of disability programs 

through better coordination and alignment of priorities and strategies. The 

Council will work with agencies to explore how they can achieve better 

results for people with disabilities through sharing data and defining 

shared objectives, among other activities. GAO supports such efforts to 

improve coordination among programs, and looks forward to the results of 

Agency Comments 

and GAO’s Evaluation
 

Page 210 GAO-12-342SP Duplication, Overlap, and Fragmentation 

the review with respect to setting governmentwide goals for people with 

disabilities and identifying opportunities for more efficient and effective 

delivery of services to this population. 

In addition, OMB noted that the current administration has set 

governmentwide goals for employment and inclusion of people with 

disabilities in the federal government. Specifically, in 2010, the President 

issued an executive order stating that the federal government should be a 

model for the employment of people with disabilities and reaffirming a 

goal set in 2000 to hire 100,000 individuals with disabilities over 5 years.8

The President issued another executive order in 2011 that resulted in the 

Office of Personnel Management’s Government-wide Diversity and 

Inclusion Strategic Plan.9

OMB also highlighted some specific ongoing or planned efforts to improve 

employment for people with disabilities. For example, OMB noted that 

Labor issued a proposed rule to strengthen affirmative action 

requirements for federal contractors and subcontractors, and that SSA 

has set a goal of assisting 118,000 Disability Insurance and Supplemental 

Security Income (SSI) beneficiaries obtain employment in 2012 through 

the Ticket to Work program. In addition, OMB noted that the Promoting 

Readiness of Minors in SSI (PROMISE) program will involve several 

federal agencies to test interventions to improve outcomes—including 

employment outcomes—for children with disabilities and their families. 

In their comments, both Labor and HHS expressed concern that GAO 

found fragmentation and/or duplication without providing a more detailed 

explanation of its findings. GAO did not find duplication, but rather, found 

fragmentation and overlap among programs providing employment 

support for people with disabilities that suggests the need to look more 

closely at the potential for unnecessary duplication. GAO stated that 

some programs have a greater potential for duplication than others, and 

provided some examples. GAO plans to issue a more detailed report on 

fragmentation, overlap, and the potential for duplication among programs 

that support employment for people with disabilities in 2012.

Labor asserted that GAO’s findings implied that one agency or program 

could address the needs of all people with disabilities. GAO agrees with 

Labor that people with disabilities have varied needs that may not 

adequately be served by one program alone. However, GAO still 

recommends that OMB and the agencies continue to work together to 

determine whether consolidating some overlapping programs might result 

in either cost savings or address service gaps through more efficient 

delivery of services. Labor also pointed out that several of the programs 

included in the scope of GAO’s study were not created specifically to 

 

8

Exec. Order No. 13,548, 75 Fed. Reg. 45,039 (July 30, 2010). 

9

Exec. Order No. 13,583, 76 Fed. Reg. 52,847 (Aug. 23, 2011).
 

Page 211 GAO-12-342SP Duplication, Overlap, and Fragmentation 

provide employment support for people with disabilities, and that service 

inclusion and integration is consistent with disability civil rights laws. GAO 

agrees and included such programs to provide a more comprehensive 

picture of the services and supports available to help people with 

disabilities stay at work or return to work.

Four agencies—USDA, HHS, Labor, and SSA—highlighted unique 

characteristics of their programs, with respect to the actual services 

provided, program design used, and populations served. For example, 

USDA noted that the AgrAbility program is the only federally funded 

program that has developed expertise to accommodate disability among 

those working in agriculture. GAO revised the report to more clearly 

reflect program variation, as appropriate. 

Labor questioned whether servicemembers and veterans should be 

considered similar populations. While there are obvious distinctions, GAO 

included programs serving these populations in one category because 

most DOD programs in the scope of this review reported facilitating the 

transition of servicemembers into veteran status. In addition, there are a 

number of programs that serve both servicemembers and veterans, such 

as Labor’s America’s Heroes at Work program and REALifelines 

program. 

Two agencies commented on their programs’ outcomes related to 

employment. SSA pointed out that a low return-to-work rate among its 

disability beneficiaries does not necessarily raise questions about the 

efficiency and effectiveness of its disability program, and also noted that 

programs that support employment for people with disabilities have 

varying definitions of disability, which may affect the return-to-work 

objectives of any given program. In addition, USDA noted that most 

participants in its AgrAbility program were able to continue working, and 

that the program has demonstrated a high return on investment. GAO 

modified language and added some additional information to the report to 

address these points. 

Finally, Labor provided examples of coordination within and among 

agencies that GAO did not identify through its survey. GAO made 

changes to the report, as appropriate, and plans to include additional 

information on coordination among selected programs in its 2012 report. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted to be published as a separate product in 2012. 

GAO identified programs that support employment for people with 

disabilities by reviewing the Catalog of Federal Domestic Assistance and 

GAO’s prior work and consulting stakeholders. GAO included programs 

that served only people with disabilities, as well as programs that served 

How GAO Conducted 

Its Work
 

Page 212 GAO-12-342SP Duplication, Overlap, and Fragmentation 

a broader population but provided special consideration to people with 

disabilities or their employers.10 GAO did not conduct an independent 

legal analysis to identify relevant programs. GAO validated this list of 

programs with agency officials and fielded a web-based survey to these 

programs from August 2011 to October 2011. GAO used the survey to 

collect information on programs’ objectives, eligibility criteria, services 

offered, and program obligations in fiscal year 2010, among other data. 

When programs were jointly administered by two or more federal 

agencies, GAO consulted with the agencies and asked them to designate 

one official to fill out the survey for that program. GAO incorporated data 

reliability checks into the survey instrument, reviewed documentation, and 

conducted follow-up interviews, as necessary. GAO followed up with 

some survey respondents based on electronic checks of data 

submissions and other criteria. GAO determined that the data used in this 

report were sufficiently reliable for the purposes of this report. GAO also 

interviewed researchers knowledgeable about employment and disability 

issues. Appendix III lists the programs GAO identified that may have 

similar or overlapping objectives, provide similar services, or be 

fragmented across government missions. Overlap and fragmentation may 

not lead to actual duplication, and some degree of overlap and duplication 

may be justified.

Social Security Disability: Ticket to Work Participation Has Increased, but 

Additional Oversight Needed. GAO-11-324. Washington, D.C.: May 6, 

2011.

High-Risk Series: An Update. GAO-11-278. Washington, D.C.: February 

2011.

Highlights of a Forum: Actions that Could Increase Work Participation for 

Adults with Disabilities. GAO-10-812SP. Washington, D.C.: July 2010.

Federal Disability Programs: More Strategic Coordination Could Help 

Overcome Challenges to Needed Transformation. GAO-08-635. 

Washington, D.C.: May 20, 2008.

Highlights of a Forum: Modernizing Federal Disability Policy. 

GAO-07-934SP. Washington, D.C.: August 2007.

 

10Specifically, in order to be considered within GAO’s scope, agencies must have reported 

that their programs met at least one of the following criteria and provided an employmentrelated service in fiscal year 2010: (1) people with disabilities are mentioned in the 

legislation as a targeted group, (2) people are eligible for the program wholly because of a 

disability, (3) people are eligible for the program partially because of a disability, (4) 

people with disabilities are given special consideration in eligibility determinations, (5) 

people with disabilities are given priority in being served, or (6) employers of people with 

disabilities are a targeted group.

Related GAO 

Products 
 

Page 213 GAO-12-342SP Duplication, Overlap, and Fragmentation 

Veterans’ Employment and Training Service: Labor Could Improve 

Information on Reemployment Services, Outcomes, and Program Impact. 

GAO-07-594. Washington, D.C.: May 24, 2007.

Federal Disability Assistance: Wide Array of Programs Needs to Be 

Examined in Light of 21st Century Challenges. GAO-05-626. Washington, 

D.C.: June 2, 2005.

People with Disabilities: Federal Programs Could Work Together More 

Efficiently to Promote Employment. GAO-HEHS-96-126. Washington, 

D.C.: September 3, 1996.

For additional information about this area, contact Daniel Bertoni at (202) 

512-7215 or bertonid@gao.gov. Contact Information
 

Page 214 GAO-12-342SP Duplication, Overlap, and Fragmentation 

31. Science, Technology, Engineering, and 

Mathematics Education

Strategic planning is needed to better manage overlapping programs across multiple agencies.

Federal agencies obligated $3.1 billion in fiscal 2010 on Science, 

Technology, Engineering, and Mathematics (STEM) education programs. 

These programs can serve an important role both by helping to prepare 

students and teachers for careers in STEM fields and by enhancing the 

nation’s global competitiveness. In addition to the federal effort, state and 

local governments, universities and colleges, and the private sector have 

also developed programs that provide opportunities for students to pursue 

STEM education and occupations. However, research shows that despite 

this investment, the United States lacks a strong pipeline of future 

workers in STEM fields and that U.S. students continue to lag behind 

students in other highly technological nations in mathematics and science 

achievement.

Over the decades, Congress and the executive branch have continued to 

create new STEM education programs, even though there is a general lack 

of assessment of how well the programs are working. Recently, both 

Congress and the administration called for a more strategic and effective 

approach to the federal government’s investment in STEM education. The 

America COMPETES Reauthorization Act of 2010 requires the Director of 

the Office of Science and Technology Policy (OSTP) within the Executive 

Office of the President to establish a committee under the National Science 

and Technology Council (NSTC) to (1) develop a 5-year strategic plan that 

includes common measures to assess progress towards the plan’s goals, 

(2) coordinate STEM education activities and programs among respective 

federal agencies, and (3) develop an inventory of federal STEM education 

programs and identify areas of duplication among those programs.1

In fiscal year 2010, 173 of the 209 (83 percent) STEM education 

programs administered by 13 federal agencies overlapped to some 

degree with at least 1 other program in that they offered similar services 

to similar target groups in similar STEM fields to achieve similar 

objectives (see fig. below).2

 

1

Pub. L. No. 111-358, § 101 (2011). 

Federal STEM education programs are also 

2

For purposes of GAO’s engagement, we defined a federally funded STEM education 

program as a program funded in fiscal year 2010 by congressional appropriation or 

allocation that includes one or more of the following as a primary objective: (1) attracting 

and preparing students throughout their academic careers in STEM areas, (2) improving 

teacher education in STEM areas, (3) improving or expanding the capacity of K-12 

schools or postsecondary institutions to promote or foster education in STEM fields, or (4) 

conducting research to enhance the quality of STEM education provided to students.

Why This Area Is 

Important

What GAO Found
 

Page 215 GAO-12-342SP Duplication, Overlap, and Fragmentation 

fragmented across a number of agencies. The number of programs each 

of the 13 agencies administered in 2010 ranged from 3 to 46. Three 

agencies—the Department of Health and Human Services, the 

Department of Energy, and the National Science Foundation—administer 

more than half of all programs—112 of 209. These programs range from 

being narrowly focused on a specific group or field of study to offering a 

range of services to students and teachers across STEM fields. Agencies 

obligated over $3 billion to STEM education programs in fiscal year 2010. 

The National Science Foundation and the Department of Education 

programs account for over half of this funding. Almost a third of the 

programs had obligations of $1 million or less, with 5 programs having 

obligations more than $100 million each. 

Overlapping Federal STEM Education Programs

This complicated patchwork of fragmented and overlapping programs has 

largely resulted from federal efforts to both create and expand programs 

across many agencies in an effort to improve STEM education and 

increase the number of students going into STEM fields. Program officials 

reported that approximately one-third of STEM education programs 

funded in fiscal year 2010 were first funded between 2005 and 2010. 

Indeed, the creation of new programs during that time frame may have 

contributed to overlap and, ultimately, to inefficiencies in how STEM 

programs across the federal government are focused and delivered. 

Overlapping programs can lead to individuals and institutions being 

eligible for similar services in similar STEM fields offered through multiple 

programs. Without information sharing, this could lead to the same 

service being provided to the same individual or institution (see fig. 

below). Fragmentation and overlap can frustrate federal officials’ efforts to 

administer programs in a comprehensive manner, limit the ability of 

decision makers to determine which programs are most cost-effective, 

and ultimately increase program administrative costs.

Many programs provided services to similar target groups, such as K-12 

students, postsecondary students, K-12 teachers, and college faculty and 
 

Page 216 GAO-12-342SP Duplication, Overlap, and Fragmentation 

staff. The vast majority of programs (170) serve postsecondary students. 

Ninety-five programs served college faculty and staff, 75 programs served 

K-12 students, and 70 programs served K-12 teachers. In addition, many 

programs served multiple target groups. In fact, 177 programs were 

primarily intended to serve two or more target groups. In addition, as the 

figure below illustrates, many STEM education programs provide similar 

services.

Services Provided by Federal STEM Education Programs

Furthermore, it is important to compare programs’ target groups and 

academic STEM fields that are a focus of the program (a STEM field of 

focus) together to get a better picture of the potential target beneficiaries 

that could be served within a given STEM discipline. As the table below 

illustrates, many programs are designed to serve multiple target groups 

across multiple STEM fields of focus. The majority of programs served 

target groups across four or more STEM fields of focus, with only 23 

programs focusing on one specific STEM field.
 

Page 217 GAO-12-342SP Duplication, Overlap, and Fragmentation 

STEM Fields of Focus and Target Groups of Federal STEM Education Programs

Target groups 

Agricultural 

sciences Biology Chemistry

Computer 

science 

Earth 

sciences Engineering Mathematics Physics 

Social 

sciences Technology 

K-12 students 8 40 36 30 38 32 33 31 19 43 

Postsecondary 

students 

22 99 85 84 64 89 79 76 62 87 

K-12 teachers 5 36 33 25 39 26 28 29 17 38 

College faculty 

and staff 

17 49 42 43 35 47 37 36 30 50 

Source: GAO analysis of survey responses

Note: Many STEM education programs serve multiple target groups with multiple STEM fields of 

focus. The totals cited in this table do not sum to 209, the number of programs in GAO’s review. Earth 

sciences includes atmospheric and ocean sciences; social sciences includes psychology, sociology, 

anthropology, cognitive science, economics, and behavior sciences. 

However, even when programs overlap, the services they provide and the 

populations they serve may differ in meaningful ways and would therefore 

not necessarily be duplicative. There may be important differences 

between the specific STEM field of focus and the program’s stated goals. 

For example, there were 31 programs that provided scholarships or 

fellowships to doctoral students in the field of physics. However, one 

program’s goal was to increase environmental literacy related to estuaries 

and coastal watersheds while another program focused on supporting 

education in nuclear science, engineering, and related trades. In addition, 

programs may be primarily intended to serve different specific populations 

within a given target group. Indeed, of the 34 programs providing services 

to K-12 students in the field of technology, 10 are primarily intended to 

serve specific underrepresented, minority, or disadvantaged groups and 2 

are limited geographically to individual cities or universities. As NSTC 

develops its 5-year strategic plan, it will need to conduct more analysis of 

each program to avoid potential duplication and ensure that the federal 

investment in these programs advances the governmentwide goals 

expressed in the strategic plan.

In addition to the fragmented and overlapping nature of federal STEM 

education programs, little is known about the effectiveness of these 

programs. Since 2005, when GAO first reported on this issue, GAO found 

that the majority of programs have not conducted comprehensive 

evaluations of how well their programs are working. Agency and program 

officials would benefit from guidance and information sharing within and 

across agencies about what is working and how to best evaluate 

programs. This could not only help to improve individual program 

performance, but could also inform agency- and governmentwide 

decisions about which programs should continue to be funded. Without 

an understanding of what is working in some programs, it will be difficult 

to develop a clear strategy for how to spend limited federal funds.

Finally, although NSTC is in the process of developing a governmentwide 

strategic plan for STEM education consistent with the requirements of the 

America COMPETES Reauthorization Act of 2010, GAO found that 

agencies in its 2005 review do not use outcome measures for STEM 
 

Page 218 GAO-12-342SP Duplication, Overlap, and Fragmentation 

programs in a way that is clearly reflected in their own performance plans 

and performance reports—key strategic planning documents.3 The 

absence of clear links between the programs and agencies’ planning 

documents may hinder decision makers’ ability to assess how agencies’ 

STEM efforts contribute to agencywide performance goals and the overall 

federal STEM effort. Moving forward, the GPRA Modernization Act of 

2010 requires agencies to identify program activities and other activities 

that contribute to each performance goal, and as agencies implement this 

provision, more information about STEM education efforts in performance 

plans and reports can be expected. In addition, NSTC’s ongoing strategic 

planning efforts provide an opportunity to develop guidance on how to 

incorporate STEM- and program-specific education goals and measures 

in agencies’ performance planning and reporting process.

GAO recommended in January 2012 that the Director of OSTP direct 

NSTC to take several actions related to STEM education programs and 

related activities.

To ensure the federal government strategically invests limited funds in an 

efficient and effective manner that achieves the greatest impact in 

developing a pipeline of future workers in STEM fields, the Director of 

OSTP should direct NSTC to

• work with agencies, through its strategic planning process to identify 

programs that might be candidates for consolidation or elimination. 

Specifically, this could be achieved through an analysis that includes 

information on program overlap, similar to the analysis conducted by 

GAO in this report, and information on program effectiveness. As part 

of this effort, OSTP should work with agency officials to identify and 

report any changes in statutory authority necessary to execute each 

specific program consolidation identified by NSTC’s strategic plan.

To ensure NSTC’s strategic planning process enhances the federal 

government’s ability to assess what works and the process for identifying 

potential program consolidation includes information on program 

effectiveness, the Director of OSTP should direct NSTC to

• develop guidance to help agencies determine the types of evaluations 

that may be feasible and appropriate for different types of STEM 

 

3

These strategic planning documents were required under the Government Performance 

and Results Act (GPRA) and continue to be required under the GPRA Modernization Act 

of 2010. We did not assess agencies’ plans and reports for compliance with GPRA and 

the GPRA Modernization Act of 2010 requirements, and our findings that some agencies 

did not include STEM education programs in their plans and reports should not be read to 

suggest that we identified instances of noncompliance. For example, we did not assess 

whether a particular STEM education program is a “program activity” as that term is 

defined by GPRA for purposes of determining what STEM education programs are 

required to be covered in agency performance plans and reports. 31 U.S.C. § 1115(h)(11). 

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 219 GAO-12-342SP Duplication, Overlap, and Fragmentation 

education programs and develop a mechanism for sharing this 

information across agencies. This could include guidance and sharing 

of information that outlines practices for evaluating similar types of 

programs.

To ensure agencies’ efforts are better aligned to governmentwide STEM 

education goals and federal resources are concentrated on advancing 

those goals, the Director of OSTP should direct NSTC to

• develop guidance for how agencies can better incorporate each 

agency’s STEM education efforts and the goals from NSTC’s 5-year 

STEM education strategic plan into each agency’s own performance 

plans and reports.

To improve transparency and strengthen accountability of NSTC’s 

strategic planning and coordination efforts, the Director of OSTP should 

direct NSTC to

• develop a framework for how agencies will be monitored to ensure 

that they are collecting and reporting on NSTC strategic plan goals. 

This framework should include alternatives for a sustained focus on 

monitoring coordination of STEM education programs if the NSTC 

Committee on STEM terminates in 2015 as called for in its charter.

GAO provided a draft of its January 2012 report to OSTP and the Office 

of Management and Budget (OMB) for review and comment. OSTP 

provided technical comments, which were incorporated as appropriate. 

OMB stated it had no concerns with GAO’s report. 

GAO also provided a draft of this report section to OMB and OSTP for 

review and comment. OMB provided technical comments, which were 

incorporated as appropriate. OMB stated that GAO’s four 

recommendations are critical to improving the provision of STEM 

education across the federal government. OSTP provided written 

comments and noted that its analysis of overlap and duplication in STEM 

education programs identified no duplicative programs. In cases where it 

identified overlapping programs it found that some program 

characteristics differed. As an illustration, OSTP explained that there 

could be two STEM education programs, one that worked with inner city 

children in New York City and another with rural children in North Dakota. 

GAO notes that while it may be important to serve both of these 

populations, it is not clear that two separate administrative structures are 

necessary to ensure both populations are served. OSTP agreed to 

consider program consolidation or elimination as part of its strategic 

planning process, but also said that it would consider other approaches 

such as strategic alignment of program goals, joint solicitations, improved 

program design and execution, and memoranda of understanding to 

increase efficiency and effectiveness of federal STEM Education 

spending. OSTP stated that they will address GAO’s recommendations in 

the NSTC 5-Year Federal STEM Education Strategic Plan, which will be 

Agency Comments 

and GAO’s Evaluation
 

Page 220 GAO-12-342SP Duplication, Overlap, and Fragmentation 

released in spring 2012. OMB added that joint administration of programs 

across agencies is also an effective measure at eliminating duplication 

and overlap and guaranteeing that the best resources are devoted to 

programming. As part of GAO’s routine audit work, GAO will track agency

actions to address these recommendations and report to Congress. All 

written comments are reprinted in appendix IV.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted. GAO reviewed relevant federal laws, regulations, 

and relevant literature and past reports. GAO interviewed officials from 

OSTP and OMB, and officials from other federal agencies that administer 

STEM education programs. In addition, to gather information on federal 

STEM education programs and to assess the level of fragmentation, 

overlap, and potential duplication, GAO surveyed over 200 programs 

across 13 agencies that met GAO’s definition of a STEM education 

program, asking questions about program objectives, target populations, 

services provided, interagency coordination, outcome measures and 

evaluations, and funding. Furthermore, to gather information on program 

effectiveness, GAO reviewed evaluations provided by program officials, 

as well as agencies’ annual performance plans and reports. Appendix III 

lists the programs GAO identified that may have similar or overlapping 

objectives, provide similar services or be fragmented across government 

missions. Overlap and fragmentation may not necessarily lead to actual 

duplication, and some degree of overlap and duplication may be justified.

Science, Technology, Engineering, and Mathematics Education: Strategic 

Planning Needed to Better Manage Overlapping Programs across 

Multiple Agencies. GAO-12-108. Washington, D.C.: January 20, 2012.

Science, Technology, Engineering, and Mathematics Education: Survey 

of Federal Programs (GAO-12-110SP, January 2012), an E-supplement 

to GAO-12-108. GAO-12-110SP. Washington, D.C.: January 20, 2012.

Higher Education: Federal Science, Technology, Engineering, and 

Mathematics Programs and Related Trends. GAO-06-114. Washington, 

D.C.: October 12, 2005.

For additional information about this area, contact George A. Scott at 

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

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 221 GAO-12-342SP Duplication, Overlap, and Fragmentation 

32. Financial Literacy

Overlap among financial literacy activities makes coordination and clarification of roles and responsibilities 

essential, and suggests potential benefits of consolidation.

Financial literacy plays an important role in helping to ensure the financial 

health and stability of individuals and families, and economic changes in 

recent years have further highlighted the need to empower all Americans 

to make informed financial decisions. As GAO reported in March 2011, 

federal financial literacy activities are fragmented among multiple federal 

agencies, which increases the risk of inefficient, uncoordinated, or 

redundant use of resources. This year’s report provides updated 

information on coordination activities, as well as additional information on 

areas of overlap and on the evolving role of the new Bureau of Consumer 

Financial Protection.

Federal financial literacy programs and resources are spread widely 

among many different federal agencies. A 2009 survey conducted by the 

Departments of the Treasury and Education, which GAO cited in its 

March 2011 report, asked federal agencies to self-identify their financial 

literacy efforts, and 56 programs related to financial literacy were reported 

by 20 federal agencies. However, GAO’s subsequent analysis found that 

there was a high degree of inconsistency in how different agencies 

defined financial literacy programs and whether they counted related 

activities as one or multiple programs.

Using a more consistent set of criteria, GAO has identified 15 significant 

financial literacy programs or activities among 13 federal agencies. These 

efforts are defined as relatively comprehensive in scope or scale and 

include financial literacy as a key objective rather than a tangential goal.1

 

1

According to GAO’s criteria, significant financial literacy and education activities and 

programs were those whose primary goals were to educate, inform, or encourage 

individuals to make informed judgments and take effective actions regarding the current 

and future use and management of money. However, GAO excluded (1) those for which 

financial literacy was only a minimal component; (2) programs that provided financial 

information related to the administration of the program itself (e.g., information on applying 

for student financial aid or evaluating Medicare choices) rather than information aimed at 

increasing the beneficiaries’ financial literacy and comprehension more generally; (3) 

activities or programs that were purely internal to the agency, such as information 

provided to agency employees on their employment and retirement benefits; and (4) 

activities that represented individualized services or advice (e.g. assistance with tax 

preparation or development of a debt management plan). For the purposes of this report, 

GAO counted as a federal agency NeighborWorks® America, a government-chartered, 

nonprofit corporation that receives federal funding for housing counseling, including 

through an annual appropriation from Congress.

As seen in appendix III, the estimated cost for 13 of these 15 financial 

literacy programs or activities was about $30.7 million in fiscal year 2010; 

GAO is still in the process of developing cost estimates for the activities of 

Why This Area Is 

Important

What GAO Found
 

Page 222 GAO-12-342SP Duplication, Overlap, and Fragmentation 

the Department of Defense (DOD) and for the Bureau of Consumer 

Financial Protection, which was not created until July 2010.

In addition, federal agencies spent about $136.6 million in fiscal year 

2010 on housing counseling. GAO has separated out costs for housing 

counseling programs because education is only a limited aspect of most 

housing counseling, which often consists largely of one-on-one service 

and assistance to address individual situations. For example, foreclosure 

mitigation counseling typically focuses on helping financially distressed 

homeowners avoid foreclosure by working with lenders to remedy 

mortgage delinquency.

Having multiple federal agencies involved in financial literacy efforts can 

have certain advantages. In particular, agencies may have deep and 

long-standing expertise and experience addressing specific issue areas 

or serving specific populations. For example, the Securities and 

Exchange Commission has efforts in place to protect securities investors 

from fraudulent schemes, while the Department of Housing and Urban 

Development (HUD) oversees most, but not all, federally supported 

housing counseling. Moreover, DOD may be the agency most able to 

efficiently and effectively deliver financial literacy programs and products 

to servicemembers and their families. However, as GAO stated in a June 

2011 report, relatively few evidence-based evaluations of financial literacy 

programs have been conducted, limiting what is known about which 

specific methods and strategies—and which federal financial literacy 

activities—are most effective.

In addition, fragmentation increases the risk of inefficiency and 

redundancy and highlights the need for strong coordination, or potential 

consolidation, of these efforts. In general, GAO has found that the 

coordination and collaboration among federal agencies with regard to 

financial literacy has improved substantially in recent years. The 

multiagency Financial Literacy and Education Commission (Commission) 

was created by Congress in 2003 and charged, among other things, with 

developing a national strategy to promote financial literacy and education, 

coordinating federal efforts, and identifying areas of overlap and 

duplication. Among other things, the Commission in concert with the 

Department of the Treasury, which provides its primary staff support, has 

served as a central clearinghouse for federal financial literacy 

resources—for example, it created a centralized federal website and has 

an ongoing effort to develop a catalog of federal research on financial 

literacy. The Commission’s 2011 national strategy identified five action 

areas, one of which was to further emphasize the role of the Commission 

in coordination. The strategy’s accompanying Implementation Plan lays 

out plans to coordinate communication among federal agencies, improve 

strategic partnerships, and develop channels of communication with other 

entities, including the President’s Advisory Council on Financial Capability 

and the National Financial Education Network of State and Local 

Governments. The Commission’s success in implementing these 

elements of the National Strategy is key given the inherently challenging 

task of coordinating the work of the Commission’s many member 
 

Page 223 GAO-12-342SP Duplication, Overlap, and Fragmentation 

agencies—each of which has its own set of interests, resources, and 

constituencies. Further, the addition of the Bureau of Consumer Financial 

Protection, whose director serves as the Vice Chair of the Commission, 

adds a new player to the mix that will influence the Commission’s 

success.

GAO’s review thus far shows that there is little evidence of duplication 

among existing federal financial literacy activities—that is, cases where 

two or more agencies or programs are engaging in the same activities 

and providing the same services to the same beneficiaries. However, 

GAO did identify cases in which there is overlap—multiple agencies or 

programs with similar goals and activities—that raise questions about the 

efficiency of some federal financial literacy and housing counseling 

efforts. For example, four federal agencies and one governmentchartered nonprofit corporation provide various forms of housing 

counseling to consumers—DOD, HUD, the Department of Veterans 

Affairs (VA), the Department of the Treasury, and NeighborWorks 

America. 

• HUD obligated about $65.4 million in fiscal year 2010 for certifying 

and overseeing housing counseling agencies, training housing 

counselors, and providing counseling agencies with competitive 

grants. The Dodd-Frank Wall Street Reform and Consumer Protection 

Act (Dodd-Frank Act) required HUD to establish an Office of Housing 

Counseling, although as of October 2011, the office had not yet been 

established, in part due to budget constraints. HUD also has 15 other 

active programs that allow some portion of their funding to be used for 

housing counseling or have some housing counseling component.2

• The federally chartered nonprofit corporation NeighborWorks America 

received an appropriation from Congress in fiscal year 2010 that 

included $65 million for the National Foreclosure Mitigation 

Counseling Program; the organization also spent $2 million of its 

appropriated funds for other housing counseling activities.

• VA has loan counselors that address housing issues in its Regional 

Loan Centers to help veterans facing foreclosure or other financial 

problems. VA often recommends HUD-approved housing counseling 

to veterans who are seeking VA-guaranteed loans but does not 

require it.

 

2

These programs are the Federal Housing Administration’s Home Equity Conversion 

Mortgage, Community Development Block Grant, HOME Investment Partnership 

Program, Second Mortgage Assistance for First-Time Homebuyers, Rural Housing 

Stability Grant Program, Public Housing Operating Fund, Section 8 Tenant-Based Rental 

Assistance Homeownership Option, Demolition and Disposition of Public Housing, Family 

Self-Sufficiency, Public Housing Resident Homeownership Programs, Conversion of 

Distressed Public Housing to Tenant-Based Assistance, Low Income Housing 

Preservation and Resident Homeownership Act Prepayment Options, Native American 

Housing Assistance and Self Determination Act Housing Block Grants, Native Hawaiian 

Housing Block Grants, and Section 8 Rental Assistance.
 

Page 224 GAO-12-342SP Duplication, Overlap, and Fragmentation 

• DOD has a foreclosure counseling program for servicemembers 

returning from active duty abroad. This program is administered 

through the Military OneSource and the Military and Family Life 

Consultant Program.

• The Department of the Treasury’s Financial Literacy and Education 

Counseling Pilot Program, created by the Housing and Economic 

Recovery Act of 2008, provided $4.15 million in grants in fiscal year 

2010 for financial literacy counseling to prospective homebuyers.3

Another example of overlap lies in the financial literacy responsibilities of 

the Bureau of Consumer Financial Protection, created by the Dodd-Frank 

Act. The act established within the bureau an Office of Financial 

Education and charged this office with developing and implementing a 

strategy to improve financial literacy through activities including 

opportunities for consumers to access, among other things, financial 

counseling; information to assist consumers with understanding credit 

products, histories, and scores; information about saving and borrowing 

tools; and assistance in developing long-term savings strategies. This 

office presents an opportunity to further promote awareness, coordinate 

efforts, and fill gaps related to financial literacy. At the same time, the 

duties this office is charged with fulfilling are in some ways similar to 

those of a separate Office of Financial Education and Financial Access 

within the Department of the Treasury, a small office that also seeks to 

broadly improve Americans’ financial literacy. In addition, the Dodd-Frank 

Act charges the Bureau of Consumer Financial Protection with developing 

and implementing a strategy on improving the financial literacy of 

consumers, even though the multiagency Financial Literacy and 

Education Commission already has its own statutory mandate to develop, 

and update as necessary, a national strategy for financial literacy. As the 

bureau has been staffing up and planning its financial education activities, 

it has been in regular communication with the Department of the Treasury 

and with other members of the Financial Literacy and Education 

Commission, and agency staff say they are seeking to coordinate their 

respective roles and activities.

In addition, the Dodd-Frank Act created within the Bureau of Consumer 

Financial Protection several offices that are charged by statute with duties 

that are in some ways similar to those of other federal agencies. For 

instance, the act created an Office of Service Member Affairs, which is 

responsible for developing and implementing initiatives for 

servicemembers and their families intended to educate and empower 

them to make better informed decisions regarding consumer financial 

products and services; monitoring complaints by service members and 

their families; and coordinating with federal and state agencies regarding 

 

3

The Financial Literacy and Education Counseling Pilot Program was appropriated $2 

million in fiscal year 2009 and $4.15 million in fiscal year 2010; the program was not 

appropriated funds in fiscal years 2011 and 2012.
 

Page 225 GAO-12-342SP Duplication, Overlap, and Fragmentation 

consumer protection measures relating to consumer financial products 

and services offered to, or used by, service members and their families. 

These activities potentially overlap with those of DOD’s Financial 

Readiness Campaign, in which Personal Financial Managers on military 

bases provide financial educational programs, partnerships, counseling, 

legal protections, and other resources designed to help servicemembers 

and their families reach financial goals such as reducing debt, setting up

a spending plan, saving for college, addressing consumer protection 

matters, and many others. Staff from the Bureau of Consumer Financial 

Protection and DOD told GAO they are working closely to coordinate their 

efforts.

The Dodd-Frank Act also creates within the bureau an Office of Financial 

Protection for Older Americans, which is charged with helping seniors 

recognize warning signs of unfair, deceptive, or abusive practices and 

protect themselves from such practices; providing one-on-one financial 

counseling on issues including long-term savings and later-life economic 

security; and monitoring the legitimacy of certifications of financial 

advisers who advise seniors. Potential overlap exists with the Federal 

Trade Commission, which also plays a role in helping seniors avoid unfair 

and deceptive practices. Further, the Department of Labor and the Social 

Security Administration both have initiatives in place to help consumers 

plan for retirement, and the Securities and Exchange Commission has 

recently initiated efforts to address concerns about the designations and 

certifications used by financial advisers.4 Officials at the Bureau of 

Consumer Financial Protection told GAO that they have been discussing 

and coordinating their financial literacy roles and activities with those of 

other federal agencies to avoid duplication of effort.

GAO expects to recommend that Congress may wish to consider

• requiring federal agencies to evaluate the effectiveness of their 

financial literacy efforts and, if appropriate, to identify options for 

consolidating such efforts. Federal agencies could potentially make 

the most of scarce resources by consolidating financial literacy efforts 

into the activities and agencies that are most effective. In addition to 

improving effectiveness, such consolidation could have potential 

monetary savings, an issue GAO is examining as part of ongoing 

work; and 

 

4

The Federal Trade Commission’s Division of Consumer and Business Education plans, 

develops, and implements various web-based financial literacy activities that focus on 

consumer protection, some of which has focused on scams targeted at seniors. The 

Department of Labor’s Retirement Savings Education Campaign seeks to increase 

retirement savings through workplace plans so that employees are better prepared for a 

secure retirement. The Social Security Administration’s Special Initiative to Encourage 

Savings focuses on saving and retirement issues and informing the public about SSA’s 

programs related to old-age, survivors, and disability insurance system.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 226 GAO-12-342SP Duplication, Overlap, and Fragmentation 

• monitoring the implementation of the Bureau of Consumer Financial 

Protection’s efforts. As the bureau’s financial literacy activities evolve 

and are implemented, it will be important to evaluate how those efforts 

are working and make appropriate adjustments that might promote 

greater efficiency and effectiveness.

The Bureau of Consumer Financial Protection should

• delineate roles and responsibilities related to its new offices of 

Financial Education, Service Member Affairs, and Financial Protection 

for Older Americans. As these offices form more fully, they will need 

to continue their efforts to work with federal agencies that have 

overlapping responsibilities so as to carefully delineate their 

respective activities and avoid duplication.

GAO provided a draft of this report section to the Bureau of Consumer 

Financial Protection, the Department of the Treasury, and the Department 

of Housing and Urban Development for review and comment. The Bureau 

of Consumer Financial Protection and the Department of the Treasury

provided written comments. The Department of Housing and Urban 

Development provided technical comments, which were incorporated as 

appropriate. GAO also provided selected portions of the draft report 

section to those agencies listed in appendix III for their technical review, 

and GAO incorporated those technical comments as appropriate. All 

written comments are reprinted in appendix IV. 

The Department of the Treasury said that it agreed that federal agencies 

should evaluate the effectiveness of their financial literacy efforts and, if 

appropriate, identify options for consolidating such efforts. However, the 

department noted that it would be necessary for funding to be 

appropriated for such evaluation. In addition, the department said it 

believed that continued and enhanced coordination among agencies may 

lead to greater effectiveness, in some cases, than consolidation. The 

Bureau of Consumer Financial Protection’s written response highlighted 

the bureau’s efforts to coordinate its activities, avoid duplication with other 

agencies, and promote the evaluation of financial literacy efforts.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section and additional work 

GAO conducted. GAO collected information on the purpose, 

beneficiaries, costs, and subject matter of federal financial literacy 

programs and activities through interviews with staff of federal agencies 

and through budget justifications, strategic plans, and other documents. 

In some cases, costs provided are estimates because financial literacy 

activities are not organized as separate budget line items or cost centers 

within an agency. GAO also reviewed the Financial Literacy and 

Education Commission’s 2011 national strategy and implementation plan 

and memorandums of understanding and other documents related to 

collaborations among federal agencies. Appendix III lists the programs 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 227 GAO-12-342SP Duplication, Overlap, and Fragmentation 

GAO identified that may have similar or overlapping objectives, provide 

similar services or be fragmented across government missions. Overlap 

and fragmentation may not necessarily lead to actual duplication, and 

some degree of overlap and duplication may be justified.

Highlights of a Forum: Financial Literacy: Strengthening Partnerships in 

Challenging Times. GAO-12-299SP. Washington, D.C.: February 9, 

2012.

Financial Literacy: A Federal Certification Process for Providers Would 

Pose Challenges. GAO-11-614. Washington, D.C.: June 28, 2011.

Financial Literacy: The Federal Government’s Role in Empowering 

Americans to Make Sound Financial Choices. GAO-11-540T. 

Washington, D.C.: April 12, 2011.

Financial Literacy and Education Commission: Progress Made in 

Fostering Partnerships, but National Strategy Remains Largely 

Descriptive Rather Than Strategic. GAO-09-638T. Washington, D.C.:

April 29, 2009.

Financial Literacy and Education Commission: Further Progress Needed 

to Ensure an Effective National Strategy. GAO-07-100. Washington, D.C.: 

December 4, 2006.

Highlights of a GAO Forum: The Federal Government’s Role in Improving 

Financial Literacy. GAO-05-93SP. Washington, D.C.: November 15, 2004.

For additional information about this area, contact Alicia Puente Cackley 

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

Related GAO 

Products 

Contact Information
 

Page 228 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Section II: Areas in Which GAO Has 

Identified Other Cost Savings or Revenue 

Enhancement Opportunities 

This section summarizes 19 additional opportunities for agencies or 

Congress to consider taking action that could either reduce the cost of 

government operations or enhance revenue collections for the Treasury.
 

Page 229 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

33. Air Force Food Service

The Air Force has opportunities to achieve millions of dollars in cost savings annually by reviewing and 

renegotiating food service contracts, where appropriate, to better align with the needs of installations.

The Air Force has 149 main dining facilities at installations nationwide.1

As GAO reported in July 2011, the Air Force recently undertook an 

initiative to improve food service at six pilot installations, with intentions to 

eventually expand this initiative to more Air Force installations in the 

United States over the next 5 years. This Food Transformation Initiative is 

primarily designed to improve the quality, variety, and availability of food. 

In the process, however, according to Air Force officials, the first group of 

pilot installations achieved cost savings compared to their previous 

contracts while increasing hours in the dining facilities and serving an 

additional 500,000 meals per year.

According to Air Force officials, most installations have their own 

individual contracts for food service, ranging from full-service contracts, 

providing cooking, cashiering, and cleaning services at Air Force dining 

facilities, to contracts that cover only basic cleaning services. The cost for 

these contracts, according to Air Force officials, ranges from $725,000 to 

$21.4 million per year, with a total cost of approximately $150 million per 

year for all Air Force installations. GAO has previously reported that,

when contracting for services, properly defined requirements are a 

prerequisite to obtaining value for the department.

The Air Force has opportunities to reduce its overall food service costs at 

installations by reviewing food service contracts and adjusting them, when 

appropriate, to better meet the needs of the installation, including aligning 

labor needs with the actual number of meals served by the dining facilities. 

The Food Transformation Initiative contract was awarded to Aramark, a 

large company experienced in food service. The new contractor reviewed 

and adjusted staffing levels for contractor staff at the main dining facilities 

to better meet the needs of the facilities. As GAO reported in July 2011, the 

Air Force and Aramark anticipated reducing labor hours at five of the six 

Food Transformation Initiative pilot locations and using the savings to offset 

the costs of the Food Transformation Initiative contract. According to Air 

Force officials, savings for fiscal year 2010 were approximately 8 percent 

compared to the cost of the previous contracts. GAO compared the 

estimated amount of food service labor for which the Air Force contracted 

at the six pilot installations prior to the implementation of the Food 

Transformation Initiative to Aramark’s projected work schedules under the 

 

1

The Air Force calls its main dining facilities “mission essential feeding facilities.” GAO 

uses the term main dining facilities to refer to these appropriated fund dining facilities in 

this report. 

Why This Area Is 

Important

What GAO Found 
 

Page 230 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

initiative and found that, even with expanded hours of operation and 

anticipated increases in the number of meals served, Aramark reduced the 

total number of labor hours at five of the six pilot installations by 53 percent. 

For example, at Travis Air Force Base, the number of labor hours for the 

mess attendant contract decreased by more than half—from approximately 

2,042 hours per week to 920 hours per week. At Elmendorf Air Force Base, 

labor hours decreased from approximately 1,350 hours per week to 588 

hours per week. The table below shows the change in the number of labor 

hours at all six pilot locations.

Comparison of Labor Hours under Previous Contract to Labor Hours under the 

Food Transformation Initiative Contract

Air Force base

Estimated weekly labor hours 

under the previous contract

Estimated weekly labor hours 

under the new contract

Elmendorf 1,350 588

Fairchild 979 476

Little Rock 1,548 303

MacDill 1,201 1,063

Patrick 1,218 1,349

Travis 2,042 920

Total 8,338 4,699

Source: GAO analysis of Air Force data.

Patrick Air Force Base was the only pilot base where the labor hours 

were not reduced and the only one of the pilot installations where the 

previous food service contract had recently been audited. The results of 

the audit, conducted by the Air Force Audit Agency in 2009, showed that 

the food service personnel did not align with the contract workload 

estimates with actual meals served. Specifically, meal counts were 

overstated, resulting in the installation paying more for contracted food 

services than necessary. As a result of this audit, in October 2009, Patrick 

Air Force Base renegotiated its workload estimates and pay rates, 

resulting in savings of approximately $77,000 annually.

Although it is unclear whether the opportunity for savings at the pilot 

installations is representative of the savings that could be realized by 

other installations, the potential exists for other Air Force installations that 

rely on contracts to meet their food service needs to achieve similar 

financial benefits. Prior to the implementation of the Food Transformation 

Initiative, the Air Force did not closely monitor the number of labor hours 

required to provide food services. Air Force officials told GAO that they 

did not realize how poorly their food service contracts were structured, in 

that these contracts might not be matched to the labor needs of the 

installation.
 

Page 231 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

The Air Force has opportunities to significantly reduce its food service 

costs at Air Force installations that are not part of the Food 

Transformation Initiative pilot.2

• monitor the actions taken by the Air Force Major Commands in 

response to the direction to review food service contracts, and take 

actions, as appropriate, to ensure that cost-savings measures are 

implemented.

During GAO’s review of the Air Force’s 

Food Transformation Initiative, GAO discussed this potential opportunity 

for savings with Air Force officials. As a result, the Air Force issued a 

memorandum to the Major Commands directing a review of existing food 

service contracts to determine if the contracts meet current mission 

needs. For example, the memorandum indicates that special attention 

must be given to whether the food service contract workload estimates 

were properly aligned with the actual number of meals served. GAO 

believes that this is a good first step toward addressing this issue. GAO 

recommended in July 2011 that the Secretary of the Air Force should

GAO provided a draft of its July 2011 report to the Department of Defense 

for review and comment. The Department of Defense agreed with this 

recommendation and stated that the Commander of the Air Force 

Services Agency requested that each Air Force Major Command task its 

bases to conduct a 100 percent review of existing food service to 

determine if their current contract workload estimates meet current 

mission needs or if the contracts require modifications. According to Air 

Force officials, eight installations have recently reviewed and renegotiated 

their food service contracts for a total savings of over $2.5 million per 

year. Further, Air Force officials told GAO that the Air Force continues to 

review contracts for additional savings opportunities. The Department of 

Defense further noted that it intends to share the results of the Air Force’s 

review of its food service labor costs to achieve cost savings with the 

other services, where similar reviews could result in substantial financial 

benefits. GAO agrees that the other services should similarly consider 

reviewing their food service contracts for potential cost savings where 

appropriate. As part of its routine audit work, GAO will track the extent to 

which progress has been made to address the identified action and report 

to Congress.

 

2

The National Defense Authorization Act for Fiscal Year 2012 contains a provision 

requiring the Secretary of the Air Force to submit certain information regarding the Food 

Transformation Initiative prior to further implementation. See Pub. L. No. 112-81, § 352 

(2011). The report may provide an opportunity to evaluate the opportunities for reducing 

food service costs under the initiative.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 232 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

The information contained in this analysis is based on findings from the 

product listed in the related GAO products section as well as additional 

work GAO conducted. GAO obtained documentation from the pilot 

installations regarding labor hours under the previous contracts, including 

memoranda showing how the contract prices were negotiated and 

contractor price proposals that estimated the number of labor hours for 

these contracts. Although these documents do not contain the precise 

number of labor hours for the main dining facilities, they provided the best

estimates of labor costs available. GAO reviewed this information from 

the Air Force about the amount of labor included in previous food service 

contracts at the six pilot locations and compared this to information from 

the Air Force and Aramark presented in projected work schedules for the 

Food Transformation Initiative contract. Further, GAO talked with Air 

Force officials about opportunities for reducing food service costs outside 

of the Food Transformation Initiative. Finally, GAO spoke with Air Force 

officials about cost savings achieved from reviewing food service 

contracts.

Defense Management: Actions Needed to Improve Management of Air 

Force’s Food Transformation Initiative. GAO-11-676. Washington, D.C.: 

July 26, 2011.

For additional information about this area, contact Brian Lepore at (202) 

512-4523 or leporeb@gao.gov. 

How GAO Conducted 

Its Work

Related GAO Product

Contact Information
 

Page 233 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

34. Defense Headquarters

The Department of Defense should review and identify further opportunities for consolidating or reducing the 

size of headquarters organizations.

In 2010, the Secretary of Defense expressed concerns about the 

dramatic growth in Department of Defense’s (DOD) headquarters and 

support organizations that had occurred since 2001, including increases 

in spending, staff, numbers of senior executives, and proliferation of 

management layers. DOD has multiple layers of headquarters 

management with complex, overlapping relationships. Such layers 

include, but are not limited to, the Office of the Secretary of Defense, the 

Joint Staff, and portions of the military departments, defense agencies, 

and DOD field activities. In DOD Instruction 5100.73, DOD defines those 

headquarters whose primary mission is to manage or command the 

programs and operations of DOD and its components, and their major 

military units, organizations, or agencies as major DOD headquarters 

activities.1 Since the mid-1980s, Congress has enacted statutory limits on 

the number of major DOD headquarters activity personnel, to include the 

Office of the Secretary of Defense; the headquarters of the combatant 

commands; the Office of the Secretary of the Army and the Army Staff; 

the Office of the Secretary of the Air Force and the Air Staff; the Office of 

the Secretary of the Navy, the Office of the Chief of Naval Operations, 

and the Headquarters, Marine Corps; and the headquarters of the 

defense agencies and DOD field activities.2

In 2010, the Secretary of Defense directed DOD to undertake a 

departmentwide initiative to assess how the department is staffed, 

organized, and operated, with the goal of reducing excess overhead costs 

and reinvesting these savings toward sustainment of DOD’s current force 

structure and modernizing its weapons portfolio. This effort identified 

efficiency initiatives totaling about $178 billion in projected savings across 

the military departments and other DOD components from fiscal year 

2012 through fiscal year 2016, about $24.1 billion of which is estimated to 

be achieved in fiscal year 2012. DOD’s efficiency initiatives included a 

broad range of efforts, such as holding the civilian workforce at fiscal year 

In addition, Congress has 

enacted various reporting requirements related to major DOD 

headquarters activity personnel.

 

1

Department of Defense Instruction 5100.73, Major DOD Headquarters Activities (Dec. 1, 

2007).

2

Applicable limits to major DOD headquarters personnel are included in sections 143, 

194, 3014, 5014, and 8014 of Title 10 of the U.S. Code. In some circumstances, statutory 

waivers, exceptions, exemptions and authorities to adjust those limits may apply. For 

example, acquisition personnel hired under an expedited hiring authority are exempt from 

the baseline personnel limitations, established under the previously mentioned sections of 

Title 10. 

Why This Area Is 

Important
 

Page 234 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

2010 levels; reducing the numbers of senior leaders, both officer and 

civilian; and reducing reliance on service support contractors. Some 

headquarters were planned to be closed and their missions and functions 

absorbed into other organizations, while others were reorganized. More 

recently, in January 2012, the administration released strategic guidance 

to guide defense priorities and spending over the coming decade. It lays 

out several principles to guide the development of DOD’s force structure, 

such as reducing DOD’s cost of doing business by finding further 

efficiencies in headquarters and other overhead.

Based on ongoing work for a report that GAO plans to issue in 2012, 

GAO found that DOD has taken some steps to examine its headquarters 

resources for efficiencies, but additional opportunities for cost savings 

may exist. For purposes of the Secretary of Defense’s efficiency initiative, 

DOD components, including the military departments, were asked to 

focus, in particular, on headquarters and administrative functions, support 

activities, and other overhead in their portfolios. DOD’s fiscal year 2012 

budget request included several initiatives related to headquarters 

organizations or personnel. Two organizations, the Joint Forces 

Command and Business Transformation Agency, were disestablished 

and some of their functions were absorbed into other organizations. DOD 

estimated that closing these two organizations would save approximately 

$2.2 billion through fiscal year 2016.

Other headquarters-related efficiency initiatives that GAO reviewed 

generally fell into two categories: (1) consolidating or eliminating 

organizations based on geographic proximity or span of control, and (2) 

centralizing overlapping functions and services.3

The DOD efficiencies that GAO reviewed to reduce headquarters 

resources are expected by DOD to save about $2.9 billion through fiscal 

year 2016, less than 2 percent of the $178 billion in savings DOD 

For example, the Navy 

merged the staff of the U.S. Fleet Forces Command and the U.S. 2nd 

Fleet. The missions of the two organizations were found to have 

converged over time, and the Navy decided that an integrated staff could 

better adapt to changing missions than two separate staffs and doing so 

would have the added benefit of eliminating redundant personnel. The 

result was the elimination of 344 military personnel for an expected 

cumulative savings of $100.8 million by fiscal year 2016. In another 

example, the Air Force is centralizing installation support functions, such 

as civil engineering, environmental quality and planning programs, real 

property programs, and family support services, among others, at field 

operating agencies or Air Force headquarters, eliminating 354 positions 

for an expected cumulative savings of $148.1 million by fiscal year 2016.

 

3

Span of control refers to the number of subordinates or activities under the control of a 

single commander.

What GAO Found
 

Page 235 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

projected departmentwide. In January 2012, DOD announced it had 

found about $60 billion in additional efficiencies and overhead savings 

over fiscal years 2013 to 2017, but did not indicate what portion of these 

savings were specific to headquarters. GAO’s work indicates that DOD 

may be able to find additional efficiencies by further examining 

opportunities to consolidate organizations or centralize functions at 

headquarters. DOD may not have identified all areas where reductions in 

headquarters personnel and operating costs could be achieved because, 

according to DOD officials, the department was working quickly to identify 

savings in the fiscal year 2012 budget. To accomplish this quickly, DOD 

used a top-down approach that identified several targets of opportunity to 

reduce costs, to include headquarters organizations, but left limited time 

for a detailed data-driven analysis.

One key factor inhibiting DOD from conducting systematic analyses of 

headquarters is the lack of complete and reliable data about the resources 

being devoted to such headquarters. According to GAO internal control 

standards, an agency must have relevant, reliable, and timely information 

in order to run and control its operations. Moreover, accurate, timely, and 

useful financial information is essential for sound management analysis, 

decision making, and reporting within DOD. The department has had longstanding challenges in identifying and tracking personnel and other 

resources devoted to headquarters; in the late 1990s, GAO reported that 

the number of personnel and costs associated with major DOD 

headquarters activities were significantly higher than DOD reported to 

Congress due to inconsistencies in how DOD tracked headquarters data.

GAO’s ongoing work has found that these problems are unresolved and 

the data on major DOD headquarters activities are still incomplete and 

unreliable for decision making. As the department did not have reliable 

major DOD headquarters activity data, DOD gathered information from 

multiple sources to compile headquarters-related information for the 

Secretary of Defense’s 2010 efficiency initiative. According to DOD 

officials, the ever-changing statutory reporting requirements have 

contributed to DOD’s failure to report to Congress about the numbers of 

headquarters personnel. DOD is required to report major DOD 

headquarters activities annually in the Defense Manpower Requirements 

Report, which is to be submitted to Congress no later than 45 days after 

the President’s budget.4

 

4

National Defense Authorization Act for Fiscal Year 2010, Pub. L. No. 111-84, §1109 

(2009), codified at 10 U.S.C. §115a. The Defense Manpower Requirements Report is an 

annual report to Congress that displays DOD’s manpower requirements, to include military 

and civilians, as reflected in the President’s budget request for the current fiscal year. 

Specifically, DOD is to report the number of 

military and civilian personnel assigned to major DOD headquarters 

activities in the preceding fiscal year and estimates of such numbers for 

the current and subsequent fiscal year. It must also include a summary of 

the replacement of contract workyears providing support to major DOD 

headquarters activities with military or civilian personnel during the 
 

Page 236 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

preceding fiscal year, including an estimate of the number of contract 

workyears associated with the replacement of contracts performing 

inherently governmental or exempt functions. DOD must also report on 

the plan for continued review of contract personnel supporting major DOD 

headquarters activities for possible conversion to military or civilian 

positions in accordance with other legal requirements. Additionally, DOD 

must report the amount of any adjustment in personnel limits made by the 

Secretary of Defense or the secretary of a military department, and for 

each adjustment made pursuant to section 1111(b)(2) of the fiscal year 

2009 National Defense Authorization Act, the purpose of the adjustment.5

Furthermore, DOD Instruction 5100.73, which guides the compilation of 

data on major DOD headquarters activities, is outdated and does not 

identify all organizations that should be included, such as the component 

command headquarters of the Departments of Navy and Air Force at U.S. 

Africa Command and certain Marine Corps components; this potentially 

omits hundreds of personnel and associated operating costs from being 

counted as part of headquarters. Second, the Instruction does not 

explicitly address how and to what extent the thousands of contractors 

that work at headquarters around DOD should be included as part of its 

major headquarters activity data. DOD has increasingly relied on 

contractors to provide a range of services at headquarters, such as 

management and administrative support, information technology, and 

base operations support. Some of the services and functions performed 

by contractors could be considered as major DOD headquarters activities. 

DOD officials are aware of the reporting requirements and expect to 

report some of the major DOD headquarters activity data to Congress in 

the fiscal year 2012 Defense Manpower Requirements Report; however, 

it is unclear what information will be included in the report. 

GAO’s work over the past decade on DOD’s contracting activities has 

noted the need for DOD to obtain better data on its contracted services 

and personnel to enable it to make more informed management 

decisions, ensure departmentwide goals and objectives are achieved, 

and to have the resources to achieve desired outcomes, which could 

include reducing overhead. GAO reported in January 2011 that further 

action was needed by DOD to better implement its requirements for 

conducting an inventory of its service contractor activities and made two 

recommendations, to include that DOD develop a plan of action to collect 

manpower data from contractors. In response to GAO’s report, DOD has 

outlined its approach for collecting these data, but does not anticipate 

complete reporting until 2016.

 

5

Section 1111 of the Duncan Hunter National Defense Authorization Act for Fiscal Year 

2009, Pub. L. No. 110-417 (2008), allows for the adjustment of statutory personnel limits 

to fill a gap in DOD’s civilian workforce, identified by the Secretary of Defense in a 

strategic human capital plan submitted to Congress, or to accommodate increases in 

workload or modify the type of personnel required to accomplish work for purposes 

specified in section 1111(c) of the Act. 
 

Page 237 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

In light of changes in DOD’s strategic priorities, complete and reliable 

headquarters information will be even more important to support a 

systematic examination of DOD’s future structure. Without such information, 

efforts to re-examine its headquarters resources on a more comprehensive 

basis to identify additional efficiencies will be hampered, and DOD may miss 

opportunities to further shift resources from overhead to forces.

In the report that GAO anticipates issuing in March 2012, GAO expects to 

recommend several actions to facilitate reliable reporting on headquarters 

staffing and improve information available for decision making. 

Specifically, DOD should

• revise its Instruction on tracking of headquarters resources to include 

all major DOD headquarters activity organizations;

• specify how contractors performing headquarters functions will be 

identified and included in headquarters reporting;

• clarify how components are to compile the major DOD headquarters 

activities information needed to respond to the reporting requirements 

in section 1109 of the fiscal year 2010 National Defense Authorization 

Act; and

• establish time frames for implementing the actions above to improve 

tracking and reporting headquarters resources.

In addition, to further DOD’s ability to find efficiencies in headquarters and 

other overhead, GAO expects to recommend in the March 2012 report 

that DOD should

• continue to examine opportunities to consolidate or eliminate defense 

headquarters organizations that are geographically close or have 

similar missions, as well as seek further opportunities to centralize 

administrative and command support services, functions, or programs. 

GAO is unable to quantify the potential for further financial benefits 

because reliable headquarters data are unavailable. Although GAO 

cannot quantify the potential for additional financial benefits, further 

efforts by DOD to examine its headquarters resources and improve its 

headquarters data could present opportunities for additional cost savings.

GAO provided a draft of this report section to DOD for review and 

comment. DOD provided technical comments, which were incorporated 

as appropriate. DOD officials generally agreed with the actions needed 

identified by GAO. Specifically, DOD officials told GAO that the 

department focused on broader reductions for purposes of the Secretary 

of Defense’s 2010 efficiency initiative, not merely those activities 

identified as major DOD headquarters activities. GAO recognizes that 

major DOD headquarters activities are a subset of what DOD considered 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 238 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

for its efficiency initiatives. However, given the Secretary’s focus on 

finding efficiencies in headquarters, both as part of his overall efficiency 

initiative, as well as DOD’s recent 2012 strategic guidance, GAO believes 

complete and reliable headquarters-specific data is even more important 

in guiding an examination of DOD resources. Without this data on 

headquarters personnel and operating costs, DOD will not have the 

information it needs, which could impact its efforts to direct resources 

toward its main priorities.

The information in this draft is based on findings from the reports listed in 

the related GAO products section as well as additional work GAO 

conducted to be published as a separate product in 2012. GAO selected 

and assessed DOD efficiency initiatives related to headquarters based on 

GAO’s analysis of information included in DOD’s fiscal year 2012 budget 

request and the Secretary of Defense’s Track Four Efficiency Initiatives 

Decisions memo. GAO then obtained and analyzed documentary and 

testimonial evidence on these selected headquarters-related efficiency 

initiatives, including the analysis conducted to identify headquarters-related 

resources and the approach taken to develop selected headquartersrelated efficiency initiatives. GAO also obtained and analyzed documentary 

and testimonial evidence from DOD components detailing the policies and 

procedures, as well as roles and responsibilities, for tracking and reporting 

headquarters personnel and operating costs, such as DOD Instruction 

5100.73 Major DOD Headquarters Activities.

6

 

Defense Acquisitions: Further Action Needed to Better Implement 

Requirements for Conducting Inventory of Service Contract Activities. 

GAO-11-192. Washington, D.C.: January 14, 2011.

Defense Headquarters: Status of Efforts to Reduce Headquarters 

Personnel. GAO/NSIAD-00-224. Washington, D.C.: September 6, 2000.

Defense Headquarters: Status of Efforts to Reduce Headquarters 

Personnel. GAO/NSIAD-99-45. Washington, D.C.: February 17, 1999.

Defense Headquarters: Total Personnel and Costs Are Significantly 

Higher Than Reported to Congress. GAO/NSIAD-98-25. Washington, 

D.C.: October 30, 1997.

For additional information about this area, contact John Pendleton at 

(404) 679-1816 or pendletonj@gao.gov. 

 

6

Department of Defense Instruction 5100.73, Major DOD Headquarters Activities (Dec. 1, 

2007). 

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 239 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

35. Defense Real Property

Ensuring the receipt of fair market value for leasing underused real property and monitoring administrative 

costs could help the military services’ enhanced use lease programs realize intended financial benefits. 

With a real estate portfolio of over 539,000 facilities and 28 million acres 

of land, the Department of Defense (DOD) has been challenged to 

effectively manage deteriorating facilities and underused and excess 

property. To address these challenges, DOD has pursued a multipart 

strategy involving the base realignment and closure process, housing 

privatization, and demolition of facilities that are no longer needed. In 

addition, DOD has pursued a strategy it calls enhanced use leasing, 

which involves leasing underused real property to gain additional 

resources for the maintenance and repair of existing facilities or the 

construction of new facilities.1

The secretaries of the military departments have authority

According to the military services, 

enhanced use leases (EUL) offer significant opportunities to reduce 

DOD’s infrastructure costs and could provide hundreds of millions of 

dollars to improve installation facilities, rather than financing these 

improvements through annual appropriations.

2 to lease 

nonexcess military real property under the control of the respective 

departments in exchange for cash or in-kind consideration that is not less 

than the fair market value3 of the lease interest, subject to certain 

conditions. Some EULs involve complex agreements and long terms. For 

example, an EUL might provide for a 50-year lease of military land to a 

private developer that would be expected to construct office or other 

commercial buildings on the land and then rent the facilities to private 

sector tenants for profit. As consideration, the military might receive cash 

or in-kind services valued at an amount equal to a share of the net rental 

revenues from the developed property. As of the end of fiscal year 2010, 

the military services reported that 17 EULs were in place—the Army 

reported 7, the Navy reported 5, and the Air Force reported 5. The 

services also reported that 37 additional EULs were in various phases of 

review or negotiation for possible future implementation. However, as 

GAO previously reported in June 2011, the services did not always 

realize expected financial benefits from the EUL program.

 

1

Section 2667 of Title 10 of the United States Code provides authority to secretaries of the 

military departments to lease nonexcess real property under the control of the respective 

departments, subject to certain conditions. 

2

10 U.S.C. § 2667. 

3

In the enhanced use leasing context, the fair market value of the lease is determined by 

the appropriate departmental secretary. 

Why This Area Is 

Important
 

Page 240 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

GAO’s detailed case studies of nine EULs found that the services’ 

management of the EUL program contains internal control weaknesses 

related to policies and procedures and performance monitoring. 

Specifically, it is not clear how and to what extent the services have 

ensured the receipt of the fair market value of the lease interest, as 

required by the authorizing statute. In addition, GAO found that the 

services have not regularly monitored or performed periodic analyses of 

EUL program administration costs. Therefore, it is unclear whether such 

costs are in line with the potential program benefits.

While the statute leaves the determination of fair market value to the 

discretion of the secretary of each military service, and thus a particular 

methodology for determining fair market value is not required, GAO found 

cases where receipt of fair market value was questionable, largely because 

service guidance for determining and ensuring the receipt of fair market 

value for proposed EULs was not clear. In implementing an internal 

controls framework, as outlined in GAO’s Standards for Internal Control in 

the Federal Government,4

In addition, GAO found that the services have not regularly monitored or 

performed periodic analyses of EUL program administration costs to help 

ensure that such costs are in line with program benefits. According to 

internal control standards, activities need to be established to monitor 

performance measures and indicators, such as analyses of data 

relationships, so that appropriate actions can be taken, if needed. Without 

regular monitoring and analysis, the services have less assurance that 

their EUL program administration costs are in line with program benefits. 

While the services have no criteria for how much they should be spending 

management is responsible for developing 

detailed policies, procedures, and practices to fit their agency’s operations 

and to ensure that those controls are built into and are an integral part of 

operations. However, GAO found, in the absence of clear guidance, at 

least one instance where the Air Force agreed to an amount of lease 

consideration below one estimate of the value of the leased property. For 

example, in an Eglin Air Force Base EUL, referred to as the Okaloosa

County Regional Airport Enhanced Use Lease, the Air Force hired a 

company to estimate the fair market value of the property. Although the 

company estimated a value of $1,274,000 annually, after negotiations with 

the lessee, the Air Force agreed to accept $318,000 annually as 

consideration. Thus, the negotiated amount was $956,000, or 75 percent, 

less per year than the appraised value of the property. Because the 

services lack clear and consistent guidance on how the fair market value of 

lease interest should be determined and how the receipt of the fair market 

value can be best ensured, it is not clear how the officials involved in this 

and other cases determined whether the services received the fair market 

value of the leased property.

 

4

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

(Washington, D.C.: November 1999).

What GAO Found 
 

Page 241 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

on EUL program administration costs relative to program benefits, GAO’s

analysis showed that EUL program administration costs ranged from 31

percent to 135 percent of the total EUL consideration received during 

fiscal years 2006 through 2010. Specifically, GAO’s analysis of 

information provided by the services concluded that EUL program 

administration costs, including personnel and consultant costs, equaled 

about 31 percent of the total EUL consideration received by the Army and 

the Navy and about 135 percent of the total EUL consideration received 

by the Air Force. The Air Force spent about $10.4 million more to 

administer its EUL program than the amount of consideration received 

from its five EULs during fiscal years 2006 through 2010.

To help effectively implement the EUL program in order to maximize the 

potential economic benefits, GAO recommended in June 2011 that the 

departmental secretaries should

• review and clarify guidance describing how the fair market value of 

the lease interest should be determined and how the receipt of fair 

market value can be best ensured; and

• develop procedures to regularly monitor and analyze EUL program 

administration costs to help ensure that the costs are in line with 

program benefits.

GAO provided a draft of its June 2011 report to DOD for review and 

comment. DOD agreed with GAO’s previous recommendations and 

stated that the military services were taking appropriate measures to 

implement the recommendations. According to a DOD official, as of 

January 19, 2012, DOD did not have the formal status of actions taken to

respond to the recommendations in GAO’s report, but verified that they 

have begun the process of making those changes. As part of its routine 

audit work, GAO will track the extent to which progress has been made to 

address the identified actions and report to Congress. 

The information contained in this analysis is based on findings from the 

reports listed in the related products section. GAO reviewed statutory 

requirements; examined military service policies, instructions, and other 

guidance; and interviewed officials from the Office of the Secretary of 

Defense, the Army, the Navy, and the Air Force to discuss implementation 

of the EUL program. While GAO reviewed information on all 17 EULs in 

place at the end of fiscal year 2010, GAO selected 9 of the 17 EULs for 

detailed case study review. The EULs were selected non-randomly to 

include three from each service and a range of lease purposes, estimated 

financial benefits, and geographic locations. For the nine case studies, 

GAO reviewed how the services provided for the receipt of the fair market 

value of the leased property and how the services monitored program 

administration costs in relation to program benefits.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 242 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Defense Infrastructure: The Enhanced Use Lease Program Requires 

Management Attention. GAO-11-574. Washington, D.C.: June 30, 2011.

Federal Real Property: Authorities and Actions Regarding Enhanced Use 

Leases and Sale of Unneeded Real Property. GAO-09-283R. 

Washington, D.C.: February 17, 2009.

For additional information about this area, contact Brian J. Lepore, at 

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

Related GAO 

Products 

Contact Information
 

Page 243 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

36. Military Health Care Costs

To help achieve significant projected cost savings and other performance goals, DOD needs to complete, 

implement, and monitor detailed plans for each of its approved health care initiatives.

As GAO reported in February 2005, the Department of Defense’s (DOD) 

health care system is an example of a key challenge facing the U.S. 

government in the 21st century, as well as an area in which DOD could 

achieve economies of scale and improve delivery of services.1 Currently, 

health care costs constitute nearly 10 percent of DOD’s baseline budget

request. For its fiscal year 2012 budget, according to DOD 

documentation, DOD received $52.7 billion2 to provide health care to 

approximately 9.6 million active duty servicemembers, reservists, retirees, 

and their dependents. According to a 2011 Congressional Budget Office 

report, military health spending could reach $59 billion by 2016, and is 

projected to grow to $92 billion by 2030.3 In 2009, the Defense Business 

Board,4

Congressional leaders also share concerns over rising military health 

costs. For example, the House Committee on Armed Services’ Print 

accompanying the Ike Skelton National Defense Authorization Act for 

Fiscal Year 2011

a group of private sector experts who advise DOD on its overall 

management and governance, expressed concern at the rise in military 

health care costs and noted such spending could eventually begin to 

divert funding away from other priorities such as critical national security 

initiatives, compensation and personnel costs, and the acquisition of 

equipment.

5 noted that DOD had not yet developed a 

comprehensive plan to enhance quality, efficiencies, and savings in the 

Military Health System.6

 

1

GAO, 21st Century Challenges: Reexamining the Base of the Federal Government, 

Furthermore, DOD officials also agree that the 

GAO-05-325SP (Washington, D.C.: February 2005). 

2

DOD’s fiscal year 2012 budget of $52.7 billion for its Unified Medical Budget includes 

$32.5 billion for the Defense Health Program, $8.3 billion for military personnel, $1.1 billion 

for military construction, and $10.8 billion for the Medicare Eligible Retiree Health Care 

Fund. The total excludes overseas contingency operations funds and other transfers.

3

Congressional Budget Office, Long-Term Implications of the 2012 Future Years Defense 

Program, Pub. No. 4281, June 2011. 

4

Defense Business Board, Focusing a Transition, January 2009. 

5

The Ike Skelton National Defense Authorization Act for Fiscal Year 2011 (Pub. L. No. 

111-383 (2010)) was not accompanied by a conference report. In lieu of a formal 

conference report and joint explanatory statement, House Armed Services Committee 

Print No. 5 (Dec. 2010) was provided to show congressional intent and maintain legislative 

history.

6

The Military Health System refers to DOD’s health operations as a whole, and consists of 

the Office of the Assistant Secretary of Defense for Health Affairs; the medical 

departments of the Army, the Navy, the Air Force and Joint Chiefs of Staff; the Combatant 

Command surgeons; and the TRICARE network of health care providers.

Why This Area Is 

Important
 

Page 244 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

rate at which health care costs are rising must be addressed, as noted in 

the 2010 Quadrennial Defense Review,

7

Under the current structure of DOD’s Military Health System, the 

responsibilities and authorities for its management are distributed among 

several organizations—including the Assistant Secretary of Defense for 

Health Affairs and the military services. Health Affairs

which stated that DOD intends 

to continue to develop health care initiatives that will improve the quality 

and standard of care, while reducing growth in overall costs.

8 is responsible for 

creating and submitting a unified medical budget and allocating funds to 

the military services for their respective medical systems; however, 

Health Affairs lacks direct command and control of the services’ military 

treatment facilities. Additionally, the three departments each have 

Surgeons General to oversee their deployable medical forces and 

operate their own health care systems, including training for medical 

personnel. In GAO’s first report issued in response to its mandate to 

report on duplication, overlap, and fragmentation within the federal 

government,9 GAO stated that realigning DOD’s military medical 

command structures and common functions could increase efficiency and 

result in projected savings ranging from $281 million to $460 million 

annually.10 GAO is currently conducting additional work to look beyond 

these potential governance transformation efforts and to examine other 

initiatives DOD is undertaking that could help contain its rising health care 

costs. These other initiatives—with the exception of one which is related 

to governance—are focused on reducing per capita costs,11 improving its 

servicemembers’ medical readiness, and improving its beneficiaries’ 

overall health and experience of care.

GAO’s ongoing work has found that DOD has begun a number of health 

care initiatives intended to slow the rise in its health care costs, but it has 

not fully applied results-oriented management practices to its efforts, 

which limits its effectiveness in implementing these initiatives and 

achieving related cost savings and other performance goals. The Senior 

Military Medical Advisory Committee—a committee that functions as an 

 

7DOD, Quadrennial Defense Review Report, (Washington, D.C.: Feb. 1, 2010).

8

For purposes of this report, the Office of the Assistant Secretary of Defense for Health 

Affairs will be called Health Affairs.

9

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

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

10This estimate is based on a May 2006 report by the Center for Naval Analyses and were 

adjusted by GAO from 2005 to 2010 dollars. 

11DOD monitors the annual increase in costs for enrollees in its TRICARE Prime benefit 

and measures it against a civilian benchmark.

What GAO Found
 

Page 245 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

executive-level discussion and advisory group,

12

Partly in response to GAO’s ongoing work assessing DOD’s management 

of its initiatives, the department has taken some initial steps toward 

managing their implementation. GAO found that, in addition to developing 

a number of high-level, non-monetary metrics and corresponding goals 

for each strategic initiative, DOD has developed a dashboard 

management tool that will include elements such as an explanation of the 

initiative’s purpose, measures, and funding requirements for 

implementation. In December 2011, the Senior Military Medical Advisory 

Committee approved 6 dashboards that were significantly, but not entirely 

completed. A Health Affairs official stated that only one initiative out of 11 

currently has a cost savings estimate associated with it. Cost savings 

estimates are critical to successful management of the initiatives so that 

DOD can achieve its goal of reducing growth in medical costs as stated in 

the 2010 Quadrennial Defense Review. In addition, DOD has developed 

a template, or a more detailed implementation plan, that is to be 

completed for each dashboard and is intended to include general 

timelines and milestones, key risks, and cost savings estimates. DOD 

currently has one completed implementation plan, which also contains the 

one available cost savings estimate among all the initiatives. See the 

table below for a list of the 11 initiatives and their current status as of 

January 13, 2012.

has approved 11 

strategic initiatives that it believes will help reduce rising health care 

costs. DOD’s strategic initiatives consist primarily of changes to clinical 

and business practices in areas ranging from primary care to 

psychological health to purchased care reimbursement practices. DOD 

was experiencing a 5.5 percent annual increase in per capita costs for its 

enrolled population, according to data available as of December 2011, but 

DOD had set its target ceiling for per capita health care cost increases for 

fiscal year 2011 at a lower rate of 3.1 percent. According to DOD 

calculations using 2011 enrollee and cost data, if DOD had met its target 

ceiling of a 3.1 percent increase as opposed to a 5.5 percent increase, 

the 2.4 percent reduction would have resulted in approximately $300 

million in savings.

 

12This group is chaired by the Assistant Secretary of Defense for Health Affairs and 

includes the Surgeons General from the Army, the Navy, and the Air Force; the Joint Staff 

Surgeon; and four Deputy Assistant Secretaries of Defense.
 

Page 246 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Progress made in Developing a Dashboard and Detailed Implementation Plans for Each of DOD’s Strategic Initiatives as of 

January 13, 2012

Description of DOD’s strategic initiatives

Dashboard 

approved?

Implementation 

plan approved?

Estimated net 

savingsa

Implement the Patient Centered Medical Home model of care to 

increase satisfaction, improve care and reduce costsb   $39.3 million

Integrate psychological health programs to improve outcomes and 

enhance value 

Implement incentives to encourage adherence to medical 

standards based on evidence to increase patient satisfaction, 

improve care and reduce per capita health care costs 

Implement alternative payment mechanisms to reward value in 

health care services 

Revise DOD’s future purchased care contracts to offer more and 

varied options for care delivery from private sector heath care 

providers



Improve the measurement and management of DOD’s population 

health by moving away from focusing on illness and disease to an 

emphasis on prevention, intervention, and wellness by health care 

providers



Optimize pharmacy practices to improve quality and reduce cost

Implement policies, procedures, and partnerships to meet 

individual servicemembers’ medical readiness goals

Implement DOD and Veterans Affairs joint strategic plan for 

mental health to improve coordination

Implement modernized electronic health record to improve 

outcomes and enhance interoperability

Improved governance to achieve better performance in 

multiservice medical markets 

Source: GAO analysis of DOD information.

a

The net savings is DOD’s estimate and it covers fiscal years 2012 through 2016. GAO did not 

independently assess the reliability of this cost savings estimate. 

b

DOD estimates that its investment in Patient Centered Medical Home will be $571.4 million in total 

from fiscal years 2010 through 2016. 

As shown above, DOD has not fully completed the dashboards, 

implementation plans, and cost savings estimates for its 11 initiatives as 

of January 13, 2012. GAO has found that comprehensive, resultsoriented plans are key to effectively implementing agency strategies.13

 

13GAO, Combating Terrorism: Evaluation of Selected Characteristics in National 

Strategies Related to Terrorism, 

 As 

DOD completes its dashboards, implementation plans, and cost savings 

estimates, it could benefit from the application of a comprehensive, 

results-oriented management framework, including a robust description of 

the initiatives’ mission statement; problem definition, scope, and 

methodology; goals, activities and performance measures; resources and 

investments; organizational roles, responsibilities, and coordination; and 

key external factors that could affect goals. Without completing its plans 

GAO-04-408T (Washington, D.C.: Feb. 3, 2004).
 

Page 247 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

and incorporating these principles into them, DOD will be limited in its 

ability to implement these initiatives and achieve cost savings.

In addition, DOD has not completed the implementation of an overall 

monitoring process across its portfolio of initiatives for overseeing the 

initiatives’ progress and has not completed the process of identifying 

accountable officials and their roles and responsibilities for all of its 

initiatives. Further, GAO’s work on results-oriented management 

practices has found that a process for monitoring progress and defining 

roles and responsibilities is key to successful implementation.

14 As 

Military Health System leaders develop and implement their plans to 

control rising health care costs, they will also need to work across multiple 

authorities and areas of responsibility. As the 2007 Task Force on the 

Future of Military Health Care noted, the current Military Health System 

does not function as a fully integrated health care system.

15

As GAO reported in October 2005, agreement upon roles and 

responsibilities is a key step to successful collaboration when working 

across organizational boundaries, such as the military services.

For example, 

while the Assistant Secretary of Defense for Health Affairs controls the 

Defense Health Program budget, the services directly supervise their 

medical personnel and manage their military treatment facilities.

16

Committed leadership by those involved in the collaborative effort, from 

all levels of the organization, is also needed to overcome the many 

barriers to working across organizational boundaries. For example, 

Health Affairs manages the medical budget by allocating money to the 

services, but it lacks direct command and control of the military treatment 

facilities. DOD’s one approved implementation plan provides further 

information on how DOD has applied a monitoring structure and has 

defined accountable officials and assigned roles and responsibilities in 

the case of this one initiative. However, DOD has not completed this 

process for the remainder of its initiatives. Without sustained top civilian 

and military leadership that is consistently involved throughout the 

implementation of its various initiatives and until DOD fully implements for 

all of its initiatives a mechanism to monitor progress and identify 

accountable officials including their roles and responsibilities, DOD may 

be hindered in its ability to achieve a more cost-efficient military health 

system and at the same time address its medical readiness goals, 

improve its overall population health, as well as increase its patients’ 

experience of care.

 

14GAO-04-408T. 

15Defense Health Board, Task Force on the Future of Military Health Care, December 

2007. 

16GAO, Results-Oriented Government: Practices That Can Enhance and Sustain 

Collaboration Among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
 

Page 248 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Based on ongoing work, GAO expects to recommend that, in order to 

enhance its efforts to manage rising health care costs and demonstrate 

sustained leadership commitment for achieving the performance goals of 

the Military Health System’s strategic initiatives, DOD should

• complete and fully implement the dashboards and detailed 

implementation plans for each of the approved health care initiatives 

in a manner consistent with results-oriented management practices, 

such as the inclusion of upfront investment costs and cost savings 

estimates; and

• complete the implementation of an overall monitoring process across 

its portfolio of initiatives for overseeing the initiatives’ progress and 

identifying accountable officials and their roles and responsibilities for 

all of its initiatives.

DOD may realize projected cost savings and other performance goals by 

taking the actions GAO describes to help ensure the successful 

implementation of its cost savings initiatives. Given that DOD identified 

these initiatives as steps to slow the rapidly growing costs of its medical 

program, if implemented these initiatives could potentially save DOD 

millions of dollars. For example, according to a DOD calculation, if it had 

met its cost growth target for fiscal year 2011, it could have saved 

approximately $300 million.

GAO provided a draft of this report section to DOD for review and 

comment. DOD provided technical comments, which were incorporated

as appropriate. DOD agreed with GAO’s finding on the need to complete, 

implement and monitor plans for each of its approved health care 

initiatives. Further, DOD officials agreed with GAO’s expected 

recommendation to complete and fully implement, for each of their 

initiatives, detailed implementation plans in a manner consistent with 

results-oriented management practices, such as the inclusion of upfront 

investment costs and cost savings estimates. They stated that quantifying 

the financial benefits of programs that change the way care is delivered is 

an extremely complex task but that they are committed to trying to do so. 

Additionally, these officials agreed with GAO’s second expected 

recommendation to complete and fully implement, for each of their 

initiatives, an overall monitoring process across DOD’s portfolio of 

initiatives, and to identify accountable officials and their roles and 

responsibilities. As part of its routine audit work, GAO will track the extent 

to which progress has been made to address the identified actions and 

report to Congress. 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation 
 

Page 249 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted to be published as a separate product in 2012. 

GAO interviewed DOD officials in the Health Budgets and Financial Policy 

Office and in the Office of Strategy Management, within the Office of the 

Assistant Secretary of Defense for Health Affairs, as well as officials in 

the TRICARE Management Activity concerning their 11 health care 

initiatives and obtained and reviewed documentation concerning their 

efforts. GAO compared DOD’s efforts to its prior work on results-oriented 

key management practices. GAO obtained available documentation and 

interviewed DOD officials to determine DOD’s approach for monitoring 

the initiatives’ progress, identifying accountable officials, and defining 

their roles and responsibilities. GAO did not assess the reliability of any 

financial data since GAO was using the data for illustrative purposes to 

provide context on DOD’s efforts and to make broad estimates about 

potential cost savings from these efforts, and GAO determined that this 

data did not materially affect the nature of its findings.

Opportunities to Reduce Potential Duplication in Government Programs, 

Save Tax Dollars, and Enhance Revenue. GAO-11-318SP. Washington, 

D.C.: March 1, 2011. 

Defense Health Care: DOD Needs to Address the Expected Benefits, 

Costs, and Risks for Its Newly Approved Medical Command Structure. 

GAO-08-122. Washington, D.C.: October 12, 2007.

For additional information about this area, contact Brenda S. Farrell at 

202-512-3604 or farrellb@gao.gov . 

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 250 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

37. Overseas Defense Posture

The Department of Defense could reduce costs of its Pacific region presence by developing comprehensive 

cost information and re-examining alternatives to planned initiatives.

According to the 2010 Quadrennial Defense Review, approximately 

400,000 U.S. military personnel are forward-stationed or rotationally 

deployed, or postured, around the world on any given day—including 

those involved in operations in Afghanistan and Iraq. In addition to the 

costs of supporting ongoing combat operations, the Department of 

Defense (DOD) spends billions of dollars annually on its network of 

installations around the world that supports its overseas defense posture. 

In last year’s report on opportunities to reduce potential duplication in 

government programs, GAO reported that DOD should assess the costs 

and benefits of its overseas installations before committing to costly 

realignments and construction plans. For this year’s analysis, GAO is 

focusing on DOD’s presence in the Pacific region.

As GAO reported in May 2011, from 2006 through 2010, DOD obligated 

$24.6 billion to build, operate, and maintain installations in support of its 

defense posture in the Pacific. Additionally, the report stated that DOD is 

currently conducting the largest transformation of its defense posture in 

the Pacific since the end of World War II, including initiatives that will cost 

billions of dollars in resource investments and take many years—perhaps 

decades—to complete. Although DOD’s new defense strategy identifies 

U.S. presence in the Pacific as important, questions have arisen about 

the magnitude and costs of overseas basing projects and whether DOD’s 

planned investments support a coherent and affordable strategy.

Although DOD has taken steps to improve its planning for overseas 

defense posture, it has not fully identified costs or provided an analysis of 

alternatives for basing U.S. forces in the Pacific. Having U.S. troops 

permanently stationed overseas provides benefits—such as deterring 

aggression against U.S. allies—but it incurs significant costs. In previous 

GAO reports on overseas defense posture, GAO emphasized the need 

for DOD to assess the costs and benefits of options for the U.S. overseas 

military presence before committing to costly personnel realignments and 

construction plans. However, in the case of DOD’s overseas presence in 

the Pacific, GAO found that comprehensive cost information is not 

systematically used to inform DOD’s planning for its overseas defense 

posture. As a consequence, DOD and Congress lack reasonable 

assurance that overseas presence in the Pacific is being planned and 

implemented in a cost-effective and financially sustainable way. Reliable 

and complete cost estimates are critical to allow analyses of alternatives 

and oversight by decision makers.

As GAO reported in May 2011, several evolving defense posture 

initiatives in the Pacific have the potential to cost the department billions 

Why This Area Is 

Important

What GAO Found
 

Page 251 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

of dollars. Through informed decision making based on comprehensive 

information and analysis of alternatives for some of its planned defense 

posture initiatives in that region, DOD may be able to reduce some of 

these costs. For example:

• South Korea tour normalization initiative. DOD is transforming its 

defense posture in South Korea through a series of interrelated 

initiatives that DOD estimates will total $17.6 billion through fiscal year 

2020. The largest of these initiatives, tour normalization, would 

increase the tour lengths of personnel stationed in South Korea and 

move thousands of military dependents to South Korea. According to 

DOD officials, the decision to move forward with tour normalization 

was made to achieve certain strategic objectives, such as providing 

military commanders greater flexibility in how U.S. military forces 

assigned to South Korea are used and to improve the quality of life for 

military service members and their families. This initiative alone could 

cost DOD $5 billion by fiscal year 2020 and $22 billion or more 

through 2050; however, prior to making the decision to move forward 

with the tour normalization initiative, DOD did not complete a business 

case analysis that would have considered alternative courses of 

action for achieving its strategic objectives, and the costs and benefits 

associated with any alternatives. Potential alternatives might be to 

maintain current primarily 1-year unaccompanied tour lengths, 

partially implement tour normalization at select locations, or other 

possibilities that would help achieve United States Forces Korea’s 

strategic objectives. DOD is embarking on an initiative that involves 

moving thousands of U.S. civilians to locations in South Korea, mainly 

Camp Humphreys, and constructing schools, medical facilities, and 

other infrastructure to support them—without fully understanding the 

costs involved or considering potential alternatives that might more 

efficiently achieve U.S. strategic objectives.

• Japan and Guam realignment initiatives. DOD has embarked on a 

major realignment of its defense posture in mainland Japan, Okinawa 

and Guam but has not developed comprehensive cost estimates for 

this work. Approximately $29.1 billion in costs—primarily in 

construction costs—is anticipated to be shared by the United States 

and Japan to implement these realignment initiatives. DOD officials 

stated that total cost estimates for these initiatives—including 

operation and maintenance costs to DOD—were not available 

because of the significant uncertainty surrounding initiativeimplementation schedules. In February 2012, the United States and 

Japan released a joint statement indicating that the two governments 

have started official discussions to revise current posture plans, 

specifically the plans to relocate the Marines to Guam. In July 2010, 

the Senate Appropriations Committee directed DOD to provide status 

updates on defense posture initiatives in Korea, Japan, Guam, and 

the Northern Mariana Islands, as an appendix to the annual DOD 

Global Posture Report, to address such items as schedule status, 

facilities requirements, and total costs—including operation and 

maintenance costs. These updates should be provided annually, 

beginning with the submission of the fiscal year 2012 budget request, 
 

Page 252 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

until the restructuring initiatives are complete or funding requirements 

to support them are satisfied. The Committee renewed its direction in 

June 2011. If DOD is fully responsive to the Committee’s reporting 

direction, these updates should provide needed visibility into the cost 

and funding of the initiatives. According to DOD officials, DOD will 

submit an appendix as part of its 2012 Global Posture Report that 

includes updates to posture initiatives in Korea, Japan, and Guam. 

They anticipate the report will be issued in the spring of 2012.

• U.S. Pacific Command operation and maintenance costs. Service 

officials estimated that operation and maintenance costs for 

installations in the Pacific region would be about $2.9 billion per year 

through 2015.1 However, GAO found that, of the approximately $24.6 

billion reported as obligated by the military services to build, operate, 

and maintain installations in the Pacific from 2006 through 2010, 

approximately $18.7 billion—or about $3.7 billion per year—was for 

operation and maintenance costs, an increase of over 27 percent per 

year over the service officials’ estimate through 2015.2 Further, the 

planned defense posture initiatives in South Korea, Japan, and Guam 

may significantly increase operation and maintenance costs over the 

long term, potentially through 2015 and beyond. For example, DOD has 

yet to estimate costs associated with furnishing and equipping 

approximately 321 new buildings and 578 housing units in Okinawa. In 

the United States Department of Defense Fiscal Year 2011 Budget 

Request Overview, prepared by the Office of the Under Secretary of 

Defense (Comptroller), DOD outlined the need to reform the way it 

buys its weapons and other important systems and investments, 

including strengthening front-end scrutiny of costs and not relying on 

overly optimistic or underestimated cost estimates. In June 2011, DOD 

revised posture-related guidance to require full project costs, including 

any operation and maintenance costs, for all ongoing, current, and 5-

year planned posture initiatives to be submitted as part of a combatant 

commander’s theater posture plan. In the October 2011, U.S. Pacific 

Command’s Theater Posture Plan, neither operation and maintenance, 

nor total costs for posture initiatives had yet been included. GAO will 

continue to monitor future updates to the plan.

 

1

Operation and maintenance funding provides for a large number of expenses. With 

respect to DOD installations, operation and maintenance funding provides for such 

aspects as base operation support and sustainment, restoration, and modernization of 

buildings and infrastructure.

2

These costs do not include (1) supplementary funding provided to support ongoing 

operations, (2) costs reimbursed by tenant organization at installations in the U.S. Pacific 

Command’s area of responsibility, and (3) personnel costs for troops stationed at 

installations in the U.S. Pacific Command’s area of responsibility.
 

Page 253 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

To provide DOD and Congress with the comprehensive defense posture 

cost information needed to fully evaluate investment decisions and the 

affordability of defense posture initiatives, GAO recommended in May 

2011 that the Secretary of Defense

• identify and direct appropriate organizations within DOD to complete a 

business case analysis, including an evaluation of alternative courses 

of action, for the strategic objectives that have to this point driven the 

decision to implement tour normalization in South Korea;

• identify and limit investments and other financial risks associated with 

construction programs at Camp Humphreys, South Korea, that are 

affected by decisions related to tour normalization until a business 

case analysis is reviewed and the most cost-effective approach is 

approved by the Secretary of Defense; and

• direct the Secretaries of the military departments to develop annual 

cost estimates for defense posture in the Pacific that provide a 

comprehensive assessment of defense posture-related costs, 

including costs associated with operating and maintaining existing 

defense posture, as well as costs associated with defense posture 

initiatives, in accordance with guidance developed by the Under 

Secretary of Defense (Comptroller).

Additionally, in light of the United States and Japan’s joint statement 

announcing discussions to revise U.S. posture plans in the Pacific, it will 

be critical for DOD to develop comprehensive cost estimates—including 

estimates of operation and maintenance costs—as it evaluates cost 

effective alternatives for the future. To facilitate congressional oversight of 

plans to realign U.S. defense posture in the Pacific, and to provide 

reasonable assurance that DOD will take all appropriate measures to 

mitigate financial risks and better define future requirements, the 

Secretary of Defense should provide Congress

• specifics regarding corrective actions the department plans to take; 

and

• time frames for completion.

By assessing alternatives, conducting comprehensive cost analyses, and 

providing comprehensive annual defense posture cost estimates, DOD 

will be in a better position to fully evaluate investment requirements, and 

make more informed decisions regarding the affordability of its overseas 

defense posture. Furthermore, congressional committees will have the 

appropriate financial context to determine funding needs for specific 

posture-related initiatives and construction programs. Cost savings or 

avoidance would depend on the nature of changes made to DOD’s plans 

and how DOD implements its chosen options.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 254 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

GAO provided its May 2011 report to DOD for review and comment. 

DOD agreed with GAO’s recommendations and stated that it would work 

with its components to implement them. Insufficient time has passed 

since the issuance of the report for GAO to fully evaluate DOD’s 

implementation. As part of its routine audit work, GAO will track the extent 

to which progress has been made to address the identified actions and 

report to Congress.

The information contained in this analysis is based on findings from the

reports listed in the related GAO products section. GAO assessed DOD 

policies and procedures, interviewed relevant DOD and State Department 

officials, and analyzed cost data from the military services.

Defense Management: Comprehensive Cost Information and Analysis of 

Alternatives Needed to Assess Military Posture in Asia. GAO-11-316. 

Washington. D.C.: May 25, 2011.

Opportunities to Reduce Potential Duplication in Government Programs, 

Save Tax Dollars, and Enhance Revenue. GAO-11-318SP. Washington, 

D.C.: March 1, 2011.

Defense Management: Additional Cost Information and Stakeholder Input 

Needed to Assess Military Posture in Europe. GAO-11-131. Washington 

D.C.: February 3, 2011.

Defense Planning: DOD Needs to Review the Costs and Benefits of 

Basing Alternatives for Army Forces in Europe. GAO-10-745R. 

Washington D.C.: September 13, 2010.

Force Structure: Actions Needed to Improve DOD’s Ability to Manage, 

Assess, and Report on Global Defense Posture Initiatives. GAO-09-706R. 

Washington D.C.: July 2, 2009.

Defense Management: Actions Needed to Address Stakeholder 

Concerns, Improve Interagency Collaboration, and Determine Full Costs 

Associated with the U.S. Africa Command. GAO-09-181. Washington 

D.C.: February 20, 2009.

For additional information about this area, contact Brian J. Lepore at 

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

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 255 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

38. Navy’s Information Technology Enterprise 

Network 

Better informed decisions are needed to ensure a more cost-effective acquisition approach for the Navy’s Next 

Generation Enterprise Network.

In 2007, the Department of the Navy (Navy) established the Next 

Generation Enterprise Network (NGEN) program to replace and improve 

the Navy Marine Corps Intranet, which provides about 382,000 

workstations to approximately 700,000 users across 2,500 Navy and 

Marine Corps locations around the world. NGEN is intended to provide 

secure data and information technology services, such as data storage, 

e-mail, and video-teleconferencing. It is also intended to provide the 

foundation for the Navy’s future Naval Networking Environment—a set of 

integrated, phased programs that share a common enterprise architecture 

and standards.

As envisioned, NGEN’s capabilities are to be incrementally acquired 

through multiple providers (contractors). The first increment is to provide 

capabilities comparable to the Navy Marine Corps Intranet, as well as 

enhanced information assurance and increased government control over 

network operations.

To date, according to the President’s fiscal year 2012 budget, the NGEN 

program has spent about $434 million on work associated with the 

transition from the Navy Marine Corps Intranet. The first increment is to 

be fully operational in March 2014 and is to cost approximately $50 billion 

to develop, operate, and maintain through fiscal year 2025.

As GAO reported in March 2011, the Navy did not have sufficient basis 

for knowing that it is pursuing the most cost-effective approach for 

acquiring NGEN capabilities. According to the Department of Defense 

guidance,1

 

1

Defense Acquisition University, Defense Acquisition Guidebook, Section 3.3 “Analysis of 

Alternatives” (accessed Mar. 19, 2010).

an analysis of alternatives should examine viable solutions 

with the goal of identifying the most promising option, thereby informing 

acquisition decision making. While the Navy conducted an analysis of 

alternatives, it ultimately selected an approach that was not considered in 

this analysis and that the Navy estimated would cost at least $4.7 billion 

more than any of the four assessed alternatives. Further, the analysis of 

alternatives highlighted the potential for greater schedule and 

performance risks as the number of contractual relationships in the 

approach increases. Given that the selected approach includes a larger 

Why This Area Is 

Important

What GAO Found
 

Page 256 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

number of such relationships than the assessed alternatives, the relative 

schedule and performance risks for this approach are likely greater, and 

therefore are likely to result in greater costs. (See the table below for the 

contractual relationships and Navy’s estimated costs of the assessed 

alternatives and the selected approach.)

NGEN Alternative and Selected Approaches

Status quo Alt. 2 Alt. 3 variant Alt. 3

Selected 

approach

Contractual 

relationships

3 3 10 15 21

Estimated costa $10.3 $10.8 $10.8 $10.7 $15.6 

Sources: Navy data (status quo and alternatives 2, 3 variant, and 3); GAO analysis of Navy data (selected approach).

a

Fiscal years 2011-2015 in billions (adjusted for inflation). 

Navy officials did not view the differences in contractual relationships and 

schedule and performance risks between the approach selected and the 

assessed alternatives as significant, despite the difference in cost. 

Nevertheless, by using this acquisition approach, Navy decision makers 

lack assurance that their selected approach is the most promising and 

cost-effective course of action.

GAO also determined that the Navy’s schedule for NGEN did not 

adequately satisfy key schedule estimating best practices, which GAO 

has previously identified, such as establishing the critical path (the 

sequence of activities that, if delayed, impacts the planned completion 

date of the project) and assigning resources to all work activities. 

Because it did not satisfy these practices, the schedule does not provide 

a reliable basis for program execution. According to program officials, 

schedule estimating was constrained by staffing limitations. However, 

these weaknesses have contributed to delays in key NGEN events and 

milestones, including the completion of multiple major acquisition reviews 

and program plans.

Additionally, successful execution of system acquisition programs 

depends in part on effective executive-level governance, to include 

having organizational executives review these programs at key 

milestones in their life cycles and make informed performance- and riskbased decisions as to how they should proceed.2

 

2

GAO, Information Technology: Federal Agencies Need to Strengthen Investment Board 

Oversight of Poorly Planned and Performing Projects, 

NGEN acquisition 

decisions were not always performance- and risk-based. In particular, 

senior executives approved the program’s continuing progress in the face 

of known performance shortfalls and risks. For example, in November 

2009, the program was approved at a key acquisition review despite the 

lack of defined requirements, which officials recognized as a risk that 

GAO-09-566 (Washington, D.C.: 

June 30, 2009). 
 

Page 257 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

would impact the completion of other key documents, such as the test 

plan. According to Navy officials, the decisions to proceed were based on 

their view that they had sufficiently mitigated known risks and issues. 

However, Navy officials later realized the risk from a lack of defined 

requirements was a critical issue.

By selecting an approach that carries greater relative schedule and 

performance risks than other alternatives and that is being executed 

against an unreliable program schedule, the department increases the 

risk that its approach will lead to future cost overruns. Furthermore, if the 

department proceeds along its current course, the issues GAO has 

identified with the program’s schedule, along with the delays already 

experienced, raise concerns that it will be unable to complete the 

transition as planned.

To ensure that NGEN capabilities are acquired in the most cost-effective 

manner, GAO recommended in March 2011 that Secretary of Defense 

should

• limit further investment in NGEN until the Navy conducts an 

immediate interim review to reconsider the selected acquisition 

approach. At a minimum, this review should ensure that the Navy 

pursues the most advantageous acquisition approach, as evidenced 

by a meaningful analysis of all viable alternative acquisition 

approaches; it also should consider existing performance shortfalls 

and known risks.

Furthermore, to facilitate implementation of the acquisition approach 

resulting from this review, the Secretary of the Navy should

• ensure that the NGEN schedule substantially reflects the key 

schedule estimating practices, and that future NGEN acquisition 

reviews and decisions fully reflect the state of the program’s 

performance and its exposure to risks.

The Navy has subsequently indicated that changes to the acquisition 

strategy are under way. GAO is undertaking work that will assess the 

extent to which the Navy has conducted its interim review to reconsider 

its acquisition approach and evaluate the revised strategy, including the 

basis for determining that this approach is the most cost-effective. GAO 

will also determine the extent to which Navy has implemented key 

schedule estimating practices and has made performance- and riskbased decisions. If fully implemented, GAO’s key recommended actions 

should help the Navy ensure that the most cost-effective approach is 

pursued.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 258 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

GAO provided a copy of its March 2011 report to the Department of 

Defense for review and comment. The department agreed with the 

recommendation to ensure that future NGEN acquisition reviews and 

decisions fully reflect the state of the program’s performance and its 

exposure to risks. The department did not concur with the 

recommendation to reconsider its acquisition approach. However, as 

noted earlier, the Navy is currently in the process of reviewing and 

making changes to its acquisition strategy. Further, the department 

partially concurred with the recommendation to ensure that the NGEN 

schedule substantially reflects the key schedule estimating practices, 

stating that it would consider incorporating practices found to be 

beneficial. GAO believes that incorporating all of the best practices for 

schedule estimating in the NGEN master schedule would help the 

department manage and measure its progress in executing the work 

needed to transition from the Navy Marine Corps Intranet to NGEN. As 

part of its routine audit work, GAO will track agency actions to address 

these recommendations and report to Congress. 

The information contained in this analysis is based primarily on findings 

from the products listed in the related GAO products section. GAO 

analyzed the NGEN alternatives analysis report and underlying support, 

the program’s master schedule, program performance assessments and 

risk reports, and executive acquisition decision briefings and meeting 

minutes, among other things. GAO also interviewed cognizant agency 

and program officials regarding the analysis of alternatives’ development 

and results, development and management of the program schedule, and 

NGEN performance and program risks.

Information Technology: Better Informed Decision Making Needed on 

Navy’s Next Generation Enterprise Network Acquisition. GAO-11-150. 

Washington, D.C.: March 11, 2011.

Information Technology: DOD Needs to Ensure That Navy Marine Corps 

Intranet Program Is Meeting Goals and Satisfying Customers. 

GAO-07-51. Washington, D.C.: Dec. 8, 2006.

For additional information about this area, contact Valerie C. Melvin at 

(202) 512-6304 or melvinv@gao.gov. 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 259 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

39. Auto Recovery Office

Unless the Secretary of Labor can demonstrate how the Auto Recovery Office has uniquely assisted auto 

communities, Congress may wish to consider prohibiting the Department of Labor from spending any of its 

appropriations on the Auto Recovery Office and instead require that the department direct the funds to other 

federal programs that provide funding directly to affected communities.

In 2008 and 2009, the Department of the Treasury (Treasury) committed 

$62 billion in Troubled Asset Relief Program funding to General Motors 

(GM) and Chrysler to help the companies restructure. Anticipating the 

possible effects of the companies’ restructuring on communities that 

relied heavily on these companies and their suppliers for employment and 

economic investment, in June 2009 the President issued Executive Order 

13509 establishing the White House Council on Automotive Communities 

and Workers (the Council)—composed of over 20 members, including the 

heads of all domestic cabinet agencies and key White House offices—to 

coordinate a federal response to issues affecting these communities and 

others that rely on GM, Chrysler, or other auto companies and suppliers.1

As GAO reported in May 2011, GM and Chrysler restructured their 

operations from 2008 through 2010 in part by closing or halting 

production at 22 plants

The staff and the funding for the Council were housed within the 

Department of Labor’s Office of Recovery for Auto Communities and 

Workers (Auto Recovery Office).

2 (16 GM and 6 Chrysler), and communities in 

which these plants were located experienced economic challenges in 

addition to those they already faced. GAO visited six of these 

communities and found that unemployment in all of them increased after 

the plants closed. Staff of the Auto Recovery Office have tried to help 

communities address these challenges by serving as a listening post and 

federal liaison to agencies and programs that might assist them, but it is 

not clear whether the office provided communities with assistance that 

they otherwise would not have received. Nevertheless, the Department of 

Labor received funding for its management expenses, which it allocated 

to the office in fiscal years 2011 and 2012. The office spent approximately 

$1.2 million in fiscal year 2011. The Auto Recovery Office does not 

receive a direct line item appropriation, but rather negotiates an annual 

spending plan with the Secretary of Labor based on projected needs and 

historical data, and officials told GAO that they expect the same will occur 

for the fiscal year 2013 budget.

 

1

Executive Order No. 13509, 74 Fed. Reg. 30903 (June 23, 2009).

2

In September 2011, GM announced that it planned to reopen its Spring Hill, Tennessee, 

plant where it had previously halted production.

Why This Area Is 

Important
 

Page 260 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Since the Auto Recovery Office was established, it has not accomplished 

half of the responsibilities set forth in executive orders, and has not been 

able to demonstrate the results of its efforts to assist auto communities. In 

July 2011, the President issued Executive Order 13578 to continue 

assisting auto communities and workers.3

As GAO reported in May 2011, the Auto Recovery Office’s efforts were 

focused primarily on the first two of these functions—coordinating the 

efforts and support of federal agencies to ensure a coordinated federal 

response to issues that affect auto communities and workers, and 

conducting outreach—and this continues to be the case. As part of their 

coordination efforts, the Council members and Auto Recovery Office staff 

visited auto communities around the country, met with local officials to 

understand the key challenges facing each community, and connected 

them to the appropriate federal agencies and resources. A specific Auto 

Recovery Office staff member was assigned to each auto community and 

state to serve as a point person for each auto community. These staff 

members responded to their assigned communities’ needs, such as by 

providing technical assistance or identifying contacts, and continued to 

connect the communities to resources and individuals as appropriate.

While this executive order 

revoked the previous one establishing the Council, it contains essentially 

the same responsibilities, but with the Secretary of Labor performing them 

instead of the Council. These responsibilities include (1) working among 

executive departments and agencies to coordinate a federal response to 

issues that impact auto communities and workers; (2) conducting 

outreach to nonprofits, businesses, local governments, and others that 

could assist in bringing to the President’s attention concerns, ideas, and 

policy options for enhancing efforts to revitalize auto communities; (3) 

advising the President on the potential effects of pending legislation; and 

(4) providing recommendations to the President on changes to federal 

policies and programs to address issues of special importance to 

automotive communities and workers.

Although officials in communities GAO visited in 2010 and 2011 

acknowledged the efforts of Council members and Auto Recovery Office 

staff, they also reported securing much of the assistance they received 

following plant closures without those efforts. For instance, officials told 

GAO that much of the federal assistance they received was targeted to 

individuals recently laid off from auto plants and delivered through 

Department of Labor resources outside the Council and Auto Recovery 

Office, such as the Workforce Investment Act Dislocated Workers 

Program and Trade Adjustment Assistance.

In August 2011 a new executive director joined the Auto Recovery Office, 

filling a position that had been vacant for almost a year. The new director 

and staff have visited eight communities, including communities and 

 

3

Executive Order No. 13578, 76 Fed. Reg. 40591 (July 6, 2011).

What GAO Found
 

Page 261 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

officials identified by the office in the past as well as new individuals. They 

are also planning to visit additional communities where office staff noted 

that automotive plant closures have been announced, such as 

Shreveport, Louisiana and St. Paul, Minnesota. The office staff stated that 

they continue to provide technical assistance to auto communities and 

have also participated in webinars and other events related to auto 

community interests, such as events hosted by the Mayors Automotive 

Coalition, and RACER—the environmental trust established to remediate 

old GM plants. However, while the Auto Recovery Office has continued its 

efforts, it still has not fulfilled its other two responsibilities—advising the 

President on pending legislation and making recommendations to the

President on changes to federal policies and programs—for which it was 

established. Auto Recovery Office officials told GAO that they plan to 

make policy recommendations to the White House in fiscal year 2012.

Further, as GAO also reported in May 2011, neither the Council nor the 

Auto Recovery Office systematically tracked, measured, or assessed their 

assistance to auto communities and GAO recommended that they do so. 

GAO has reported in the past that federal agencies engaged in 

collaborative efforts need to create the means to monitor and evaluate 

their efforts so that they can identify areas for improvement.4

Since then, the office has provided some additional examples of 

assistance provided to specific communities, for example noting that its 

staff helped Kokomo, Indiana, secure Economic Development 

Administration funding to hire a “recovery coordinator” to support a 

regional economic development strategic plan, and helped Kokomo 

negotiate with Chrysler to receive over $25 million in personal property 

taxes the company owed the county. The office plans to publish some of 

these examples on its website. In addition, the office reported that it is in 

the process of developing measures to assess its work, including 

“assessments of needs of affected communities” and “strategic 

collaboration/recovery plans tailored to affected communities.” However, 

the Auto Recovery Office still does not have a process to systematically 

inventory and analyze all assistance provided to auto communities, 

without which it cannot ensure that it has identified all relevant areas for 

However, 

since the Council and Auto Recovery Office did not keep an inventory of 

assistance that they had provided or funding they had helped 

communities secure, analyze the inventory for trends, or publish the 

results of their analysis, it was difficult to identify that assistance. In their 

response to GAO’s May 2011 report, the Department of Labor noted the 

challenges in developing a set of metrics that measures activities such as 

facilitation and process and that the more traditional measures of 

performance-based results are being tracked by the agencies that are 

responsible for administering the actual delivery of services.

 

4

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
 

Page 262 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

improvement or made the appropriate recommendations, including to the 

President, as it was tasked to do.

Finally, Auto Recovery Office officials told GAO the office’s unique role is 

to serve as an ombudsman between auto communities undergoing 

economic and social distress and federal initiatives that could be of value 

to those communities, and that they see a need for this role continuing as 

long as auto factories are marked for closure. However, there are other 

efforts within the executive branch to assist economically distressed 

communities. For example, the White House’s Office of Domestic Policy 

is overseeing the Strong Cities, Strong Communities program, which also 

involves multiple agencies collaborating to assist communities facing 

economic challenges. This program has selected six communities to 

receive technical assistance, and at least one—Detroit—is an auto 

community that the Auto Recovery Office has also assisted.

Though the Auto Recovery Office has made progress toward tracking its 

assistance to auto communities, it still has not implemented three of 

GAO’s prior recommendations, making it difficult to identify the office’s 

assistance or benefit to auto communities. GAO recommended in May 

2011 that the Secretary of Labor 

• direct the Auto Recovery Office to (1) document the office’s 

achievements to date, including its assistance to various auto 

communities; (2) establish a process for measuring the office’s 

results; and (3) determine when and how the specialized assistance 

provided by the office can be transitioned to existing federal 

programs.

In addition, in the absence of documented results, Congress may wish to

• consider prohibiting the Department of Labor from spending any of its 

appropriations on the Auto Recovery Office and instead require that 

the department direct the funds to other federal programs that provide 

funding directly to affected communities.

GAO provided a draft of this report section to the Department of Labor for 

review and comment. The department provided written comments and 

agreed with GAO’s recommendations. In its comments, the department 

reiterated that the Auto Recovery Office is the only executive office that 

deals specifically with the needs of auto communities, and thus it is more 

effective than other federal programs at helping communities address the 

complex effects of automotive industry restructuring. The department 

notes that Strong Cities, Strong Communities, the initiative GAO cites as 

an example of other interagency efforts to assist economically distressed 

communities, was not designed to deal with issues unique to automotive 

communities, and therefore GAO should not suggest that it replace the 

Auto Recovery Office. In the report, GAO does not suggest that this 

initiative replace the Auto Recovery Office, but rather highlights that other 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 263 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

executive efforts exist to help communities facing economic challenges, 

regardless of the cause of these challenges. The department also 

provided additional examples of auto communities the office is assisting, 

which GAO incorporated as appropriate. Finally, the department writes 

that the Auto Recovery Office has fulfilled its responsibilities to advise the 

President on pending legislation, in part by participating in administrative 

review of pending legislation, preparing portions of the President’s 

budget, and engaging with the National Economic Council’s Office of 

Manufacturing Policy to inform policy decisions affecting proposed 

manufacturing legislation. While GAO recognizes that the Auto Recovery 

Office is involved in executive branch discussions regarding policies that 

could affect auto communities, the tasks the department cites, such as 

preparing the President’s budget, are tasks in which all executive 

agencies engage. Outside of these typical agency tasks, the department 

did not identify instances in which the Auto Recovery Office formally 

advised the President. More importantly, the Auto Recovery Office has 

not fulfilled GAO’s recommendations to track and measure its assistance, 

without which neither GAO nor Congress can identify what the office has 

done or accomplished with the funding provided to date. Given the 

challenges auto communities face, it is important to maximize federal 

assistance to these communities. As such, GAO suggested the 

department, if unable to demonstrate the results of the Auto Recovery 

Office’s efforts, redirect funds from the office to other departmental 

programs. As part of GAO’s routine audit work, GAO will track agency 

actions to address these recommendations and report to Congress. All 

written comments are reprinted in appendix IV. 

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted. GAO interviewed the Auto Recovery Office to 

obtain updated information on its activities and accomplishments. GAO 

also reviewed existing documentation related to the data and interviewed 

Auto Recovery Office staff. GAO determined that the data were 

sufficiently reliable to describe the Auto Recovery Office’s spending.

Troubled Asset Relief Program: Treasury’s Exit from GM and Chrysler 

Highlights Competing Goals, and Results of Support to Auto Communities 

Are Unclear. GAO-11-471. Washington, D.C.: May 10, 2011.

Troubled Asset Relief Program: Continued Stewardship Needed as 

Treasury Develops Strategies for Monitoring and Divesting Financial 

Interests in Chrysler and GM. GAO-10-151. Washington, D.C.: 

November 2, 2009.

For additional information about this area, contact A. Nicole Clowers at 

(202) 512-8678 or clowersa@gao.gov. 

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 264 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

40. Excess Uranium Inventories

Marketing the Department of Energy’s excess uranium could provide billions in revenue for the government. 

Uranium—a naturally occurring radioactive element—is used in nuclear 

weapons, as well as in fuel for nuclear power plants. In the United States, 

20 percent of the nation’s electricity comes from nuclear power, and 

growing anxiety over climate change generated by ever-growing demand 

for fossil fuels has sparked interest in increasing the use of nuclear 

power, despite ongoing concerns about safety in light of the March 2011 

nuclear accident in Japan. A healthy domestic uranium industry is 

considered essential to ensuring that commercial nuclear power remains 

a reliable option for supporting the nation’s energy needs.

The Department of Energy (Energy) maintains large inventories of 

uranium that it no longer requires for nuclear weapons or fuel for naval 

nuclear propulsion reactors. A large portion of Energy’s inventories 

consists of depleted uranium hexafluoride, otherwise known as “tails”— a 

byproduct of the uranium enrichment process. Although once considered 

an environmental liability, recent increases in uranium prices could 

transform these tails into a lucrative source of revenue for the 

government. Hundreds of thousands of metric tons of tails are stored at 

Energy’s uranium enrichment plants in Portsmouth, Ohio, and Paducah, 

Kentucky.

In addition to tails, Energy maintains thousands of tons of natural 

uranium, which likewise could be sold to utilities or others for additional 

revenue. For example, since December 2009, Energy has used some of 

this uranium to pay for environmental cleanup work at its Portsmouth 

uranium enrichment plant.

The Energy uranium inventories are worth potentially billions of dollars to 

commercial nuclear power plants that can use the material as fuel in their 

reactors.

With regard to the Energy depleted uranium tails, as GAO reported in 

March and April 2008 and again in June 2011, under certain conditions, 

pursuing the following options could generate significant revenue: 

• Energy could contract to re-enrich the tails. Uranium tails lack 

sufficient quantities of the fissile uranium-235 isotope necessary for 

nuclear fuel. Considerable enrichment is required to further increase 

the concentration of uranium-235. In the past, low uranium prices 

meant that the cost of enrichment would have been greater than the 

proceeds the government would receive for the relatively small 

amount of uranium-235 extracted. But increases in uranium prices—

from a nominal price of approximately $21 per kilogram of uranium in 

the form of uranium hexafluoride in November 2000 to about $160 per 

Why This Area Is 

Important

What GAO Found
 

Page 265 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

kilogram in May 2011—could make tails re-enrichment profitable. 

Although Energy would have to pay for processing, the resulting reenriched uranium could be profitably sold if the sales price of the 

uranium exceeded processing costs.

• Provided appropriate statutory authority, Energy could sell the tails “as 

is.” Although GAO found that Energy generally has the legal authority 

to process the tails and sell the resulting re-enriched uranium, GAO 

found that the department lacks authority to sell depleted uranium tails 

in their current form. While Energy disagrees and believes it currently 

has the necessary legal authority, it is nonetheless planning no sale of 

depleted uranium tails in the near term. Instead, Energy is committed 

to converting the tails to a more stable chemical form for safe longterm storage, which involves additional processing and stockpiling 

thousands of protective cylinders to contain the material indefinitely. If 

Congress were to provide the department with the needed legal 

authority to sell the tails, however, firms such as nuclear power 

utilities and enrichment companies might find it cost-effective to 

purchase these tails and re-enrich them as a source of nuclear fuel.

With regard to Energy’s inventories of natural uranium, as GAO reported 

in March and April 2008 and again in June 2011, the department has the 

general legal authority to sell this material; and in September 2011, GAO 

reported that in seven transactions executed since 2009, Energy has, in 

effect, “sold” nearly 1,900 metric tons of natural uranium into the market, 

using its contractor as a sales agent, receiving from $109 to $183 per 

kilogram. The total proceeds from these transactions funded over $250 

million in environmental cleanup services by that contractor at the 

Portsmouth uranium enrichment plant. Although Energy characterized 

these sales as barter transactions— exchanges of services 

(environmental cleanup work) for materials (uranium)—GAO’s review 

showed that they were sales of natural uranium through a sales agent. 

While Energy received no cash from the transactions, it allowed USEC, 

Inc. to keep cash from the sales. Energy thus violated the miscellaneous 

receipts statute, which requires an official or agent of the government 

receiving money for the government from any source to deposit the 

money in the U.S. Treasury. Executed in accordance with federal law, 

however, future sales of natural uranium by Energy could generate 

additional revenue for the government.

Ultimately, the extent to which sales of Energy’s uranium inventories 

would generate financial benefits for the government depends on several 

factors:

• The market price of uranium. The price for uranium is historically 

volatile, affected greatly by speculation regarding supply and demand, 

the price of competing energy resources, and domestic and 

international political and economic events or natural disasters, such 

as the March 2011 nuclear accident in Japan.
 

Page 266 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

• The price and availability of re-enrichment services. Only two 

companies currently provide enrichment services domestically. 

Energy would have to find a company with excess enrichment 

capacity beyond its current commitments, which may be difficult if 

large amounts of enrichment processing were required.

• An existing commitment to domestic uranium producers to limit 

Energy inventory sold. Under its December 2008 Excess Uranium 

Inventory Management Plan, Energy committed to limit the amount of 

uranium sold in a given year to no more than 10 percent of the 

domestic requirements for nuclear fuel. The sudden introduction of 

hundreds of tons of uranium into the market could topple prices and 

not only reduce the government’s revenue from such sales, but could 

also undermine profitability of the domestic uranium industry.

As GAO reported in June 2011, the potential value of Energy’s tails is 

currently substantial, but changing market conditions could greatly affect 

the tails’ value over time. GAO estimated the value of the tails at $4.2 

billion based on May 2011 uranium prices and enrichment costs and 

assuming sufficient re-enrichment capacity was available. 

In Energy’s 2008 uranium management plan, the department summarized 

its intent to sell or transfer uranium to the commercial market through 

2017, including plans to re-enrich and sell depleted uranium tails. But 

because DOE has decided to use uranium to fund environmental cleanup 

at the Portsmouth site, more uranium has been released into the market 

than articulated in the 2008 plan. As a result, Energy tabled plans to also 

sell uranium tails, because doing so would violate the commitment the 

department made to domestic uranium producers to limit the amount of 

uranium Energy sells in a given year.

Even in the absence of such a commitment, however, legal obstacles to 

the pursuit of certain options for its uranium tails and natural uranium 

exist. GAO previously found that Energy lacked the necessary legal 

authority to pursue potential options for its tails and natural uranium and 

that the following congressional action may be needed. Specifically

GAO recommended in March 2008 that Congress may wish to 

• clarify Energy’s statutory authority regarding depleted uranium, 

explicitly providing direction about whether and how Energy may sell 

or transfer the tails in their current form. Depending on the terms of 

the legislation, and given the significant amount of tails in inventory, 

the government could garner substantial revenue as a result.

GAO recommended in September 2011 that if Congress sees merit in 

using the proceeds from the barter, transfer, or sale of federal uranium 

assets to pay for environmental cleanup of uranium enrichment plants, it 

could consider 

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 267 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

• providing Energy with explicit authority to barter excess uranium and 

to retain the proceeds from all three types of uranium transactions 

(barter, transfer, and sale). Likewise, Congress could direct Energy to 

sell uranium for cash and make those proceeds available by 

appropriation for decontamination and decommissioning expenses at 

Energy’s uranium enrichment plants.

Congress has taken some actions in response to GAO’s work. For 

example, the Consolidated Appropriations Act, 2012, among other things, 

requires the Secretary of Energy to report to the House and Senate 

Appropriations Committees not less than 30 days prior to the transfer, 

sale, barter, distribution, or other provision of uranium in any form specific 

details on the transactions, including the amounts of uranium to be 

provided and an estimate of the uranium value along with the expected 

recipient of the material. The act also requires the Secretary to submit a 

report evaluating the economic feasibility of re-enriching depleted 

uranium.

GAO provided a draft of its September 2011 report to Energy. Energy 

provided written comments that stated that because it did not receive 

money for the uranium it used to pay for environmental cleanup work, it 

did not violate the miscellaneous receipts statute. However, GAO and the 

courts have found in a number of instances that an entity does not have 

to receive actual cash to trigger a responsibility to deposit money into the 

U.S. Treasury. Energy also disagreed with GAO’s estimate of the value of 

Energy’s depleted uranium tails, stating that it did not include additional 

costs that may be incurred processing tails including, among other things, 

the costs of re-enriching the tails and packaging and transporting the 

material. The estimate does include the costs of re-enriching the tails, but 

it does not include some other costs, including packaging and 

transportation, because those costs are unknown. Furthermore, as GAO’s 

March and April 2008, June 2011, and September 2011 reports noted, 

GAO’s estimate is very sensitive to changing uranium prices, as well as to 

the availability of sufficient enrichment capacity. Uranium prices are 

volatile, and a sharp rise or fall can greatly affect the value of the tails. 

Any estimates of the value of the Energy tails are therefore subject to 

great uncertainty. As part of its routine audit work, GAO will track agency 

actions to address its recommendations and report to Congress.

The information contained in this analysis is based on findings from the 

products listed the related GAO products section. These reports reviewed 

Energy’s management of its uranium inventories and the department’s 

transactions using its uranium to pay for environmental cleanup and other 

services. GAO reviewed Energy documents detailing the transactions the 

department has engaged in involving its uranium, assessments of the 

value of uranium in each transaction, and analyses of the impact of 

DOE’s activities on the uranium market. 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 268 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Excess Uranium Inventories: Clarifying DOE’s Disposition Options Could 

Help Avoid Further Legal Violations. GAO-11-846. Washington, D.C.: 

September 26, 2011.

Nuclear Material: DOE’s Depleted Uranium Tails Could Be a Source of 

Revenue for the Government. GAO-11-752T. Washington, D.C.: June 13, 

2011.

Department of Energy: December 2004 Agreement with the United States 

Enrichment Corporation. B-307137. Washington, D.C.: July 12, 2008.

Nuclear Material: Several Potential Options for Dealing with DOE’s 

Depleted Uranium Tails Could Benefit the Government. GAO-08-613T. 

Washington, D.C.: April 3, 2008.

Nuclear Material: DOE Has Several Potential Options for Dealing with 

Depleted Uranium Tails, Each of Which Could Benefit the Government. 

GAO-08-606R. Washington, D.C.: March 31, 2008.

For additional information about this area, contact Gene Aloise at (202) 

512-3841 or aloisee@gao.gov. 

Related GAO 

Products 

Contact Information
 

Page 269 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

41. General Services Administration 

Schedules Contracts Fee Rates

Re-evaluating fee rates on the General Services Administration’s Multiple Award Schedules contracts could 

result in significant cost savings governmentwide.

In recent years, federal agencies spent nearly $40 billion each fiscal year 

procuring goods and services through the General Services 

Administration’s (GSA) Multiple Award Schedules (MAS) contracts. MAS 

contracts are operated to help leverage the buying power of the federal 

government by providing cost savings at prices associated with volume 

buying on millions of commercial goods and services. GSA awards and 

administers over 19,000 contracts with vendors under the MAS program.

As permitted by statute, GSA charges customer agencies a fee when 

they place orders under MAS contracts. The MAS program’s fee rate, 

which is expressed as a percentage of the dollar value of the order, has 

remained stable for the last 5 fiscal years at 0.75 percent. In fiscal year 

2010, GSA collected approximately $282 million in fee revenue from 

agencies that use the MAS contracts. GSA retains this revenue to support 

the MAS program.

As GAO reported in September 2011, the revolving fund statute under 

which GSA operates its MAS program requires that GSA set its 

interagency contract fee rate to recover the costs of the program’s 

operations.1

 

1

40 U.S.C. § 321(d)(2), which requires cost recovery “so far as practicable.” 

It also provides that GSA may establish reserves for 

operating needs. The program is not required to break even on an annual 

basis. As such, the program is permitted to have excess revenue in a 

given year or annual costs that exceed revenue. The figure below shows 

the fee revenue GSA collected and GSA’s costs to operate the MAS 

program during fiscal years 2007 through 2010, and illustrates the 

difference between those amounts, which GAO refers to as excess 

revenue. The figure also illustrates that although the annual excess 

revenue generated by GSA’s MAS program has declined over those 

years, GSA’s MAS program averaged an excess of $62.2 million in 

revenue over program costs, before contributions to reserves, each fiscal 

year.

Why This Area Is 

Important

What GAO Found
 

Page 270 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Fee Revenue versus Costs for the GSA MAS Program—Fiscal Years 2007 through 

2010

Note: All data and calculations are in nominal dollars. 

GSA maintains three reserves for all the programs operated through the 

revolving fund that includes the MAS program:

• the Working Capital Reserve, an operating reserve,

• the Business Reserve, which is to be used for planned improvement 

projects, and

• the Investment Reserve, which is to be used for improvements that 

were not planned when the revenue was placed in the reserve.

Excess revenue accumulates in the reserves until it is used for operations 

or improvement projects.

From fiscal years 2007 to 2010 GSA’s reserve balances grew 

significantly, largely due to this excess revenue generated annually by the 

MAS program. At the end of fiscal year 2010, the combined balance of 

GSA’s three reserves was over $800 million—about $350 million of which 

resided in the Working Capital Reserve to cover shortfalls in operating 

funds. Although GSA reviews its program fee rate annually as part of its 

budget process, there is nothing in GSA’s internal guidance that would 

trigger an evaluation of the fee rate of an individual program, such as the 

MAS program, that consistently generates excess revenue resulting in the 

continuous growth of the reserve balances.
 

Page 271 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

A reduction in the fee rate for the MAS program could generate significant 

cost savings for every agency of the federal government that uses the 

MAS program. For example, a reduction of 0.10 percentage points—from 

the current rate of 0.75 percent to 0.65 percent—would generate a 

savings of almost $40 million per year.

To improve the management of the MAS program, GAO recommended in 

September 2011 that the Administrator of General Services direct the 

Federal Acquisition Service Commissioner to

• develop and implement guidance for evaluation of current fee rates 

when an individual program consistently transfers excess revenue to 

the reserve funds.

Such an evaluation would allow GSA to determine whether a reduction in 

the fee rate of any of its programs might be warranted. A reduction of the 

fee rate for the MAS program alone would provide federal agencies 

potentially significant cost savings.

GAO provided GSA with a copy of its September 2011 report for review 

and comment. GSA agreed with GAO’s recommendation to develop and 

implement guidance. GSA is planning to issue a new policy in February 

2012 that establishes an annual process to determine the need to 

conduct fee rate reviews for programs that produce an excess (or 

shortfall) of over $5 million in revenue on average over any 3-year period. 

The draft policy also requires an automatic review of the fee rate of the 

MAS program each year. GSA plans to perform these assessments 

annually beginning in March 2012. GSA expressed concern about 

reducing the current fee rate in light of recent reductions in excess 

revenue. In this regard, GSA pointed out that it needs to ensure sufficient 

levels of reserves to fund needed improvements in the information 

technology systems that support its programs. GAO believes the annual 

process will provide for a more rigorous monitoring of the fee rates 

charged by GSA and provide a trigger for fee rate reviews when 

appropriate. The annual process could also give GSA further insight into 

the level of reserve funds that will be available for its information 

technology improvement projects.

As part of its routine audit work, GAO will track agency action to address 

the recommendation and report to Congress.

The information contained in this analysis is based on the findings in the 

report listed in the related GAO product section as well as additional work 

GAO conducted. GAO analyzed cost and revenue data on the program 

for fiscal years 2007 through 2010. GAO also interviewed officials from 

GSA’s MAS program, policy, and financial offices.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 272 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Interagency Contracting: Improvements Needed in Setting Fee Rates for 

Selected Programs. GAO-11-784. Washington, D.C.: September 9, 2011.

For additional information about this area, contact William T. Woods at 

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

Related GAO Product

Contact Information
 

Page 273 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

42. U.S. Currency

Legislation replacing the $1 note with a $1 coin would provide a significant financial benefit to the government 

over time. 

Over the past 40 years, many nations have replaced lower-denomination 

notes with coins as a means of providing a financial benefit to their 

governments. GAO has reported five times over the past 22 years that 

replacing the $1 note with a $1 coin would provide a net benefit to the 

government of hundreds of millions of dollars annually.1

 

The federal government realizes a financial gain when it issues notes or 

coins because both forms of currency usually cost less to produce than 

their face value. This gain, which is known as “seigniorage,” equals the 

difference between the face value of currency and its costs of 

production.2

GAO updated its most recent March 2011 estimate

Seigniorage reduces the government’s need to raise 

revenues through borrowing, and with less borrowing, the government 

pays less interest over time, resulting in a financial benefit.

3 due to changes by 

the Federal Reserve and Department of the Treasury (Treasury) in note 

processing and $1 coin production4 and found that replacing the $1 note 

with a $1 coin would provide a net benefit to the government of 

approximately $4.4 billion over 30 years, amounting to an average yearly 

discounted net benefit5

 

1

Over time, GAO’s estimate has changed due to a variety of reasons, including the 

increased lifespan of the $1 note and different assumptions in its analyses.

of about $146 million. This benefit occurs 

because, based on differences in how notes and coins are used in the 

economy, more coins than notes will have to be circulated to meet 

2

Traditionally, seigniorage is defined as the difference between the face value of coins 

and their cost of production. As long as there is public demand, the government creates

this net value when it puts coins into circulation. Similarly, when the Federal Reserve 

issues notes, it creates an analogous net value for the federal government, equal to the 

face value of the notes less their production costs.

3

In March 2011, GAO estimated that replacing the $1 note with a $1 coin would provide a 

net financial benefit to the government of about $5.5 billion over 30 years.

4

In April 2011, the Federal Reserve put in place new equipment to process notes that 

extended the life of the $1 note to approximately 56 months; GAO used an estimated note 

life of 40 months in its 2011 report. In December 2011, the Treasury Department decided 

to stop producing $1 coins for circulation, relying on coins currently stored at the Federal 

Reserve to meet the relatively small transactional demand for $1coins.

5

A discounted net value uses a rate, known as the discount rate, to convert the value of 

payments or receipts expected in future years to today’s value, taking into account that the 

further into the future an amount is paid or received, the smaller its value is today. 

Applying a discount rate establishes a consistent basis for comparing alternative 

investments that will have differing patterns of costs and benefits over many years.

Why This Area Is 

Important

What GAO Found 
 

Page 274 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

demand, and therefore more seignorage will be created. This estimate 

differs from what GAO reported in March 2011 because it takes into 

account the Treasury’s decision in December 2011 to stop producing $1 

coins for circulation immediately. To meet public demand for the coins, 

the Treasury intends to rely on the approximately 1.4 billion $1 coins 

currently stored with the Federal Reserve as of September 30, 2011. The 

current estimate also differs from the 2011 estimate because it uses a 

revised forecast that anticipates a lower government borrowing rate over 

the next 30 years and a longer life expectancy for the $1 note that results 

from efficiencies in the way the Federal Reserve processes notes, which 

began in April 2011.

GAO’s current estimate assumes a 4-year transition period beginning in 

2012 during which the production of $1 notes stops immediately and $1 

coins are quickly produced to meet demand for this currency 

denomination. This replacement scenario is compared to a status quo 

scenario under which $1 notes remain the primary single dollar currency.

The status quo scenario also incorporates the Treasury’s December 2011 

decision to rely on $1 coins in storage to meet public demand for $1 coins 

until that stock is nearly depleted, at which time production of $1 coins 

would resume. According to the Treasury, the coins in storage could meet 

current levels of circulating demand for more than a decade. As shown in 

the figure below, the annual net benefit from replacing the $1 note with a 

$1 coin would vary over the 30 years—the government would incur a net 

loss in 6 of the first 7 years and then realize a net benefit in the remaining 

years. The early net loss from replacing the $1 note is due in part to the 

up-front costs to the United States Mint of increasing its coin production 

during the transition, together with the limited interest expense the 

government would avoid in the first few years after replacement began. 

GAO’s net benefit estimate is due solely to seigniorage and not to 

reduced production costs. In fact, the production costs of transitioning to a 

$1 coin are never recovered during the 30-year period. And like all 

estimates, it is uncertain, particularly in the later years, and thus the 

benefit could be greater or smaller than estimated.
 

Page 275 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Discounted Net Benefit to the Government of Replacing $1 Notes with $1 Coins over 30 Years, by Year

The December 2011 action by the Treasury to stop producing $1 coins for 

circulation and to meet public demand for the coin by using the $1 coins 

currently being stored will reduce government costs by preventing the 

overproduction of $1 coins. The overproduction results from the 

presidential $1 coin program, which requires four new presidential $1 coin 

designs, featuring images of past presidents in the order they served, to 

be issued each year.6 According to Federal Reserve officials, because 

the United States Mint delivers each new presidential coin design to 

banks in large quantities, banks have no choice but to order more coins 

than they ultimately need to fulfill the demand for new coins.7

 

6

Presidential $1 Coin Act of 2005, Pub. L. No. 109-145 (2005), codified at 31 U.S.C. § 

5112(p)(3)(D).

As a result, 

unneeded coins are returned to the Federal Reserve, which held over 1.4 

billion $1 coins in storage as of September 30, 2011. The Treasury 

estimates that stopping production of $1 coins for circulation while it 

draws down the coins in storage will save about $50 million per year over 

the next several years in coin production costs. However, GAO estimates 

that eliminating $1 notes and replacing them with a $1 coin will have 

larger net benefit over time.

7

Twelve regional Federal Reserve banks order coins from the United States Mint, which 

distributes coins directly to those banks. The Federal Reserve banks distribute coins as 

well as notes to commercial banks to meet the demand of retailers and the public. Some 

coins and notes are returned by commercial banks as deposits to the Federal Reserve 

banks, where they are processed for storage or recirculation. According to Federal 

Reserve officials, each new presidential coin design is delivered in units of 1,000.
 

Page 276 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

To reduce the costs associated with the $1 note and $1 coins in the long 

term, Congress may wish to consider

• replacing the $1 note with a $1 coin to achieve an estimated financial 

benefit of $4.4 billion over 30 years. Legislation has been proposed 

that would make this replacement.8

GAO provided a draft of this report section to the Federal Reserve and 

Treasury for review and comment. The Federal Reserve provided written 

comments that noted it believes GAO’s estimate overstates the net 

financial benefit to the government because it does not (1) adequately 

address the costs to the Federal Reserve to reinforce the floors of its 

bank vaults to accommodate the heavier weight of coins or (2) consider 

potential increases in raw material costs for coins or possible future 

changes in discount rates. GAO included all costs to the Federal Reserve 

that the agency provided data on. The Federal Reserve provided no 

estimate of the additional cost to accommodate heavier coins. GAO used 

the best data available on coin production costs, which accounts for the 

cost of raw materials, and discount rate. The Federal Reserve also noted 

an increased risk of counterfeiting $1 coins and the lack of a GAO 

sensitivity analysis that reflected further increases in electronic payments 

by the public. GAO reported in 2011 that counterfeiting of U.S. coins is 

currently minimal, according to the U.S. Secret Service. Furthermore, in 

2011, GAO reported the results of a sensitivity analysis in which the 

replacement leads to a decrease in the demand for currency as people 

switch to electronic means of payment. GAO recognizes that changing 

conditions, such as how people use cash and the cost of materials in the 

future, may alter the total cost savings associated with the $1 coin. The 

Treasury provided e-mailed comments that pointed out that GAO’s 

analysis does not account for the impact on or costs to the private sector; 

both Treasury and the Federal Reserve noted that the analysis should not 

include seigniorage. As GAO reported in 2011, it found no quantitative 

estimates of the cost of replacement to the private sector that could be 

evaluated or modeled. GAO believes that seigniorage cannot be set aside 

since it is a result of issuing currency. The Treasury also provided 

technical comments, which were incorporated as appropriate. All written 

comments are reprinted in appendix IV.

 

8

Currency Optimization, Innovation, and National Savings Act, H.R. 2977, 112th Cong. 

(2011). Other legislation has been proposed that would postpone the minting of new $1 

coins until the inventory of stored $1 coins has been reduced (Currency Efficiency Act of 

2011, S. 1624, 112th Cong. (2011).

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation
 

Page 277 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

The information contained in this analysis is based on findings from the 

product listed in the related GAO products section as well as additional 

work GAO conducted. GAO reviewed the Federal Reserve’s June 2011 

report on the $1 coin9 and recent proposed legislation; and conducted 

interviews with senior officials from the Federal Reserve, the United 

States Mint, the Bureau of Engraving and Printing, and the Department of 

the Treasury. To estimate the net benefit to the government of replacing 

the $1 note with a $1 coin, GAO constructed an economic model with 

data from the Federal Reserve, the Bureau of Engraving and Printing, 

and the United States Mint. GAO’s model assumptions covered a range 

of factors including the replacement ratio of coins to notes, the expected 

rate of growth in the demand for currency over 30 years, the costs of 

producing and processing both coins and notes, and the differential life 

spans of coins and notes. GAO arrived at its estimate of net benefit to the 

government by subtracting the benefit from a status quo scenario from 

the benefit of a replacement scenario. In the status quo scenario, notes 

remain the dominant form of currency at the $1 denomination, the United 

States Mint ceases production of $1 coins until the current stored coins 

are all released into circulation to meet public demand, and production of 

$1 coins resumes after the stored coins are depleted. In the replacement 

scenario, GAO assumed, among other things, that the production of $1 

notes would stop immediately; no notes would be withdrawn from 

circulation, but because of their shorter life span, they would naturally fall 

out of circulation within a few years; and the United States Mint would 

expand its production of $1 coins during the first 4 years. In estimating the 

net benefit to the government of replacing the $1 note with a $1 coin, 

GAO considered only the financial effect of this change on the 

government and did not consider other factors, such as the relative 

environmental and societal costs and benefits due to data limitations. 

GAO conducted sensitivity analyses that decreased the demand for 

currency as people switch to electronic payments and changed the 

number of coins needed to replace each note.

U.S. Coins: Replacing the $1 Note with a $1 Coin Would Provide a 

Financial Benefit to the Government. GAO-11-281. Washington, D.C.: 

March 4, 2011.

For additional information about this area, contact Lorelei St. James at 

(202) 512-2834 or stjamesl@gao.gov. 

 

9

Board of Governors of the Federal Reserve System, Annual Report to the Congress on 

the Presidential $1 Coin Program (June 2011).

How GAO Conducted 

Its Work

Related GAO Product

Contact Information
 

Page 278 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

43. Federal User Fees 

Regularly reviewing federal user fees and charges can help the Congress and federal agencies identify 

opportunities to address inconsistent federal funding approaches and enhance user financing, thereby 

reducing reliance on general fund appropriations.

Federal user fees and charges are generally related to some voluntary 

transaction or request for government goods or services beyond what is 

normally available to the public, such as fees for national park entrance, 

patent applications, and customs inspections. Twenty-three federal 

agencies reported collecting nearly $64 billion in fees or charges in fiscal 

year 2010. As GAO reported in May 2008, well-designed user fees can 

reduce the burden on taxpayers to finance those portions of activities that 

provide benefits to identifiable users. Regular, comprehensive fee reviews 

can help identify duplicative fee-funded activities, prevent misalignment 

between fees and the activities they cover, and maximize opportunities for 

user financing.

In many instances, Congress has provided specific authority to federal 

agencies to assess user fees in agency authorization or appropriations 

legislation. Agencies that lack specific statutory authority to charge fees 

can rely on the Independent Offices Appropriation Act of 19521 which 

provides broad authority to assess user fees or charges on identifiable 

beneficiaries by administrative regulation.2 When a fee’s authorizing 

statute does not specify review and reporting requirements, and for fees 

that derive their statutory authority from the Independent Offices 

Appropriation Act, the CFO Act of 19903

 

1

Pub. L. No. 82-137 (Aug. 31, 1951), codified at, 31 U.S.C. § 9701.

(CFO Act) and OMB Circular No. 

A-25 directs agencies to biennially review their fees and to recommend 

fee adjustments as appropriate. In addition, OMB Circular No. A-25 

directs agencies to include non-fee-funded programs in these reviews to 

determine whether fees should be initiated for government services or 

goods for which fees are not currently charged. Further, if imposing such 

fees is prohibited or restricted by law, agencies are to recommend 

legislative changes as appropriate. Moreover, agencies are to discuss the 

2

User fees assessed under the Independent Offices Appropriation Act’s authority must be 

(1) fair and (2) based on costs to the government, the value of the service or thing to the

recipient, public policy or interest serviced, and other relevant facts. Fees collected under 

this authority are deposited in the general fund of the U.S. Treasury and are generally not 

available to the agency or the activity generating the fees. Unless otherwise authorized by 

law, the act requires that agency regulations establishing a user fee are subject to policies 

prescribed by the President. 

3

Pub. L. No. 101-576 (Nov. 15, 1990), codified at, 31 U.S.C. § 902. The CFO Act requires 

agencies to report on “fees, royalties, rents, and other charges imposed by the agency for 

services and things of value it provides.” For the purposes of this discussion, GAO 

collectively refers to all of these as user fees.

Why This Area Is 

Important

What GAO Found
 

Page 279 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

results of these reviews and any resulting proposals, such as adjustments 

to fee rates, in the CFO annual report required by the CFO Act. This 

discussion may be included in agency performance and accountability 

reports. Lastly, budget formulation guidance to agencies in OMB Circular 

No. A-11 directs agencies to follow fee review guidance in OMB Circular 

No. A-25 and to report on the results of fee reviews in CFO Act reports.

GAO previously reported that not reviewing fees regularly can result in 

large fee increases and create costly challenges. For example, prior to its 

2007 fee review, U.S. Citizenship and Immigration Services had not 

conducted a comprehensive review of its immigration and naturalization 

fees in 9 years and, as a result, had to increase fees by an average of 86 

percent to cover its costs. Further, during the month before the fee 

increase took effect, applications increased an unprecedented 100 

percent over the prior month, far outpacing the agency’s processing 

capacity. As a result, 1.47 million applications were delayed and the 

agency incurred unplanned costs to secure additional facilities to store 

these applications.

In May 2008, GAO issued its User Fee Design Guide, which examined 

how the four key design and implementation characteristics—how fees 

are set, collected, used, and reviewed—may affect the economic 

efficiency, equity, revenue adequacy, and administrative burden of the 

fees. The Design Guide also stated that the tools for congressional and 

stakeholder oversight could be enhanced by agencies reporting the 

methods for setting fees, including an accounting of program costs and 

assumptions it uses to project future program costs and fee collections.

In GAO’s 2011 survey of the 24 agencies covered by the CFO Act and 

OMB Circular No. A-25, 21 of the 23 agencies that responded reported 

charging more than 3,600 fees and collecting nearly $64 billion in fiscal 

year 2010, but agency responses indicated varying levels of adherence to 

the biennial review and reporting requirements of the CFO Act and OMB

Circular No. A-25.4

 

4

Twenty-three of the 24 departments covered by the CFO Act and OMB Circular No. A-25 

responded to GAO’s survey. The Department of Defense did not respond to GAO’s

survey. The Department of Education and the National Science Foundation reported no 

fees. The Department of Commerce’s National Technical Information Service is a feebased agency that charges more than 3 million different fees as a clearing house for 

government-funded, technical, engineering and business related information. The service 

reported these as a single fee. For all Department of Commerce Bureaus, other than the 

U.S. Patent and Trademark Office, fee collections are as of June 30, 2010, per the 

Department of Commerce. The U.S. Patent and Trademark Office reported collections for 

all of fiscal year 2010. There may be some duplication of reported fees as both the 

Department of Commerce and Department of State reported collecting fees for 

Commercial Services. The Mint reported a single fee and collection amount for the fees 

related to all Numismatic products which account for $3.25 billion of the Department of the

Treasury’s total collections.

The survey responses indicated that for most fees, 

agencies (1) had not discussed fee review results in annual reports, and 

(2) had not reviewed the fees and were inconsistent in their ability to 
 

Page 280 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

provide fee review documentation. Specifically, agencies reported that 

only 29 percent of the fees (1,064 fees), representing only 37 percent 

($23.6 billion) of total fee collections in fiscal year 2010 were discussed in 

their CFO annual report as directed by OMB Circular No. A-25. However, 

agencies reported reviewing 1,687 fees, which make up about 46 percent 

of the total 3,666 fees charged.5

 

5

Agency documentation of these fee reviews varied, limiting GAO’s ability to corroborate 

individual fee reviews and the recency and frequency of these fee reviews. 

This suggests that agencies are 

reviewing more fees than are being discussed in their annual reports. For 

agency responses, please see the table below. While these reviews may 

provide information for agency management and decision making, the 

extent to which this information is being shared with congressional 

decision makers or other stakeholders appears far more limited. When 

asked why they did not review individual reported fees, agencies most 

commonly chose “other” amongst the survey responses provided. When 

selecting “other,” agency-provided responses included that fees were 

based upon market prices, that the fee was set or administrated by 

another agency, or that they did not review some fees because the fee 

was set in legislation, and therefore they may not have the authority to 

revise the fee. Agencies also commonly selected responses that GAO 

provided, including minimal total fee collections or that fee requirements 

were not clear. GAO has previously reported that to ensure decision 

makers have complete information about program costs and activities, 

agencies must substantively review and report on all cost-based fees 

regularly, regardless of whether agencies have sole discretion for revising 

fee rates.
 

Page 281 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Agencies Reported Fiscal Year 2010 Total Fee Collections and Adherence to the CFO Act and OMB Circular No. A-25 

Guidance on Reviewing and Discussing Results of Biennial Fee Reviews

Dollars in millions

Agency

Reported FY 2010 total 

fee collections 

Reported percentage of 

fees and charges 

revieweda

Reported percentage of fees 

and charges reviewed 

biennially and discussed in 

CFO annual documents

Department of Health and Human Services $31,545 84% 30%

Department of the Treasury 9,789 97 67

Department of Homeland Security 8,784 87 96

Department of Agriculture 3,991 100 100

Department of Energy 2,498 86 0 

Department of Commerce 2,136 83 65

Department of State 1,896 100 73

Department of Interior 1,320 6 5 

Department of Justice 777 71 65

Social Security Administration 370 100 100

Department of Transportation 214 89 0 

Department of Labor 164 90 0 

Environmental Protection Agency 84 100 29

National Aeronautics and Space 

Administration

61 83 0 

Department of Veterans Affairs 51 80 47

Small Business Administration 16 100 100

Office of Personnel Management 8 0 0 

General Services Administration 6 50 0 

United States Agency for International 

Development

5 0 0 

Nuclear Regulatory Commission 2 100 50

Department of Housing and Urban 

Development

0.043 100 0 

Source: GAO summary of agency-reported data.

a

The third column, “reported percentage of fees and charges reviewed” is generally inclusive of fees 

and charges reported in the fourth column as reviewed biennially and discussed in CFO annual 

documents. 

Agencies were inconsistent in their ability to provide documentation for 

their fee reviews. For example, the Department of Agriculture provided 

documentation of reviews for all of its fees, while a few agencies did not 

provide any documentation. Even for agencies that provided 

documentation however, GAO found the reviews contained varying levels 

of detail and analysis, potentially limiting their value to decision makers. 

For one agency, it was not clear when the reviews had been conducted.

GAO has previously reported that decision makers must understand the 

decisions and tradeoffs made when designing fees to achieve specific 

policy goals and the costs of these decisions in determining if the policy 

goals were being met. Finally, most of the reporting agencies (16 out of 

23) reported reviewing at least some of their non-fee-funded programs for 

opportunities to initiate new fees for government services or goods.
 

Page 282 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Without regular comprehensive reviews, agencies and Congress may 

miss opportunities to make improvements to a fee’s design which, if left 

unaddressed, could contribute to inefficient use of government resources. 

For example, fee reviews could help ensure that fees are properly set to 

cover the total costs of those activities which are intended to be fully feefunded, thus eliminating the need for direct appropriations for those 

activities. Fee reviews may also

• allow agencies and Congress to identify where similar activities are 

funded differently; for example, one by fees and one by 

appropriations. One such example is the export control system, in 

which the State Department charges fees for the export of items on 

the U.S. Munitions List, while the Commerce Department does not 

charge fees for those items exported under its jurisdiction. Fee 

reviews may thereby assist in eliminating or managing inconsistent or 

overlapping funding sources for similar activities; and

• be a useful step toward examining whether the activities themselves 

are duplicative or overlapping.

As GAO reported in September 2007, fragmentation exists in the 

Department of Homeland Security’s One Face at the Border program, 

which integrated the customs, agriculture, and immigration air passenger 

inspection programs and is funded by three separate fees and general 

fund appropriations, creating administrative, operational, and oversight 

challenges. GAO also reported in February 2008 that fragmentation in 

Harbor Maintenance Fee administration between the Army Corps of 

Engineers and Department of Homeland Security’s U.S. Customs and 

Border Protection inhibits oversight. Further, regular reviews increase 

congressional and agency awareness of federal program costs, and 

therefore may increase incentives to reduce costs where possible.

Federal agencies reported collecting nearly $64 billion in federal user fees 

and charges in fiscal year 2010. Regular fee reviews can help the 

Congress and federal agencies identify opportunities to revise fees in 

ways that enhance user funding of goods or services above and beyond 

what is normally available to the public, and can be a useful step towards 

examining whether the activities themselves are duplicative or 

overlapping. GAO has ongoing work evaluating federal user fee reviews 

and opportunities to initiate new fees for government services or goods. 

The Director of the Office of Management and Budget (OMB) should use 

its budget reviews to ensure that agencies

• review their fee-funded programs biennially, as required by the CFO 

Act and consistent with GAO’s User Fee Design Guide, to help 

identify opportunities to improve the (1) efficiency, equity, revenue 

adequacy, and administrative burden of the fee design and (2) 

alignment of fee collections with program costs over time; and

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 283 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

• review their non-fee-funded programs on a regular basis, in 

accordance with OMB Circular No. A-25 guidance, and discuss the 

results in their CFO annual report. Regular reviews of non feefunded 

programs can help agencies and Congress determine whether 

programs funded with general fund revenues could be fully or partially 

funded with user fees.

Further, the Director of OMB could direct agencies to

• use a framework such as GAO’s User Fee Design Guide when 

designing or redesigning user fees.

GAO provided a draft of this report section to OMB as well as the 

Departments of State, Commerce, and Homeland Security. OMB as well 

as the Departments of State and Commerce provided technical 

comments, which were incorporated as appropriate. The Department of 

Homeland Security responded that it generally agreed.

OMB said that two of our three recommended actions—that is, that OMB 

use its budget reviews to (1) ensure that agencies review their fee-funded 

programs biennially and (2) review their non fee-funded programs—seem 

unnecessary. OMB Circular No. A-11 guidance directs agencies to 

comply with the user fee review requirements in OMB Circular No. A-25 

and the CFO Act. OMB did not comment on our third recommended 

action.

As we note above, agencies review less than half of the fees that they 

charge, and report the reviews of less than one-third of the fees charged. 

In addition, as noted above, 16 out of the 23 agencies told us that they 

review at least some of their non fee-funded programs to determine 

whether fees should be assessed.

GAO continues to believe that the recommended actions have merit. 

Especially in light of the significant impact user fees can have on the 

federal treasury given the current budgetary outlook, we believe that OMB 

should do more to ensure that agencies comply with OMB’s own 

guidance. We have added clarifying language regarding OMB’s direction 

to agencies. As part of its routine audit work, GAO will track the extent to 

which progress has been made to address the identified actions and 

report to Congress.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section, as well as work GAO 

conducted between May 2011 and February 2012. GAO surveyed 24 

agencies covered by the CFO Act to obtain (1) the number of fees the 

department or agency administered, (2) the basis for setting the fee 

amounts, (3) the aggregate amount of fees collected for fiscal year 2010, 

(4) the most recent CFO Act/OMB Circular No. A-25 review date, (5) 

documentation of fee reviews, and (6) in cases where reviews were not 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 284 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

conducted, the reasons why. Because this was not a sample survey, there 

are no sampling errors. However, the practical difficulties of conducting any 

survey may introduce nonsampling errors, such as variation in how 

respondents interpret questions and their willingness or ability to offer 

accurate responses. GAO took steps to minimize nonsampling errors. For 

example, prior to surveying agencies, GAO pretested the survey with three 

agencies with differing numbers of fees, as well as varying values of total 

collections, to ensure that GAO’s questions were clear and that the 

definitions used in the survey were correct and understandable to the 

respondents. GAO revised the final survey instrument based on the pretest 

results. Since this was a self-administered survey using a spreadsheet 

completed by the respondents, there was no need to have data entered by 

another party, thus eliminating another source of error. Finally, all 

calculations used in the analysis of the data were reviewed by another 

GAO analyst. GAO did not independently verify survey responses provided 

by the 23 agencies. GAO did not verify that the results of these fee reviews 

and any resulting proposals were discussed in the CFO annual report, per 

OMB Circular No. A-25. Some fees have more specific, statutorily-set 

review and reporting requirements, and are therefore not subject to the 

CFO Act’s or OMB Circular No. A-25’s biennial review. As a result, GAO 

did not independently verify whether agencies reported all of the applicable 

user fees.

Budget Issues: Better Fee Design Would Improve Federal Protective 

Service’s and Federal Agencies’ Planning and Budgeting for Security.

GAO-11-492. Washington, D.C.: May 20, 2011.

Budget Issues: Electronic Processing of Non-IRS Collections Has 

Increased but Better Understanding of Cost Structure Is Needed.

GAO-10-11. Washington, D.C.: November 20, 2009.

Federal User Fees: Additional Analyses and Timely Reviews Could 

Improve Immigration and Naturalization User Fee Design and USCIS 

Operations. GAO-09-180. Washington, D.C.: January 23, 2009.

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

May 29, 2008.

Federal User Fees: Substantive Reviews Needed to Align Port-Related 

Fees with the Programs They Support. GAO-08-321. Washington, D.C.: 

February 22, 2008.

Federal User Fees: Key Aspects of International Air Passenger Inspection 

Fees Should Be Addressed Regardless of Whether Fees Are 

Consolidated. GAO-07-1131. Washington, D.C.: September 24, 2007.

For additional information about this area, contact Susan J. Irving at 

(202) 512-6806 or irvings@gao.gov. 

Related GAO 

Products

Contact Information
 

Page 285 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

44. Internal Revenue Service Enforcement 

Efforts 

Enhancing the Internal Revenue Service’s enforcement and service capabilities can help reduce the gap 

between taxes owed and paid by collecting billions in tax revenue and facilitating voluntary compliance.

The financing of the federal government depends largely on the Internal 

Revenue Service’s (IRS) ability to collect federal taxes every year, which 

totaled $2.34 trillion in 2010. For the most part, taxpayers voluntarily 

report and pay their taxes on time with no direct enforcement and little 

interaction with IRS. However, the size and persistence of the tax gap—

estimated in 2012 for the 2006 tax year to be a $385 billion difference 

between the taxes owed and taxes IRS ultimately collected for that year—

highlight the need to make progress in improving compliance by those 

taxpayers who do not voluntarily pay what they owe. IRS’s enforcement 

of tax laws remains on GAO’s high-risk list.

Given that tax noncompliance ranges from simple math errors to willful 

tax evasion, no single approach is likely to fully and cost-effectively 

address the tax gap. A multifaceted approach to improving compliance—

one that covers both IRS’s enforcement and taxpayer service programs 

and also leverages external resources such as tax whistleblowers—could 

increase legally owed revenue collection by billions of dollars and result in 

cost savings for IRS. Without continued attention to IRS’s enforcement 

and taxpayer service efforts, taxpayers could feel that the tax system is 

not administered fairly and not everyone is paying their fair share, which 

could undermine voluntary compliance.

GAO identified a range of areas where IRS can improve its programs 

which can help it collect billions in tax revenue, facilitate voluntary 

compliance, or reduce IRS’s costs. These include pursuing stronger 

enforcement through increasing third-party information reporting and 

identifying and pursuing abusive tax avoidance transactions;1

• Expanding third-party information reporting improves taxpayer 

compliance and enhances IRS’s enforcement capabilities. The tax 

gap is due predominantly to taxpayer underreporting and 

underpayment of taxes owed. At the same time, taxpayers are much 

making 

more use of external resources such as tax whistleblowers to prevent and

detect compliance problems; and improving telephone and online 

services provided to taxpayers.

 

1

Abusive tax avoidance transactions range from tax schemes based on clearly frivolous 

arguments to highly technical and abusive tax shelters.

Why This Area Is 

Important

What GAO Found 
 

Page 286 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

more likely to report their income accurately when the income is also 

reported to IRS by a third party. By matching information received 

from third-party payers with what payees report on their tax returns, 

IRS can detect income underreporting, including the failure to file a 

tax return.

As GAO reported in August 2008, one area where information 

reporting could be expanded is payments made to contractors 

(payees) by owners of rental real estate (third-party payers). Like 

other businesses entities, under current law, taxpayers who rent out 

real estate are required to report to IRS expense payments for certain 

services, such as payments for property repairs, as long as their

rental activity is considered a trade or business (which includes 

activities engaged in for profit as well as activities by certain 

nonprofits). However, the law does not clearly spell out how to 

determine when rental real estate activity is considered a trade or 

business. Consequently, determining whether an information return 

should be filed requires a case-by-case analysis of when rental real 

estate is, or is not, a trade or business depending on the facts and 

circumstances for each taxpayer. As GAO reported in August 2008, 

without clear statutory language, it may be difficult for payers with 

rental real estate activity to determine if they are required to report 

certain expense payments to IRS, and as a result, it is possible that 

some third-party payers who should report do not. Expanding 

information reporting to cover payment for services by all owners of 

rental real estate would provide clarity on reporting requirements and 

improve payee compliance. 

In another case, as GAO reported in November 2010, under existing 

law, businesses (payers) must report to IRS payments for services 

they made to unincorporated persons or businesses, but payments to 

corporations generally do not have to be reported. Extending reporting 

to cover payments to corporations for services would increase payee 

compliance. Congress enacted a more expansive regime in March 

2010, covering goods as well as services, and repealed it in 2011. 

GAO believes the more narrow extension to include services, but not 

goods, provided by corporations—which would match the provision for 

unincorporated persons or businesses—remains an important option 

for improving compliance.2

 

2

In March 2010, pursuant to the Patient Protection and Affordable Care Act, information 

reporting requirements were expanded to cover payments for goods as well as services 

and payments to corporations. Pub. L. No. 111-148, § 9006. Later in September 2010, 

pursuant to the Small Business Jobs Act of 2010 information reporting requirements were 

expanded to include landlords who have generally not been considered to be engaged in 

a trade or business. Pub. L. No. 111-240, § 2101.These provisions were repealed by the 

Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy 

Overpayments Act of 2011. Pub. L. No. 112-9, §§ 2(a), 3 (2011).

 
 

Page 287 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

In 2010, the Joint Committee on Taxation estimated revenue 

increases for a 10-year period from third-party reporting of (1) rental 

real estate service payments to be $2.5 billion and (2) service 

payments to corporations to be $3.4 billion.

• Pursuing abusive tax avoidance transactions has been a longstanding tax evasion problem that results in potentially billions of 

dollars in tax losses. As GAO reported in May 2011, IRS had 

incomplete data on the results of abusive tax avoidance transaction 

(ATAT) related enforcement efforts, so it is unable to assess the 

effectiveness of these efforts. More could also be done to ensure 

compliance with ATAT disclosure requirements. For example, while 

investigations of those who promoted ATATs were often closed 

without penalties or injunctions to stop promoters, IRS had incomplete 

data on why these investigations were closed. During fiscal year

2011, IRS started tracking the amount of additional taxes collected as 

a result of taxpayer audits, where ATATs were at least one of the 

audited issues, but the amounts collected from ATAT issues alone 

could not be isolated.

Pursuant to the American Jobs Creation Act of 2004, IRS expanded 

requirements for both promoters and taxpayers to disclose their use of 

certain transactions and enhanced penalties for improper disclosure—

failure to disclose, delinquent disclosure, and incomplete disclosure. 

However, as GAO reported in May 2011, IRS did not know whether it 

received all the disclosures it should have from taxpayers and did not 

verify the completeness of those disclosures it received. IRS also did 

not track how quickly all those who promoted ATATs provided lists of 

their investors when either required or requested. Without complete 

data on enforcement outcomes or full disclosure from promoters and 

taxpayers, IRS is less able to assess the effectiveness of ATAT 

enforcement efforts, make informed resource allocation decisions, or 

identify transactions that merit auditing or penalties. 

• Leveraging external resources such as tax whistleblowers can 

contribute to taxpayer compliance. GAO reported in August 2011, IRS 

did not collect or report complete data on, nor have a systematic 

process to manage the timeliness of, processing claims from 

whistleblowers, in part, because of how it set up its claims tracking 

system. As a result, claims alleging millions or potentially billions of 

dollars in tax noncompliance may not receive the attention or 

resources they need. Moreover, without complete and accurate data 

or processes to follow up on claims that exceed established review 

time targets, IRS may not be able to identify aspects of the program 

that could be improved to more effectively address noncompliance. 

Collecting and reporting such data could also improve the 

transparency of the program, which may result in additional 

whistleblowers coming forward. 

• Improving taxpayer services can benefit voluntary compliance by 

making it easier for taxpayers to pay what they owe. As GAO reported 
 

Page 288 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

in December 2011, determining the costs and benefits of enhancing 

certain services for taxpayers, such as providing more automated 

telephone applications, could lead to faster service for taxpayers and 

lower IRS costs. Similarly, GAO also reported that completing a 

comprehensive online services plan might include an assessment of 

and justification for giving taxpayers the ability to access and update 

account information online, which may simultaneously improve 

taxpayer services and lower IRS’s costs. In addition to reducing costs, 

providing more automated taxpayer services could increase revenue 

collection by supporting greater voluntary compliance and allow 

resources to be shifted to other priorities. 

GAO continues to suggest Congress consider expanding third-party 

information reporting, which improves taxpayer compliance, by amending 

the Internal Revenue Code. GAO recommended that Congress may wish 

to

• make owners of rental real estate subject to the same payment 

reporting requirements regardless of whether they engaged in a trade 

or business under current law (GAO-08-956); and

• require payers to report service payments to corporations, thereby 

reducing payers’ burden to determine which payments require 

reporting (GAO-11-218T, GAO-09-238). 

IRS has agreed with and taken action on some GAO recommendations— 

for example, by providing taxpayers with rental real estate activity 

additional guidance on their reporting obligations. However, other 

recommendations remain to be addressed. Specifically, to increase 

revenue, reduce costs, and promote voluntary compliance, GAO 

recommended that IRS:

• track the examination results for ATAT versus non-ATAT issues 

separately and check whether taxpayers filed all required ATATrelated disclosure forms (GAO-11-493); 

• collect and report more information on the whistleblower program and 

establish a process to follow up on claims that exceed review time 

targets (GAO-11-683); 

• determine the costs and benefits of creating automated telephone 

applications and automate those where benefits exceed the costs 

(GAO-12-176); and

• finalize a more comprehensive plan for online services, including an 

assessment of granting taxpayers the ability to update their account 

information online (GAO-12-176). 

These actions can lead to increased revenue collections and cost savings 

totaling billions of dollars, which would help reduce the $385 billion tax 

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 289 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

gap. Although precise estimates of total cost savings are not available, for 

just the two congressional actions cited above, the Joint Committee on 

Taxation estimated revenue increases of $5.9 billion over 10 years. As 

part of its routine audit work, GAO will continue to track the extent to 

which progress has been made to address the identified actions and 

report to Congress.

GAO provided a draft of its previously issued reports to IRS for review

and comment. IRS generally agreed with GAO’s recommendations on 

checking taxpayer ATAT filing obligations, return preparer oversight, and 

whistleblower information and processing but has not yet completed the 

recommended actions. IRS said it will consider reporting summary 

whistleblower statistics and improving online taxpayer services. Finally, 

IRS agreed that the recommendations regarding tracking ATAT issues 

and determining the costs and benefits of automating selected telephone 

applications had merit, but that resources for tracking or telephone 

automation were not available.

The information contained in this analysis is based on findings from the

products listed in the related GAO products section.

2011 Filing Season: Processing Gains, but Assistance Could Be 

Enhanced by More Self-Service Tools. GAO-12-176. Washington, D.C.: 

December 15, 2011.

Tax Whistleblowers: Incomplete Data Hinders IRS’s Ability to Manage 

Claim Processing Time and Enhance External Communication. 

GAO-11-683. Washington, D.C.: August 10, 2011.

Abusive Tax Avoidance Transactions: IRS Needs Better Data to Inform 

Decisions about Transactions. GAO-11-493. Washington, D.C.: May 12, 

2011.

High Risk Series: An Update. GAO-11-278. Washington, D.C.: February 

2011.

Small Businesses: Tax Compliance Benefits and Opportunities to Mitigate 

Costs on Third Parties of Miscellaneous Income Reporting Requirements. 

GAO-11-218T. Washington, D.C.: November 18, 2010.

Tax Gap: IRS Could Do More to Promote Compliance by Third Parties 

with Miscellaneous Income Reporting Requirements. GAO-09-238. 

Washington, D.C.: January 28, 2009.

Tax Gap: Actions That Could Improve Rental Real Estate Reporting 

Compliance. GAO-08-956. Washington, D.C.: August 28, 2008.

Agency Comments

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 
 

Page 290 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

For additional information about this area, contact Michael Brostek or 

James R. White at brostekm@gao.gov or whitej@gao.gov or 

(202) 512-9110. 

Contact Information
 

Page 291 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

45. Medicare Advantage Payment

The Centers for Medicare & Medicaid Services could achieve billions of dollars in additional savings by better 

adjusting for differences between Medicare Advantage plans and traditional Medicare providers in the reporting 

of beneficiary diagnoses.

In fiscal year 2010, the federal government spent about $113 billion on 

the Medicare Advantage program, a private plan alternative to the original 

Medicare program that covers about a quarter of Medicare beneficiaries. 

Medicare Advantage plans are paid a fixed monthly amount to provide 

beneficiaries with the same services as traditional Medicare. Most of 

these plans receive larger payments than would be required to provide 

traditional Medicare services. This allows them to provide additional 

services not covered by traditional Medicare.

The Centers for Medicare & Medicaid Services (CMS), the agency that 

administers Medicare, adjusts payments to Medicare Advantage plans 

based on the health status of each plan’s enrollees. This adjustment is 

intended to provide higher payments for sicker patients and lower 

payments for those who are less sick. CMS calculates a risk score—

which is a relative measure of health status—for every beneficiary. The 

risk score is based on a beneficiary’s demographic characteristics, such 

as age and gender, and major medical conditions. To obtain information 

on the medical conditions of beneficiaries in traditional Medicare, CMS 

generally analyzes diagnoses—numerically coded by providers into 

Medicare defined categories—on the claims that providers submit for 

payment. For beneficiaries enrolled in Medicare Advantage plans, which 

do not submit claims, CMS requires plans to submit diagnostic codes for 

each beneficiary. Analysis has shown that risk scores are higher for 

Medicare Advantage beneficiaries than for beneficiaries in traditional 

Medicare with the same characteristics, and CMS has taken steps to 

reduce Medicare Advantage payments, saving $2.7 billion in 2010.

Risk scores for beneficiaries with the same demographic characteristics 

and health conditions should be identical, regardless of whether the 

beneficiaries are in a Medicare Advantage plan or traditional Medicare. 

This will be true if Medicare Advantage and traditional providers code 

medical diagnoses with the same level of reliability and completeness. 

However, Medicare Advantage plans and providers in traditional 

Medicare may code diagnoses differently. Medicare Advantage plans 

have a financial incentive to ensure that all relevant diagnoses are coded, 

as this can increase beneficiaries’ risk scores and, ultimately, payments 

to the plans. Many traditional Medicare providers are paid for services 

rendered, and providers have less incentive to code all relevant 

diagnoses. If Medicare Advantage risk scores are higher than traditional 

Medicare scores for beneficiaries with the same demographic 

characteristics and medical conditions simply because Medicare 

Advantage diagnostic coding is more comprehensive, then CMS’s 

Why This Area Is 

Important

What GAO Found
 

Page 292 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

payment adjustment will not be accurate and Medicare Advantage 

payments will be too high.

Policymakers have expressed concern that risk scores for Medicare 

Advantage beneficiaries have grown at a faster rate than those for 

traditional Medicare beneficiaries, and some believe that systematic 

differences in coding diagnoses have contributed to this growth. The 

Deficit Reduction Act of 2005 directed CMS to conduct an analysis and 

adjust risk scores for differences in coding practices, to the extent that 

such differences could be identified in 2008, 2009, and 2010. The Health 

Care and Education Reconciliation Act of 2010 directed CMS to continue 

adjusting risk scores until the agency implements risk adjustment using 

Medicare Advantage data. In 2010, CMS estimated that 3.41 percent of 

Medicare Advantage risk scores were due to differences in diagnostic 

coding practices, and it reduced the scores by 3.41 percent, thereby 

saving $2.7 billion.

As GAO reported in January 2012, three major shortcomings exist in 

CMS’s method for adjusting Medicare Advantage payments to reflect 

differences in diagnostic coding practices between Medicare Advantage 

and traditional Medicare. A revised methodology that addressed these 

shortcomings could have saved Medicare between $1.2 billion and $3.1 

billion in 2010 in addition to the $2.7 billion in savings that CMS’s 3.41 

percent adjustment produced—a total savings of between $3.9 billion and 

$5.8 billion. GAO expects savings in 2011 and future years will be 

greater. However, CMS has continued to use, or plans to use, its 2010 

adjustment of 3.41 percent in 2011 and 2012.

First, CMS did not use the most recent data for its estimates. For 2010, 

the agency did not incorporate in its estimates 2008 data, the most recent 

data available. Similarly, the agency did not incorporate 2009 and 2010 

data as it became available to update its estimates for 2011 and 2012. 

The most recent risk score data used by CMS in any of these estimates 

was 2007.

Second, CMS assumed that the annual impact of coding differences 

remained constant relative to coding differences from 2004 to 2007, 

despite evidence that the impact was increasing over time. Although 

CMS’s 2010 estimate accounted for the cumulative impact of coding 

differences over the 3 prior years, CMS did not account for any additional 

years of accumulated impact in its 2011 or 2012 estimates.

Third, CMS only accounted for differences in age and mortality between 

the Medicare Advantage and traditional Medicare populations. GAO 

accounted for additional beneficiary characteristics, such as sex, 

diagnoses as a proxy for health status, Medicaid enrollment status, 

beneficiary residential location, and whether the original reason for 

Medicare entitlement was disability, thereby improving the accuracy of the 

estimate.
 

Page 293 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

CMS could enhance its efforts to estimate effects of coding differences 

between Medicare Advantage and traditional Medicare and realize even 

greater cost savings than the $2.7 billion that it has identified. GAO 

demonstrated a methodology which incorporated additional data and 

identified additional savings—$1.2 billion to as much as $3.1 billion in 

payment reductions to Medicare Advantage plans. In January, 2012, 

GAO made the following recommendations:

To help ensure appropriate payments to Medicare Advantage plans and 

improve the accuracy of the adjustment made for differences in coding 

practices over time, the Secretary of Health and Human Services should 

direct the Administrator of CMS

• incorporate the most recent data available in its estimates and identify 

and account for all years of diagnostic coding differences that could 

affect the payment year for which any adjustment is made;

• take into account the upward trend of annual impact of coding 

differences in its estimates; and

• account, insofar as possible, for all relevant differences in beneficiary 

characteristics between the Medicare Advantage and traditional 

Medicare populations.

GAO provided a draft of its January 2012 report to the Department of 

Health and Human Services. The Department of Health and Human 

Services did not comment on GAO’s recommendations but provided 

general and technical comments, which were incorporated as 

appropriate. The Department of Health and Human Services 

characterized GAO’s results as “similar” to those obtained by CMS, and 

found GAO’s methodological approach and findings informative. 

The information contained in this analysis is based on findings from the 

report listed in the related GAO product section. GAO estimated the 

impact of coding differences between Medicare Advantage and traditional 

Medicare on Medicare Advantage risk scores and payment to plans. GAO 

compared risk score growth for Medicare Advantage beneficiaries with an 

estimate of what risk score growth would have been if they had been in 

traditional Medicare.

Medicare Advantage: CMS Should Improve the Accuracy of Risk Score 

Adjustments for Diagnostic Coding Practices. GAO-12-51. Washington, 

D.C.: January 12, 2012.

For additional information about this area, contact James C. Cosgrove at 

(202) 512-7114 or cosgrovej@gao.gov. 

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO Product

Contact Information
 

Page 294 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

46. Medicare and Medicaid Fraud Detection 

Systems 

The Centers for Medicare & Medicaid Services needs to ensure widespread use of technology to help detect 

and recover billions of dollars of improper payments of claims and better position itself to determine and 

measure financial and other benefits of its systems.

GAO has designated Medicare and Medicaid as high-risk programs, in 

part due to their susceptibility to improper payments—estimated to be 

about $65 billion in fiscal year 2011.1

To integrate data about all types of Medicare and Medicaid claims and 

improve its ability to detect fraud, waste, and abuse in these programs, 

CMS initiated two information technology programs: the Integrated Data 

Repository (IDR) and One Program Integrity (One PI). IDR is intended to 

provide a centralized repository of claims data for all Medicare and 

Medicaid programs, and One PI is a set of tools that enables CMS’s 

program integrity contractors and staff to access and analyze data 

retrieved from IDR. The intent of these programs is to provide enhanced 

capabilities and support to help CMS achieve goals for improving 

outcomes of its program integrity initiatives. Among other things, these 

enhancements are intended to improve CMS’s ability to detect and 

recover funds lost to improper payments, and according to CMS officials, 

are expected to provide financial benefits of more than $21 billion by the 

end of fiscal year 2015.

As the administrator of these 

programs, the Centers for Medicare & Medicaid Services (CMS) is 

responsible for safeguarding them from loss and for performing functions 

intended to help ensure the integrity of the programs, such as reviewing 

paid claims to identify patterns that may indicate cases of fraud, waste, 

and abuse, or other payment errors. These and other program integrity 

functions are conducted by CMS staff and several types of contractors.

As GAO reported in June 2011, CMS had developed and begun using 

both IDR and One PI, but was not yet positioned to identify, measure, or 

track benefits realized from these programs. Although IDR had been 

implemented and in use since 2006, it did not include all the data that 

were planned to be incorporated by fiscal year 2010. Specifically, while 

IDR included most types of Medicare claims data, it did not include the 

Medicaid data needed to help analysts detect improper payments of 

Medicaid claims. IDR also did not include data from other CMS systems 

that store and process data related to the entry, correction, and 

 

1

Improper payments may be made as a result of several causes, such as submissions of 

duplicate claims or fraud, waste, and abuse.

Why This Area Is 

Important

What GAO Found
 

Page 295 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

adjustment of claims prior to payment. These data are needed to help the 

agency’s program integrity analysts prevent improper payments. 

According to program officials, the data were not incorporated because of 

obstacles introduced by delays in funding and technical issues. 

Specifically, funding to support activities to incorporate data from the 

other CMS systems was not approved until summer 2010. In November 

2011, program officials stated that they had begun incorporating these 

data in September 2011 and planned to make them available to program 

integrity analysts in spring 2012.

Regarding the Medicaid data, IDR officials stated that they did not 

account for difficulties and resulting delays associated with integrating 

into IDR the various types and formats of data stored in disparate state 

systems. Further, the agency did not finalize plans or develop reliable 

schedules for its efforts to incorporate these data. In particular, program 

officials did not consider certain risks and obstacles, such as technical 

challenges, as they developed schedules for implementing IDR. Until it 

does so, CMS may face additional delays in making available all the data 

that are needed to support enhanced program integrity efforts.

Additionally, CMS developed and deployed to users its One PI system—a 

web-based portal that is to provide CMS program integrity analysts a 

single point of access to data contained in IDR, along with tools for 

analyzing those data. Nonetheless, few program integrity analysts were 

using the system. Specifically, One PI program officials planned for 639 

analysts to be using One PI by the end of fiscal year 2010; however, only 

41—less than 7 percent—were actively using the portal and tools as of 

October 2010.

According to program officials, the agency had not trained its broad 

community of analysts to use the system because of delays introduced 

when they took time to redesign initial training plans, which were found to 

be insufficient. Specifically, the initial plan provided training for the use of 

the One PI system and IDR data in a 3-and-a-half-day course, whereas 

the redesigned plan includes courses on each of the components and 

allows trainees time to use them to reinforce learning before taking 

additional courses. Because of these delays, the initial use of the system 

was limited to a small number of CMS staff and contractors. In updating 

the status of the training efforts in November 2011, CMS officials reported 

that a total of 215 program integrity analysts had been trained and were 

using One PI.2

 

2

We did not validate the data provided in November 2011.

However, until program officials finalize plans and 

schedules for training all intended users and expanding the use of One 

PI, the agency may continue to experience delays in reaching widespread 

use of the system and realizing expected financial benefits.
 

Page 296 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Further, while CMS made some progress toward its goals to provide a 

single repository of data and enhanced analytical capabilities for program 

integrity efforts, the agency was not positioned to identify, measure, or 

track financial benefits or progress toward meeting program goals as a 

result of its efforts. Specifically, although IDR program officials stated that 

they avoided technology costs as a result of implementing IDR, they did 

not identify financial benefits of using IDR based on the recovery of 

improper payments.

According to agency officials, CMS expected to realize more than $21 

billion in benefits as a result of using One PI from 2006 through 2015. 

These benefits were expected to accrue as CMS’s broad community of 

program integrity analysts used the systems to identify increasing 

numbers of improper payments. However, these officials further stated 

that because the agency did not meet its goal for widespread use of One 

PI, there were not enough data available to quantify benefits attributable 

to the use of the system. In this regard, we found that CMS did not 

produce outcomes that positioned the agency to identify or measure 

financial benefits, or to gauge its progress toward achieving the $21 

billion in benefits that it expected.

CMS officials also did not develop quantifiable measures that could be 

used to determine whether the agency was making progress toward 

meeting program goals through the use of One PI. For example, 

performance measures for one PI included increases in the detection of 

improper payments for Medicare Parts A and B claims. However, 

program integrity officials stated that measures were not quantified 

because they had not identified ways to determine the extent to which 

increases in the detection of errors could be attributed to the use of One 

PI. Additionally, the limited use of the system did not generate enough 

data to quantify the amount of funds recovered from improper payments.

To better position the agency to measure, gauge, and take actions to help 

ensure the program’s success toward achieving the $21 billion in financial 

benefits that program integrity officials projected, GAO recommended in 

June 2011 that the Administrator of CMS

• finalize plans and schedules for incorporating additional data into IDR 

that consider risks and obstacles to the program;

• implement and manage plans for incorporating data into IDR to meet 

schedule milestones;

• establish plans and schedules for training all program integrity 

analysts who are intended to use One PI;

• establish and communicate deadlines for program integrity 

contractors to complete training and use One PI in their work;

• conduct training in accordance with plans and deadlines;

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 297 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

• define any measurable financial benefits expected from the 

implementation of IDR and One PI; and

• establish measures for IDR and One PI that gauge progress toward 

meeting program goals.

GAO provided a draft of its June 2011 report to CMS for review and 

comment. CMS agreed with all of GAO’s recommendations and identified 

steps agency officials were taking to implement them. GAO expects to 

conduct additional work to determine whether CMS has addressed its 

recommendations and identified financial benefits and progress toward 

meeting agency goals resulting from the implementation of IDR and One 

PI for program integrity purposes. As part of its routine audit work, GAO 

will track agency actions to address these recommendations and report to 

Congress.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. GAO reviewed IDR 

and One PI system and program management plans and other 

documents and compared them to key practices. GAO also interviewed 

program officials, analyzed system data, and reviewed reported costs and 

benefits.

Fraud Detection Systems: Centers for Medicare and Medicaid Services 

Needs to Expand Efforts to Support Program Integrity Initiatives.

GAO-12-292T. Washington, D.C.: December 7, 2011.

Fraud Detection Systems: Centers for Medicare and Medicaid Services 

Needs to Ensure More Widespread Use. GAO-11-475. Washington, D.C.: 

June 30, 2011.

For additional information about this area, contact Valerie C. Melvin at 

(202) 512-6304 or melvinv@gao.gov. 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 298 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

47. Border Security

Delaying proposed investments for future acquisitions of border surveillance technology until the Department of 

Homeland Security better defines and measures benefits and estimates life-cycle costs could help ensure the 

most effective use of future program funding.

Securing the Arizona portion of the approximately 2,000-mile southwest 

border that the United States shares with Mexico—while keeping illegal 

flows of people and drugs elsewhere under control—is a top priority for 

the Department of Homeland Security’s (DHS) U.S. Customs and Border 

Protection (CBP).

Following the 2011 cancellation of CBP’s costly Secure Border Initiative 

Network (SBInet), CBP has taken steps to develop and implement a new 

Arizona Border Surveillance Technology Plan (the Plan) for the remainder 

of the Arizona border. This Plan is the first step in a multiyear, multibilliondollar effort to secure the southwest border. The Plan is intended to guide 

the identification, acquisition, and deployment of additional surveillance 

technology, as well as any modifications needed to adjust them to varying 

terrain along the Arizona border to enhance situational awareness of 

illegal intrusions. CBP requested $242 million to fund the new Plan for 

fiscal year 2012 and estimates that the total costs of acquiring and 

maintaining all of the proposed new systems for the Arizona border over 

their expected 10-year life cycle will be about $1.5 billion.

CBP began development of SBInet in 2005 as a combination of 

surveillance technologies that relied primarily on radar and camera towers 

to create a “virtual fence” along the southwest border in order to enhance 

CBP’s capability to detect, identify, classify, track, and respond to illegal 

breaches at and between land ports of entry. After 5 years and a cost of 

nearly $1 billion, SBInet systems are now deployed along the 53 miles of 

Arizona’s 378-mile border with Mexico that represent the highest-risk area 

for illegal entry attempts.

Since its inception, SBInet experienced continued and repeated technical 

problems, cost overruns, and schedule delays, which raised serious 

questions about the program’s ability to meet CBP’s needs for 

surveillance technology along the border. GAO issued 26 reports and 

testimonies identifying operational and program management 

weaknesses that contributed to SBInet’s performance shortfalls, including 

cost overruns and schedule slippages. For example, as GAO reported in 

November 2008 and June 2010, deficiencies existed in CBP’s timely 

preparation and completion of key acquisition documents essential to 

setting operational requirements, identifying and mitigating risks, and 

establishing the cost, schedule, and performance requirements of the 

Why This Area Is 

Important
 

Page 299 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

project and the technology to be delivered.1

Given the previously reported challenges and eventual cancellation of 

SBInet, and the fact that similar challenges could affect CBP’s current 

plan to acquire and deploy surveillance technology, GAO analyzed CBP’s 

business case for its new initiative. This business case is important in 

light of DHS’s overall management of acquisitions. GAO has reported that 

DHS faces significant challenges in managing its acquisitions, including 

programs not meeting their cost, schedule, and performance 

expectations. Further, strengthening its acquisition management process 

would help DHS to deliver critical mission capabilities that meet identified 

needs on time and within budget, including helping to reduce the cost 

overruns and schedule delays that DHS continues to experience in many 

of the major acquisition programs GAO has reviewed.

In May 2010, GAO concluded 

that it was unclear whether the department’s pursuit of SBInet was a costeffective course of action, and whether it would produce expected results 

on time and within budget. In part based on these concerns, the 

Secretary of Homeland Security announced the cancellation of further 

procurements of SBInet systems in January 2011.

2

CBP’s proposed approach is at an increased risk of not cost-effectively 

accomplishing its goal in support of Arizona border security because CBP 

has not provided support for its business case for investing in the Plan. 

As GAO reported in November 2011, CBP has taken some steps to 

develop a business case for the Plan, but the agency has not (1) 

documented the analysis justifying the specific types, quantities, and 

deployment locations of border surveillance technologies proposed in the 

Plan in accordance with Standards for Internal Control in the Federal 

Government; (2) defined the mission benefits or developed performance 

metrics to assess its implementation of the Plan; or (3) developed a 

robust life-cycle cost estimate that can be relied on for the purposes of 

budget requests for fiscal year 2012 and beyond.

CBP program officials developed and proposed the Plan without 

documenting the analysis justifying the specific types, quantities, and 

deployment locations of border surveillance technologies proposed in the 

Plan. These technologies include a mix of currently employed 

technologies, such as unattended ground sensors, as well as new 

alternatives, such as Integrated Fixed Tower systems (that include fixed 

towers, cameras and radar, a data communications network, facilities 

 

1

GAO, Department of Homeland Security: Billions Invested in Major Programs Lack 

Appropriate Oversight, GAO-09-29 (Washington, D.C.: Nov. 18, 2008) and Department of 

Homeland Security: Assessments of Selected Complex Acquisitions, GAO-10-588SP

(Washington. D.C.: June 30, 2010). 

2

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

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

GAO-10-588SP. 

What GAO Found
 

Page 300 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

upgrades, information displays, and an information management system). 

According to the Plan, CBP will begin acquiring and deploying three 

Integrated Fixed Tower systems in Arizona in 2012, with two others to be 

deployed by 2015, depending on funding availability. Standards for 

Internal Control in the Federal Government call for agencies to promptly 

record and clearly document transactions and significant events to 

maintain their relevance and value to management in controlling 

operations and making decisions and to ensure that agency objectives 

are met. The senior CBP official responsible for the program’s 

acquisitions told GAO that he believed the process used to develop and 

support the plan justified acquisition decisions called for in the Plan.

However, documenting the analysis justifying the specific types, 

quantities, and deployment locations of border surveillance technologies 

proposed in the Plan would allow an independent party to confirm the 

process followed, and to assess the validity of the decisions made.

The Secretary of Homeland Security reported to Congress in January 

2011 that the Plan is expected to provide situational awareness for the 

entire Arizona border by 2014. However, CBP officials have not yet 

defined the expected benefits or developed measurable and quantifiable 

performance metrics which could show progress toward achieving that 

goal.3 In September 2011, CBP officials reported that they are developing 

new measures to determine whether and how investments impact border 

security. They acknowledged that since large investments have been 

made in border security, it is critical to assess the impacts these 

investments have had on improving border security, as well as projecting 

the additional impact future investments will have on their ability to 

manage the borders. However, CBP officials had not yet determined the 

key attributes of these new measures. The Clinger-Cohen Act of 1996 

and Office of Management and Budget (OMB) guidance emphasize the 

need to ensure that information technology investments produce tangible, 

observable improvements in mission performance.4 Additionally, the 

GPRA Modernization Act of 2010 (GPRAMA) established a new, crosscutting, and integrated framework for achieving results and improving 

government performance.5

 

3

According to OMB Circular A-11, performance measurement should include program 

accomplishments in terms of outputs (quantity of products or services provided) and 

outcomes (results of providing outputs in terms of effectively meeting intended agency 

mission objectives), as well as indicators, statistics or metrics used to gauge program 

performance. See OMB, Preparation, Submission, and Execution of the Budget, Circular 

A-11 (Washington, D.C.: August 2011).

Without defining the expected benefit or 

establishing metrics, CBP’s ability to assess the effectiveness of the Plan 

as it is implemented may be limited.

4

Clinger-Cohen Act of 1996, 40 U.S.C. §§ 11101-11703, and OMB Circular A-130, 

Management of Federal Information Resources (Washington, D.C., Nov. 30, 2000). 

5

Pub. L. No. 111-352, 124 Stat. 3866 (2011).
 

Page 301 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Finally, while CBP officials have taken steps to develop a cost estimate 

for the Plan, because they did not determine a level of confidence around 

the estimate, it may not be realistic or sufficient for the purposes of 

budget requests for fiscal year 2012 or beyond. GAO reported that CBP’s 

cost estimate did not fully comply with related best practices. GAO’s Cost 

Estimating and Assessment Guide and OMB guidance emphasize that 

reliable cost estimates are important for program approval and continued 

receipt of annual funding. High-quality cost estimates should be well 

documented, comprehensive, accurate, and credible.6 Specifically, GAO 

reported that CBP officials took steps to develop a comprehensive and 

accurate cost estimate. However, the actual data used to determine the 

estimate were not always shown. As a result of insufficient 

documentation, the validity and reliability of the estimate cannot be 

verified. In addition, because CBP officials did not follow other best 

practices for cost estimation, the estimate for the plan is likely to be 

unrealistic. Until CBP determines a robust life-cycle cost estimate for the 

Plan in accordance with best practices, it will be difficult for CBP to 

provide reasonable assurance regarding the reliability of CBP’s expected 

future cost estimates for border surveillance technology.

To increase the likelihood of successful implementation of the Arizona 

Border Surveillance Technology Plan, minimize performance risks 

associated with the new approach, help justify program funding, and 

increase the reliability of CBP’s cost estimate, GAO recommended in 

November 2011 that the Commissioner of CBP

• determine the mission benefits to be derived from implementation of 

the plan,

• develop and apply key attributes for metrics to assess program 

implementation; and

• update its cost estimate for the Plan using best practices.

In addition, Congress may wish to consider 

• limiting future program funding until CBP has more fully defined the 

benefits and costs of its new Plan for Arizona. As part of our routine 

audit work, we will track agency actions to address these 

recommendations and report the results to Congress.

 

6

GAO, Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009).

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 302 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

GAO provided a draft of its November 2011 report as well as this report 

section for review and comment. DHS agreed with GAO 

recommendations and identified steps officials planned to take to 

implement them, along with estimated dates for their completion. 

Regarding the recommendations that CBP determine the mission benefits 

to be derived from implementation of the Plan and develop and apply key 

attributes for metrics to assess the program’s implementation, DHS 

concurred and stated that CBP plans to develop a set of measures by 

April 30, 2012, that will assess the effectiveness and mission benefits of 

future technology investments. Such action should address the intent of 

the recommendations. Regarding the recommendation related to 

updating CBP’s life-cycle cost estimate using best practices, DHS 

concurred and stated that CBP was preparing individual project cost 

estimates for the two largest elements of the Plan and will complete these 

actions by April 30, 2012. While these actions are positive steps, they do 

not fully address the recommendation that DHS implement best practices 

for cost estimates for the entire Plan, which is still needed to fully 

understand the impacts of integrating these separate projects. 

This information contained in this analysis is based on findings from the 

products listed in the related GAO products section. GAO reviewed key 

program planning documents CBP relied on to support its new approach 

to identifying, acquiring, and deploying surveillance technology and 

compared them with requirements in DHS acquisition regulations. GAO 

also interviewed CBP officials responsible for assessing the need for and 

documenting the cost, operational effectiveness and suitability of 

proposed systems to support its Arizona Border Surveillance Technology 

Plan, and for identifying appropriate metrics to assess progress in border 

security. GAO reviewed cost and budget documents CBP relied on to 

support cost estimates for technology alternatives and interviewed 

program officials and contractors responsible for estimating the cost of 

future investments in surveillance technology, specifically the life-cycle 

approach, requirements development and management, test 

management, and risk management. GAO also compared this information 

to relevant federal guidance and leading industry practices. 

Arizona Border Surveillance Technology: More Information on Plans and 

Costs Is Needed Before Proceeding. GAO-12-22. Washington, D.C.: 

November 4, 2011.

Border Security: Preliminary Observations on the Status of Key 

Southwest Border Technology Programs. GAO-11-448T Washington 

D.C.: March 15, 2011. 

Secure Border Initiative: DHS Needs to Strengthen Management and 

Oversight of Its Prime Contractor. GAO-11-6. Washington, D.C.: October 

18, 2010.

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 
 

Page 303 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Secure Border Initiative: DHS Needs to Reconsider Its Proposed 

Investment in Key Technology Program. GAO-10-340. Washington, D.C.: 

May 5, 2010.

Secure Border Initiative: DHS Needs to Address Testing and 

Performance Limitations That Place Key Technology Program at Risk. 

GAO-10-158. Washington, D.C.: January 29, 2010.

Secure Border Initiative: Technology Deployment Delays Persist and the 

Impact of Border Fencing Has Not Been Assessed. GAO-09-1013T. 

Washington, D.C.: September 17, 2009.

Secure Border Initiative: DHS Needs to Address Significant Risks in 

Delivering Key Technology Investment. GAO-08-1148T. Washington, 

D.C.: September 10, 2008.

Secure Border Initiative: Observations on the Importance of Applying 

Lessons Learned to Future Projects. GAO-08-508T. Washington, D.C.: 

February 27, 2008.

Secure Border Initiative: SBInet Planning and Management 

Improvements Needed to Control Risk. GAO-07-504T. Washington, D.C.: 

February 27, 2007.

For additional information about this area, contact Rebecca Gambler at 

(202) 512-6912 or gamblerr@gao.gov. Contact Information
 

Page 304 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

48. Passenger Aviation Security Fees

Options for adjusting the passenger aviation security fee could further offset billions of dollars in civil aviation 

security costs.

According to the President’s 2011 National Counterterrorism Strategy, 

aviation security and screening is an essential tool in the country’s ability 

to detect, disrupt, and defeat plots to attack the homeland.1 Civil aviation

security includes, among other things, screening passengers and their 

carry-on and checked baggage for explosives, weapons, and other 

prohibited items. To help offset the costs associated with providing this 

security, the Aviation and Transportation Security Act authorized the 

Transportation Security Administration (TSA) to impose two securityrelated fees: a passenger security fee and an air carrier security fee 

(Aviation Security Infrastructure Fee).2

TSA imposed the passenger security fee—a uniform fee on passengers 

of U.S. and foreign air carriers originating at airports in the United 

States—in February 2002 at $2.50 per enplanement, capped at $5.00 per 

one-way trip, which are the maximum amounts allowed under the Aviation 

and Transportation Security Act. In addition, in February 2002, TSA 

imposed the air carrier security fee—a fee imposed on air carriers to 

further offset the costs of civil aviation security and capped at the amount 

paid by air carriers for screening passengers and property in calendar 

year 2000.3

The fees collected offset amounts appropriated to TSA for aviation 

security. In his fiscal year 2012 budget request, the President requested 

that Congress increase the passenger security fee but did not request an 

increase in the air carrier fee. In light of the administration’s focus on the 

passenger security fee and the possibility that the basis for calculating the 

cost to air carriers for screening passengers and property in 2000 could 

 

1

National Strategy for Counterterrorism (Washington, D.C.: June 28, 2011).

2

See Pub. L. No. 107-71, § 118(a) (2001) (codified as amended at 49 U.S.C. § 44940). In 

general, the fees collected offset the account that finances the activities and services for 

which the fee is imposed. Specifically, the fees collected offset amounts appropriated to 

TSA’s “aviation security” account. See, e.g., Department of Homeland Security 

Appropriations Act, 2010, Pub. L. No. 111-83 (2009). See also 49 U.S.C. § 44940(f)(1). 

3

See 49 U.S.C. § 44940(a)(2) (authorizing the collection of the air carrier fees if passenger 

security fee collections were insufficient to pay for the costs of providing civil aviation 

security services). TSA collected approximately $280 million in air carrier fees in fiscal 

year 2010 and expects to have collected an estimated $420 million in fiscal year 2011 and 

each fiscal year thereafter. 

Why This Area Is 

Important
 

Page 305 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

remain in dispute, for the purposes of this summary, GAO will focus on 

options for offsetting aviation security costs related to the passenger fee.4

In the 10 years since TSA imposed the passenger security fee, TSA has 

developed additional measures to help mitigate potential risks to the 

nation’s civil aviation security system, such as enhanced passenger 

screening technologies, among other programs, which have contributed 

to increases in the costs of aviation security to the federal government.

Several options exist for revising passenger security fees to help further 

offset civil aviation security costs. From fiscal years 2002 through 2011, 

TSA collected about $18 billion in passenger and air carrier security fees, 

compared to the approximately $63 billion appropriated for aviation 

security activities over the same time frame; thus, security fees offset 

about 29 percent of amounts appropriated for aviation security-related 

activities during this time frame. The figure below shows the difference 

between the funds appropriated for aviation security and the aviation 

security fees collected since fiscal year 2002.

 

4

See, e.g., Southwest Airlines, Co. v. Transp. Sec. Admin., 650 F.3d 752 (D.C. Cir. 2011) 

(denying airlines’ petition for review of TSA’s determination to use $420 million as the 

basis for its calculation of the cost to air carriers for screening passengers and property in 

calendar year 2000). As of this most recent ruling by the Court of Appeals, it remains 

unclear if air carriers will continue to dispute the amount of the fee imposed by TSA. 

What GAO Found
 

Page 306 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Difference between TSA’s Annual Appropriations and Aviation Security Fees Collected, from Fiscal Years 2002 through 2011

Notes: For the purposes of GAO’s analysis, TSA identified the total amounts appropriated to TSA for 

aviation security-related programs and activities, including Federal Air Marshals, threat assessments, 

and some support costs. Due to statutory and other limitations, TSA did not collect a full year’s worth 

of fees in fiscal years 2002 through 2004. In addition, beginning in fiscal year 2005, and each fiscal 

year thereafter, the first $250 million in passenger security fees collected have been designated to the 

Aviation Security Capital Fund, except for fiscal year 2008, when an additional $250 million in fee 

collections were designated to the Checkpoint Screening Security Fund. See 49 U.S.C. §§ 44923(h), 

44940(i). The figure above excludes amounts designated for the Aviation Security Capital Fund or the 

Checkpoint Screening Security Fund from “passenger security fees collected” and does not include 

these amounts in “amounts appropriated to TSA.” Percentages may not add to 100 due to rounding. 

The importance of closely aligning fees to the cost of the service provided 

has been widely documented. As GAO previously reported in May 2008 

about user fee design, agencies should review their fees on a regular 

basis to ensure that they, Congress, and stakeholders have complete 

information on the costs of federal programs, and that fees are 

appropriately aligned to program costs and activities, among other 
 

Page 307 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

things.5 Further, GAO’s report stated that user fees can be designed to 

reduce the burden on taxpayers to finance the portions of activities that 

provide benefits to identifiable users above and beyond what is normally 

provided to the public. The International Civil Aviation Organization also 

issued guidance regarding cost recovery for airport charges.6 This 

guidance provides information to consider when setting fees, including 

fees related to aviation security, and determining the extent to which fees 

should offset security costs. According to International Civil Aviation 

Organization officials, costs should be a key consideration in setting fees 

and governments or airports, with input from relevant stakeholders, may 

consider increasing security fees when costs increase. For example, 

following the September 11, 2001, terrorist attacks, the government of 

Canada imposed an Air Travelers Security Charge of $12.00 per one-way 

trip to cover the costs of aviation security services.7 This fee was 

reviewed and reduced each year from 2003 through 2006 to reflect 

increases in passenger enplanements, revenue, and tax reductions, while 

it was increased in 2010 to $7.48 to reflect increased expenditures for 

deploying upgraded checked baggage screening systems, among other 

things.8

In recent years, several options have been considered for increasing the 

passenger aviation security fee. However, the fee has not been increased 

since it was imposed in February 2002. The table below provides a 

 

5

In addition, pursuant to the Chief Financial Officers Act of 1990, agencies must review 

fees and other charges for services and things of value biennially, and based on these 

reviews make recommendations, as appropriate, on revising the fees to reflect costs 

incurred. See 31 U.S.C. § 902(a)(8). Similarly, OMB Circular A-25 provides that each 

agency will review user charges biennially. These reviews include (1) assuring that 

existing charges are adjusted to reflect unanticipated changes in costs or market values, 

and (2) reviewing of all other agency programs to determine whether fees should be 

assessed for government services or the user of government goods or services. In 

accordance with OMB guidance, TSA reviews the passenger security fee, which is a user 

fee, biennially, but TSA does not have authority to adjust the fee beyond the maximum 

amount established in statute, if warranted.

6

International Civil Aviation Organization, Policies on Charges for Airports and Air 

Navigation Services (Doc 9082), Eighth Edition, 2009. The International Civil Aviation 

Organization is a specialized agency of the United Nations that sets standards and 

regulations related to aviation safety, security, and aviation environmental protection, 

among other things.

7

The Canadian Air Transport Security Authority, created after September 11, 2001, is a 

governmental entity responsible for providing core civil aviation security functions, such as 

screening passengers and baggage at Canadian airports. The Air Travelers Security 

Charge is imposed on flights departing from any of the 89 airports regulated by the 

Canadian Air Transport Security Authority. GAO did not compare the costs of civil aviation 

security in Canada to those in the United States.

8

The amount of Air Travelers Security Charges imposed on travelers varies depending on 

flight segment, such as domestic (one-way), domestic (round-trip), transborder (to the 

United States), and other international flights. The fee is charged to passengers who use 

airports in which the Security Authority performs security-related services. Dollar amounts 

shown above are in Canadian dollars. When converted to U.S. dollars, the Air Travelers 

Security Charge would have been $7.56 in 2002 and $7.36 in 2010. 
 

Page 308 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

description of the proposed options presented from various sources for 

increasing the passenger security fee.

Options to Increase the Passenger Aviation Security Fee 

Source Description of option

Potential for addressing the difference 

between amounts appropriated and fees 

collected

President’s Deficit Reduction Plan 

(September 2011)

The administration proposed increasing 

the passenger fee to $7.50 per one-way 

trip by 2017 through incremental $0.50 

increases. 

The plan estimates that this option would collect 

an additional $8.8 billion over 5 years and $24.9 

billion over 10 years. According to the plan, over 

10 years, $15 billion of these collections would be 

directed for debt reduction and the remaining 

collections would be used to offset TSA 

appropriations.

Congressional Budget Office 

(CBO) (March 2011), President’s 

Debt Commission (November 

2010), and House Budget 

Committee (April 2011) 

In late 2010 and 2011, CBO and the 

President’s Debt Commission advanced 

similar options in which the passenger fee 

would be increased to a flat rate of $5.00 

per one-way trip. The House Budget 

Committee also included this option in its 

concurrent resolution on the budget for 

fiscal year 2012.

CBO estimates that this option would increase 

annual fee collections by about $2 billion, on 

average, or about $10 billion over 5 years. TSA 

officials stated that TSA is supportive of the CBO 

and President’s Debt Commission option because 

it would enable them to more closely meet their 

goal of offsetting 80 percent of the federal 

government’s aviation security costs through fee 

collections.

TSA Fiscal Year 2012 Budget 

Request (February 2011)

In its fiscal year 2012 budget request, TSA 

proposed incrementally increasing the 

passenger security fee to $5.50 per 

enplanement by 2014, with an $11 per 

one-way trip maximum.

The fiscal year 2012 budget request for TSA 

includes an option to increase the current $2.50 

fee by $1.50, offsetting appropriations by $590 

million in 2012. In addition, the option assumes 

$0.50 and $1.00 increases in 2013 and 2014, 

respectively. When fully implemented in 2014, 

TSA anticipates that this option will increase 

annual passenger fee collections by $2.3 billion. 

TSA’s goal for security fee 

collections (February 2009)

TSA officials stated that their goal is 

ultimately to offset 80 percent of amounts 

appropriated to TSA for aviation securityrelated programs and activities through fee 

collections. To achieve this goal, TSA 

would need to increase the passenger 

security fee to about $7.00 per 

enplanement, capped at $14 per one-way 

trip, according to GAO’s analysis. 

Increasing the fee to offset 80 percent of the 

amounts appropriated to TSA for aviation 

security-related programs and activities would 

represent an average annual increase of about $4 

billion in passenger fee collections, depending on 

appropriations. 

Source: GAO analysis of TSA, CBO, OMB, and President’s Debt Commission data.

Note: Estimates for future years are based on available enplanement data and are subject to change. 

In addition to the options noted above, the passenger security fee could 

also be adjusted for inflation. OMB Circular A-25 provides that biennial 

reviews assure that existing charges are adjusted to reflect unanticipated 

changes in costs or market values. GAO also reported on issues to 

consider when setting user fees such as whether fee collections are 

projected to change with inflation. According to GAO’s analysis, an 

inflation adjustment to the existing passenger security fee would result in 
 

Page 309 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

an increase of approximately $0.50,9

Industry association officials representing key aviation stakeholders—

including airport executives, airlines, and passengers—from four of the 

five associations GAO interviewed have expressed general opposition to 

a passenger security fee increase for various reasons, such as the 

argument that aviation security is a federal responsibility and therefore 

associated costs should be borne by the government. One association 

noted that the burden of subsidizing these costs should not fall solely on 

passengers. Officials with three of the five aviation industry associations 

GAO interviewed also stated that the demand for air travel could be 

impacted if aviation security fees were increased. However, TSA officials 

stated that TSA does not expect its fiscal year 2012 proposal to increase 

the passenger security fee to $5.50 per enplanement (capped at $11.00 

per one-way trip) to have a significant impact on travelers’ demand to fly 

since the proposal suggests modest, incremental increases to the fee.

increasing the fee from $2.50 to 

about $3.00 per enplanement, capped at $6 per one-way trip. Adjusting 

the fee for inflation would represent an average annual increase of about 

$410 million in passenger fee collections.

In addition, GAO’s review of the economic literature and related analysis 

suggests that the demand for air travel is somewhat elastic to price 

changes,10 though TSA’s proposed fee increase to $5.50 per 

enplanement by 2014 constitutes a small proportion of the average price 

of a one-way trip,11 which is about $210 as of calendar year 2010, 

according to the U.S. Department of Transportation.12

 

9

GAO’s inflation adjustment factor is derived from the Consumer Price Index (for urban 

consumers) compiled by the Bureau of Labor Statistics using 2002 as the base year. GAO

divided the annual Consumer Price Index for 2010 by that of 2002 to get the adjustment 

factor for 2010.

Moreover, the 

responsiveness of travelers to changes in air travel prices depends on 

several factors such as distance traveled, nature of the trip (nonbusiness 

versus business), and the availability of alternative travel modes (for 

example, rail, road, etc.). GAO’s analysis of TSA’s fiscal year 2012 

budget proposal to incrementally increase the passenger security fee to 

$5.50 per enplanement by 2014 shows that when demand effects are 

taken into account, total enplanements from fiscal years 2012 through 

2014 could be reduced by 1 percent or about 26 million passengers over 

10See D.W. Gillen, W.G. Morrison, and C. Stewart, Air Travel Demand Elasticities: 

Concepts, Issues, and Management, Department of Finance, Government of Canada 

(January 2003). 

11Note that this is the fare for a whole trip; since a trip may entail more than one 

enplanement, the fee increase as a percentage of enplanement fare would be slightly 

higher but still very small.

12The average ticket price reflects a weighted average price of domestic and international 

flights.
 

Page 310 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

this 3-year period.13 This would reduce expected fee collections by about 

$120 million, or 3 percent of the $4.4 billion in additional fees collected 

over this period.14

Increasing the passenger security fee could help further offset billions of 

dollars in the federal budget for aviation security programs and activities 

in outlying fiscal years. Therefore, Congress, working with the 

Administrator of TSA, may wish to consider

• increasing the passenger security fee according to one of the options 

identified in this summary. Options to increase the fee include the 

President’s Deficit Reduction Plan option ($7.50 per one-way trip by 

2017); the CBO, President’s Debt Commission, and House Budget 

Committee option ($5.00 per one-way trip); TSA’s Fiscal Year 2012 

Budget Request option ($5.50 per enplanement by 2014); TSA’s goal 

to ultimately offset 80 percent of federal aviation security costs 

through fee collections (according to GAO analysis, this option would 

increase the fee to about $7.00 per enplanement); as well as 

adjusting the fee for inflation (according to GAO analysis, this option 

would increase the fee to about $3.00 per enplanement). These 

options could increase fee collections from about $2 billion to $10 

billion over 5 years. 

GAO provided a draft of this report section to DHS for review and 

comment. DHS provided technical comments, which were incorporated 

as appropriate.

The information contained in this analysis is based on findings from 

products listed in the related GAO products section and additional work 

GAO conducted. To address the issues discussed here, GAO analyzed 

(1) available documentation and guidance on TSA’s aviation security fees 

and programs, (2) TSA’s historical revenue data for aviation security fees 

from fiscal years 2002 through 2011, and (3) TSA estimates of applicable 

enplanement data for fiscal years 2012 through 2014. GAO compared 

 

13In this context, demand elasticity refers to the degree to which the demand for air travel 

changes with price. Our analysis assumes a demand elasticity of -1.122. This is the 

median of 254 estimates from 21 studies analyzed in a 2003 study conducted by the 

Department of Finance, Government of Canada. See D.W. Gillen, W.G. Morrison, and C. 

Stewart. In addition, a 2007 study claims that this demand is less elastic (less responsive 

to price changes especially when those price changes apply to all national routes). The 

2007 study estimates this national level elasticity to be -0.8. In this case, the reduction in 

total enplanements could be even lower. See Intervistas Consulting Group, Estimating Air 

Travel Demand Elasticities, Final Report (December 2007). 

14Note that the reduction in enplanements by 26 million could also result in some lost 

revenues from excise and segment taxes levied on air travel. GAO estimated this to be 

about $295 million.

Actions Needed and 

Potential Financial or 

Other Benefits

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 311 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

this data with other supporting documents, when available, to determine 

data consistency and reasonableness. On the basis of these efforts, GAO 

concluded that the data are sufficiently reliable for the purposes of this 

summary. GAO also analyzed various options to raise the passenger 

security fee, including the Obama administration’s February 2009 budget 

request for fiscal year 2010, CBO’s August 2009 option, and the 

President’s Debt Commission report. 

To develop the option to adjust the fee for inflation, GAO analyzed OMB 

Circular A-25 and GAO’s May 2008 report, which includes issues to 

consider when setting user fees such as whether fee collections are 

projected to change with inflation. GAO also reviewed OMB Circular A-25 

and relevant provisions of the Chief Financial Officers Act related to the 

setting and periodic review of user fees. GAO further interviewed officials 

with the International Civil Aviation Organization and analyzed policy 

guidance regarding international policies and best practices for the 

development and periodic review of aviation-related fees. To provide 

information on comparable fee structures and approaches in which fees 

are periodically adjusted, GAO analyzed documentation and analysis 

regarding Canada’s Air Travelers Security Charge, including 

documentation of fee adjustments and associated demand elasticity 

analysis. GAO also discussed the current aviation security fee structure 

and options for modifying these fees with TSA officials; officials from five 

industry associations representing passengers, airports, and international 

groups; and officials from three organizations with subject matter 

expertise in aviation issues. GAO selected these associations because 

they represent key stakeholders—passengers, airports, and airlines—that 

could be affected by a fee increase. 

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

May 29, 2008.

Aviation Fees: Review of Air Carriers’ Year 2000 Passenger and Property 

Screening Costs. GAO-05-558. Washington, D.C.: April 18, 2005.

For additional information about this area, contact Steve Lord at (202) 

512-4379 or lords@gao.gov. 

Related GAO 

Products 

Contact Information
 

Page 312 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

49. Immigration Inspection Fee

The air passenger immigration inspection user fee should be reviewed and adjusted to fully recover the cost of 

the air passenger immigration inspection activities conducted by the Department of Homeland Security’s U.S. 

Immigration and Customs Enforcement and U.S. Customs and Border Protection rather than using general 

fund appropriations. 

International air passengers arriving in the United States are subject to an 

immigration inspection to ensure that they have legal entry and 

immigration documents. Immigration inspection activities are conducted 

by U.S. Immigration and Customs Enforcement (ICE) and U.S. Customs 

and Border Protection (CBP). The immigration fee is set in statute at $7 

per passenger. The collections are available to pay for all expenses 

incurred in providing inspection and pre-inspection services.1

Passengers pay the immigration inspection fee when they purchase their 

airline tickets. Fee collections—which GAO estimates were about $600 

million

The statute 

also directed the agency to report to the Congress every 2 years on the 

status of the Immigration User Fee Account, including balances, and 

recommend fee adjustments that may be required to ensure that the 

collections equal, as closely as possible, the cost of providing these 

services. However, ICE has not yet analyzed air passenger immigration 

inspection fee data to identify what fee adjustments, if any, are 

necessary.

2 in fiscal year 2010—are available to ICE and CBP to pay for costs 

incurred in providing inspection and pre-inspection services, and are 

intended to be divided between ICE and CBP according to the costs of 

the immigration inspection activities for which each agency is responsible. 

Air passenger immigration inspection fee collections do not recover the 

total costs of these inspections. However, because immigration inspection 

costs and collections have not recently been comprehensively reviewed, 

it is unknown (1) whether collections are appropriately distributed 

between ICE and CBP and (2) the extent to which fee collections fail to 

cover air passenger immigration inspection costs, especially for ICE’s 

inspection activities.

Air passenger immigration fee collections did not fully cover CBP’s costs 

in fiscal years 2009 and 2010. According to ICE officials, although ICE 

does not track air passenger costs separately from sea passenger costs, 

ICE’s portion of total air and sea passenger collections did not cover 

 

1

8 U.S.C § 1356(d).

2

Because ICE does not analyze air passenger collections information separately, GAO 

estimated ICE’s collections using CBP’s data and the allocation rate between ICE and 

CBP. 

Why This Area Is 

Important

What GAO Found
 

Page 313 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

ICE’s total air and sea passenger costs in fiscal years 2007 through 

2009.3

Air Passenger Immigration Inspection Fee Costs and Collections

As a result, in recent years, CBP and ICE have relied on general 

fund appropriations (in fiscal year 2010 alone, this amounted to over $120 

million for CBP and an unknown amount for ICE) to help fund activities for 

which these agencies have statutory authority to fund with user fees. 

Fiscal year 2008 Fiscal year 2009 Fiscal year 2010

ICE CBP ICE CBP ICE CBP

Air passenger 

immigration 

inspection 

collections

$115,522,669 

(GAO estimate)a $549,547,391 $98,917,337 (GAO 

estimate)

a $470,554,955 $103,865,917(GAO 

estimate)a $494,095,613

Air passenger 

immigration 

inspection 

costs 

Unknownb $524,016,131 Unknownb $523,576,731 Unknownb $620,348,927

Difference Unknown $25,531,260 Unknown -$53,021,776 Unknown -$126,253,314

Source: GAO analysis of ICE and CBP data.

a

Because ICE does not separately analyze air passenger collections data, GAO estimated ICE’s 

collections using CBP’s data and the user fee allocation rate between ICE and CBP. This estimate 

does not replace the actual data which would be found in a fee review. 

b

ICE provided immigration inspection cost data for both air and sea passengers, but not specific data 

for air passengers. 

The air passenger immigration inspection fee has not been recently 

comprehensively reviewed, and the rate, which is set in statute, has not 

been adjusted since fiscal year 2002. As GAO reported in May 2008, 

regular, comprehensive fee reviews could prevent misalignment between 

fees and the activities they support. Comparing ICE and CBP cost and 

collection information could help determine the extent to which collections 

cover costs and the appropriate share of collections for each agency. 

Further, GAO reported in its May 2008 User Fee Design Guide that 

regular reviews also help to increase awareness about program costs—

and therefore increase incentives to reduce costs where possible.

As GAO reported in September 2007, while CBP reviewed its share of air 

passenger inspection costs, ICE had not reviewed its share of these 

costs, and ICE and CBP do not have a process to determine how the 

immigration user fee would be split between them. In that report, GAO 

recommended that the Secretary of Homeland Security report on ICE’s 

activity costs to ensure the immigration fee is divided between ICE and 

CBP according to their respective immigration inspection activity costs 

and to develop a legislative proposal to adjust the air passenger 

immigration inspection fee if it was found to not recover the costs of 

 

3

As of January 2012, ICE officials said they were evaluating fiscal year 2010 data and did 

not know whether collections covered costs for that year.
 

Page 314 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

inspection activities. The Department of Homeland Security agreed with 

GAO’s recommendations.

Since 2006, GAO has requested that ICE and CBP provide a 

comprehensive review showing the extent to which fee collections cover 

their air passenger immigration inspection costs. CBP provided GAO with 

this analysis for its share of the immigration inspection activities. ICE only 

provided aggregate costs for air and sea ports of entry. Agency officials 

said that ICE cannot provide this information because it does not 

separately analyze air passenger amounts. Absent such information, the 

extent to which total air passenger fee collections cover total air 

passenger costs, and whether these collections are appropriately 

distributed between ICE and CBP, is unknown. 

To determine the extent to which air passenger immigration inspection 

fees are aligned with the costs of inspection activities, which could enable 

fee adjustments to reduce reliance on general fund appropriations, 

Congress may wish to require the Secretary of the Department of 

Homeland Security to fully implement the recommendations from GAO’s 

September 2007 report, including to

• require ICE and CBP to regularly report on the total cost of air 

passenger immigration inspections and the amount of associated fee 

collections;

• adjust the fee as needed so that collections are aligned with total 

inspection costs, if it is determined that total immigration fee 

collections do not cover total immigration inspection costs;4

• direct ICE to amend its cost study methodology to determine the 

extent to which air passenger fee collections cover reimbursable 

activities;5

• direct ICE and CBP to establish a regular schedule to review and 

coordinate on the costs of their respective air passenger immigration 

inspection activities, and revise the proportion of the fee received by 

each agency accordingly.

and

 

4

In September 2007, GAO recommended that, if air passenger immigration inspection

activity costs exceed collections, the Secretary of Homeland Security should develop a 

legislative proposal in consultation with Congress to adjust the immigration fee to recover 

costs as closely as possible, per statute. As of November 2011, this recommendation 

remains open pending the completion of ICE’s cost study.

5

In September 2007, GAO recommended that the Secretary of Homeland Security 

complete development of and report on ICE’s activity costs to ensure the air passenger 

immigration inspection fee is divided between ICE and CBP according to their respective 

proportion of air passenger immigration inspection activity costs. As of November 2011, 

this recommendation remains open pending the completion of ICE’s cost study.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 315 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Taking these four actions would allow ICE and CBP to better align air 

passenger immigration inspection fee revenue with the costs of providing 

these services and achieve cost savings by reducing the reliance on 

general fund appropriations.

GAO provided a draft of this report section for to the Department of 

Homeland Security for review and comment. The department agreed with 

the material facts as presented. ICE supplied GAO with its Immigration 

User Fee Account cost studies for fiscal years 2007, 2008, and 2009, 

which showed its combined immigration inspection fee costs for air and 

sea inspections. ICE said that it will update its methodology for 

determining Immigration User Fee Account air and sea costs and will 

conduct additional analysis to separate the air and sea immigration fee 

collections and costs. ICE estimates that the revised analysis for fiscal 

year 2010 will be completed by March 31, 2012. Further, ICE said that it 

will continue to work with GAO and CBP to close the remaining 

recommendations outlined in GAO reports concerning the Immigration 

User Fee Account.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section as well as additional 

work GAO conducted. GAO reviewed documents from ICE and CBP. In 

addition, GAO requested fiscal year 2010 cost and collections data from 

ICE and CBP and used data from CBP. 

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

May 29, 2008.

Federal User Fees: Key Aspects of International Air Passenger Inspection 

Fees Should Be Addressed Regardless of Whether Fees Are 

Consolidated. GAO-07-1131. Washington, D.C.: September 24, 2007.

For additional information about this area, contact Susan J. Irving at 

(202) 512-6806 or irvings@gao.gov. 

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 

Contact Information
 

Page 316 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

50. Iraq Security Funding 

When considering new funding requests to train and equip Iraqi security forces, Congress should consider the 

government of Iraq’s financial resources, which afford it the ability to contribute more toward the cost of Iraq’s 

security.

Since 2003, the United States has reported obligating about $708 billion 

for U.S. military operations in Iraq and has provided about $25.5 billion for 

training, equipment, supplies, facility construction, and other services for 

Iraqi security forces.1 In its fiscal year 2012 budget request, the 

administration requested more than $2.4 billion in U.S. funding to support 

the training and equipping of forces under Iraq’s security ministries. The 

fiscal year 2009 National Defense Authorization Act instructed the U.S. 

government to take actions to ensure that Iraqi funds are used to pay the 

costs of training, equipping, and sustaining Iraqi security forces.2 In 

December 2011, the United States withdrew all U.S. forces from Iraq.

However, the U.S.-Iraq Strategic Framework Agreement affirms the 

desires of the two countries to establish a long-term relationship of 

cooperation in the economic, diplomatic, cultural, and security fields, 

among others.3 Iraq’s large oil reserves offer the Iraqi government the 

potential to contribute to the country’s current and future security and 

stabilization requirements. Oil revenues account for over 50 percent of 

the country’s gross domestic product and about 90 percent of the 

government’s revenues. As GAO previously reported, Iraq reported 

substantial budget surpluses.

GAO analysis of Iraqi revenue and expenditure data through the end of 

2009 showed that Iraq generated an estimated cumulative budget surplus 

of $52.1 billion. This estimate is consistent with the method that Iraq uses 

to calculate its fiscal position. Adjusting for $40.3 billion in estimated 

outstanding advances reduces the amount of available surplus funds to 

$11.8 billion. For 2010, Iraqi Ministry of Finance and Central Bank of Iraq 

data show that the Iraqi government generated a $600 million cash deficit 

(rather than the $19. 6 billion deficit budgeted) due to higher-thanpredicted revenue and less-than-planned expenditures. In addition, during 

the first 6 months of 2011, the government of Iraq collected $7.9 billion 

more in oil revenue than it originally budgeted. GAO does not have more 

 

1

Iraqi security forces include the Iraqi army, navy, and air force under the Ministry of 

Defense and the Iraqi police, federal police, and border enforcement under the Ministry of 

Interior.

2

Duncan Hunter National Defense Authorization Act for Fiscal Year 2009, Pub. L. No. 

110-47 (Oct. 14, 2008).

3

Strategic Framework Agreement for a Relationship of Friendship and Cooperation 

between the United States of America and the Republic of Iraq (Nov. 17, 2008), effective 

January 1, 2009.

Why This Area Is 

Important

What GAO Found
 

Page 317 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

recent data on outstanding advances that would allow for an update to 

the amount of available surplus. The International Monetary Fund, 

however, has determined that the Ministry of Finance should review the 

outstanding advances as a benchmark the government of Iraq needs to 

achieve under its current stand-by arrangement.

Iraqi government data indicate that security spending under the Ministries 

of Defense and Interior increased from $2.0 billion in 2005 to an 

estimated $8.6 billion in 2009. In addition, these ministries set aside about 

$5.5 billion over this period for the purchase of equipment, training, and 

services under the U.S. Foreign Military Sales (FMS) program. In certain 

instances, the United States has provided an incentive for these 

ministries to increase their security spending by leveraging U.S. funds to 

supplement Iraq’s FMS purchases. The Iraqi government also funded the 

Iraq-Commander’s Emergency Response Program and assumed 

responsibility for the salaries of almost 90,000 Sons of Iraq—

nongovernmental security contractors hired by U.S. and Coalition forces 

to help maintain security in their local communities. While security 

spending has increased, GAO’s analysis of data for the Iraqi government, 

the Department of Defense (DOD), and the Trade Bank of Iraq showed 

that the ministries did not spend or set aside between $2.5 billion and 

$5.2 billion of their 2005 through 2009 budgeted funds—funds that could 

have been used to address security needs.4

In its fiscal year 2012 budget request, the administration requested more 

than $2.4 billion in U.S. funding to support the training and equipping of 

forces under Iraq’s security ministries. Specifically,

Department of State (State) 

and DOD officials cited overly centralized decision making and weak 

procurement capacity as reasons for the ministries’ inability to spend 

these funds. In April 2010, Ministry of Defense officials received Ministry 

of Finance approval to use $143 million of their unspent 2009 funds for 

FMS purchases. Ministry of Interior officials planned to use more than 

$300 million of their unspent 2009 funds for similar purposes.

• State requested $1 billion for Foreign Military Financing to purchase 

training and equipment for Iraqi security forces. According to State, 

this request for Iraq is a replacement for DOD’s Iraq Security Forces 

Funding and is in addition to the $25.5 billion that has already been 

provided since 2003. In the 2012 Consolidated Appropriations Act,

Congress appropriated $1.102 billion for Foreign Military Financing for 

Overseas Contingency Operations/Global War on Terrorism.5

 

4

The range that GAO estimated reflects uncertainty regarding what portion of funds set 

aside for FMS purchases and paid as letters of credit has been recorded as expenditures 

by the Ministry of Finance and is therefore included in expenditure totals. 

The 

Conference Agreement accompanying the act explains that the 

5

Consolidated Appropriations Act, 2012, Pub. L. No. 112-74, Dec. 23, 2011.
 

Page 318 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

amount is for the extraordinary costs of contingency operations, 

including in Iraq, Pakistan, the Philippines, and Yemen.

• State also requested $886 million to fund its new Police Development 

Program in Iraq, of which 15.5 percent ($137 million) will be used to 

deploy approximately 190 police advisors and 82 percent ($723 

million) will be used for security and support costs. These funds are in 

addition to the $757 million that was available in fiscal years 2010 and 

2011, for the Police Development Program’s start-up and initial 

operating costs. Congress appropriated $983,605,000 for 

International Narcotics Control and Law Enforcement for Overseas 

Contingency Operations/Global War on Terrorism. The conference 

Agreement accompanying the act explained that the amount is for the 

extraordinary costs of contingency operations, including in Iraq, 

Pakistan, Afghanistan, Yemen, Somalia, and for African 

counterterrorism partnerships.

• DOD requested $524 million to establish its Office of Security 

Cooperation-Iraq, which will be responsible for administering Iraq’s 

FMS and Foreign Military Financing program, among other 

responsibilities. Congress authorized that from the funds made 

available to DOD for Operation and Maintenance, Air Force, up to 

$524 million could be used to fund the operations and activities of the 

Office of Security Cooperation-Iraq and security assistance teams, 

including life support, transportation and personal security, and 

facilities renovation and construction.

Iraq generated an estimated cumulative budget surplus of $52.1 billion 

through December 2009. Adjusting for outstanding advances, at least 

$11.8 billion of this surplus was available for future spending. In light of 

these resources, Iraq has the potential to further contribute toward its 

security needs, even as it addresses other competing priorities. GAO 

recommended in September 2010 that Congress should

• consider Iraq’s available financial resources when it reviews future 

budget requests for additional funds to train and equip Iraqi security 

forces.

Additional clarity is needed on Iraq’s outstanding advances to determine 

the financial resources Iraq has available for future spending. To this end, 

GAO recommended in September 2010 that the Secretaries of State and 

the Treasury should

• work with the Iraqi government to identify these resources by assisting 

Iraq in completing International Monetary Fund-required review of 

outstanding advances.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 319 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

GAO provided a draft of its September 2010 report to State, Treasury, 

DOD and the International Monetary Fund for review and comment. 

State, Treasury, DOD, and the International Monetary Fund provided 

technical comments, which were incorporated as appropriate. State and 

Treasury agreed with GAO’s recommendation and agreed to work with 

their Iraqi counterparts to identify available financial resources. Treasury 

also agreed in principle that, while Iraq’s fiscal accounts are not well 

ordered, Iraq potentially will have financial resources to engage in greater 

cost-sharing. State, Treasury, and DOD stated that the Iraqi government’s 

available funds are closer to the low end of GAO’s range, and that Iraq 

needs to maintain a fiscal reserve. GAO believes that it is premature to 

determine that Iraq’s available resources fall at the low end of the range 

until Iraq has completed International Monetary Fund-required review of 

outstanding advances, particularly in light of the substantial shortcomings 

associated with Iraq’s accounting for advances. This review will clarify the 

total resources available for government spending. GAO agrees that it 

may be prudent for Iraq to maintain a fiscal reserve.

DOD also commented that it believes the overall message of the draft 

report—that the Iraqi government had significant cash reserves that 

would have allowed it to pay more of its security costs—is inaccurate. 

GAO disagreed. In its report, GAO noted that Iraq ended 2009 with at 

least $15.3 billion in financial deposits. Moreover, when completed, 

International Monetary Fund-required review of Iraq’s outstanding 

advances will clarify the total funds that are available to the government 

for spending.

The information contained in this analysis is based on findings from the 

products listed in the related GAO products section. GAO analyzed 

relevant data, reviewed documents, and interviewed Iraqi officials in 

Baghdad, Iraq, including the Ministers of Finance, Defense, and Interior; 

the Governor of the Central Bank of Iraq; the President of the Trade Bank 

of Iraq; and the Deputies General of Accounting at the Rafidain and 

Rasheed banks, which are Iraq’s two largest state-owned commercial 

banks. GAO analyzed data on Iraq’s reported revenues and expenditures 

from the Minister of Finance for 2005 through 2010 and from Iraq’s 

financial statements prepared by Iraq’s Board of Supreme Audit for 2005 

through 2007. GAO also analyzed similar data on Iraq’s advances 

through September 2009. GAO also interviewed U.S. and other officials in 

Washington, D.C., and Baghdad, Iraq, including officials from DOD, State, 

and the Department of the Treasury; the World Bank; the International 

Monetary Fund; and the Federal Reserve Bank of New York. GAO 

conducted a site visit in Baghdad, Iraq, in April 2010, to interview Iraqi 

officials and to obtain additional information on Iraq’s fiscal position. To 

report on the President’s fiscal year 2012 budget request, GAO reviewed

the President’s fiscal year budget request for international affairs, and 

past and current transition and interagency planning documents for the 

transition to a civilian-led U.S. presence in Iraq. GAO also interviewed 

officials from the Departments of State and Defense in Washington, D.C., 

and the U.S. Embassy Baghdad.

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work
 

Page 320 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Iraqi-U.S. Cost-Sharing: Iraq Has a Cumulative Budget Surplus, Offering 

the Potential for Further Cost-Sharing. GAO-10-304. Washington, D.C.: 

September 13, 2010.

Iraq: Key Issues for Congressional Oversight. GAO-09-294SP. 

Washington, D.C.: March 24, 2009.

Stabilizing and Rebuilding Iraq: Iraq Revenues, Expenditures, and 

Surplus. GAO-08-1031. Washington, D.C.: August 5, 2008.

For additional information about this area, contact Charles Michael 

Johnson, Jr. at (202) 512-7331 or johnsoncm@gao.gov. 

Related GAO 

Products 

Contact Information
 

Page 321 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

51. Domestic Disaster Assistance

The Federal Emergency Management Agency could reduce the costs to the federal government related to 

major disasters declared by the President by updating the principal indicator on which disaster funding 

decisions are based and better measuring a state’s capacity to respond without federal assistance.

The growing number of major disaster declarations has contributed to an 

increase in federal expenditures for disaster assistance. From fiscal years 

2002 to 2011, Presidents have declared 35 percent more disasters than 

during the preceding 10-year period. Major disaster declarations can 

trigger a variety of federal response and recovery assistance for 

government and nongovernmental entities, households, and individuals. 

Officials from the Federal Emergency Management Agency (FEMA), 

within the Department of Homeland Security (DHS), have cited various 

possible reasons for increases in the number of declarations, including 

more active weather patterns, increased costs to repair damaged 

infrastructure, and population increases.

When a state is hit by a disaster, the governor may request a major 

disaster declaration from the President.1 FEMA makes an assessment of 

damage and other factors and makes a recommendation to the President, 

who has discretion to accept or reject FEMA’s recommendation. FEMA 

uses a statewide per capita damage indicator to help determine whether 

sufficient damage has occurred to warrant a declaration and to determine 

whether a state should receive Public Assistance. Public Assistance is 

the federal disaster assistance program used by FEMA to reimburse 

states for certain response and recovery activities.2

Much of the growth in major disaster declarations has occurred at the 

same time (that is, since 9/11) that the federal government has provided 

more than $34 billion to state and local governments to enhance their 

Public Assistance 

funding represents the largest proportion of funds obligated from FEMA’s 

Disaster Relief Fund, which is the major source of federal disaster 

recovery assistance for state and local governments when a disaster is 

declared.

 

1

42 U.S.C. § 5170. In addition to major disaster declarations, the President may issue 

emergency declarations. If the President declares an emergency, the federal government 

may provide immediate and short-term assistance that is necessary to save lives, protect 

property and public health and safety, or lessen or avert the threat of a catastrophe. 42 

U.S.C. § 5192. Federal assistance may not exceed $5 million under an emergency 

declaration unless continued emergency assistance is immediately required; there is a 

continuing and immediate risk to lives, property, public health or safety; and necessary 

assistance will not otherwise be provided on a timely basis. 42 U.S.C. § 5193. 

2

The Public Assistance Program provides for debris removal, emergency protective 

measures, and the repair, replacement, or restoration of disaster-damaged, publicly 

owned facilities and the facilities of certain private nonprofit organizations that provide 

services otherwise performed by a government agency.

Why This Area Is 

Important
 

Page 322 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

preparedness to protect against, respond to, and recover from disasters 

of all types. From fiscal years 2004 through 2011, the President approved 

539 major disaster declarations. As of September 30, 2011, $78.7 billion 

was paid for by the Disaster Relief Fund for these disasters.3 For 13 of 

these declared disasters, FEMA has obligated over $1 billion each.4

In August 2011, the Disaster Relief Fund diminished to a level that 

caused FEMA to temporarily halt funding on long-term recovery projects 

and focus on immediate needs. According to the FEMA Administrator, 

due to the shortage of available balances in the Disaster Relief Fund, 

FEMA accelerated its efforts to recover previously obligated funds from 

states for completed projects that had unexpended balances.5 Further, 

throughout fiscal year 2011, FEMA recovered over $3.5 billion in 

unexpended funds from states and other federal agencies.6 GAO has 

identified determining the costs to be borne by the federal, state, and 

local governments or the private sector in preparing for, responding to, 

and recovering from disasters of all types as a 21st Century challenge.7

GAO is currently conducting a review of the disaster declaration process 

and plans to report the results in summer 2012.

FEMA could reduce federal expenditures by updating its eligibility 

indicator and more accurately determining a state’s capacity to respond to 

a disaster. According to FEMA and state emergency management 

officials, FEMA has primarily relied on a single indicator, the statewide per 

capita damage indicator, to determine whether to recommend that a state 

receive Public Assistance funding. For example, in fiscal year 2012, the 

per capita indicator is $1.35; thus, for a state with 10 million people, 

estimated damages from a disaster would generally have to be $13.5 

million or more for FEMA to recommend Public Assistance, although 

other factors could also influence the recommendation.

 

3

FEMA’s obligations of $78.7 billion exclude obligations for disasters declared before 

fiscal year 2004 that had yet to be closed out by October 1, 2004, and, therefore, 

remained eligible for additional obligations in fiscal year 2004 and subsequent years.

4

In addition to the 13 disasters that have currently exceeded a billion dollars in obligations, 

other disasters declared during fiscal years 2004 to 2011 that are still open could reach 

obligations of over $1 billion as FEMA continues to obligate funds for them.

5

Statements of The Honorable W. Craig Fugate, Administrator, FEMA, before the House 

Committee on Transportation and Infrastructure, Subcommittee on Economic 

Development, Public Buildings, and Emergency Management, Streamlining Emergency 

Management: Improving Preparedness, Response, and Cutting Costs (Washington, D.C.: 

Oct. 13, 2011). 

6

Statements of The Honorable W. Craig Fugate, Administrator, FEMA, before the House 

Committee on Homeland Security, Subcommittee on Emergency Preparedness, 

Response, and Communications, Five Years Later: An Assessment of the Post Katrina 

Emergency Management Reform Act (Washington, D.C.: Oct. 25, 2011). 

7

See GAO, 21st Century Challenges: Reexamining the Base of the Federal Government, 

GAO-05-325SP (Washington, D.C.: February 2005). 

What GAO Found 
 

Page 323 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

FEMA’s method for determining a state’s capacity to respond without 

federal assistance relies on a governor’s certification and damage 

indicators. The Stafford Act requires that a governor’s request for a major 

disaster declaration be based on a finding that the disaster is of such 

severity and magnitude that an effective response is beyond the 

capabilities of the state and that federal assistance is necessary.8

 FEMA 

officials stated that governors must certify in their letter to the President 

requesting a major disaster declaration that the disaster is beyond the 

capabilities of the state. FEMA regulations list quantitative and qualitative 

factors, such as whether a state is responding to multiple disasters within 

a short time period, that the agency considers when determining whether 

a disaster declaration is warranted.9

The Post-Katrina Emergency Management Reform Act of 2006, enacted 

in response to Hurricane Katrina, required FEMA to develop a set of 

preparedness metrics that could be used to assess operational 

preparedness capacity.

However, in describing the 

declarations process, FEMA and state officials stated that FEMA uses the 

statewide per capita indicator as the primary determining factor for Public 

Assistance funding. This damage indicator, which FEMA has used since 

1986, is essentially a proxy fiscal measure of a state’s capacity to 

respond to and recover from a disaster.

10 Presidential Policy Directive-8, issued in March 

2011, also includes such a requirement. However, FEMA has not yet 

developed such metrics, which limits its ability to comprehensively assess 

a state’s disaster preparedness and capabilities. Moreover, at this time, 

FEMA does not have any plans or policies in place to use state 

preparedness data to inform decisions regarding Presidential disaster 

declarations. Without an established means of assessing state response 

and recovery capacity, FEMA has continued to rely primarily on the per 

capita damage indicator when determining whether a major disaster 

declaration is warranted. Metrics to assess a state’s disaster 

preparedness and capabilities would augment the Public Assistance per 

capita indicator to provide a more comprehensive understanding of a 

state’s capacity to respond to and recover from a disaster without federal 

assistance.11

Further, FEMA has not adjusted the per capita indicator for Public 

Assistance to keep pace with changes in per capita personal income. 

 

8

42 U.S.C. § 5170. The intent of the Stafford Act is to, among other things, provide an 

orderly and continuing means of assistance by the federal government to state and local 

governments in carrying out their responsibilities to alleviate the suffering and damage 

from disasters. 42 U.S.C. §5121(b).

9

See 44 C.F.R. § 206.48(a)(5).

106 U.S.C. § 749. 

11GAO has previously reported on the importance of metrics, for example, see GAO, 

Measuring Disaster Preparedness: FEMA Has Made Limited Progress in Assessing 

National Capabilities, GAO-11-260T (Washington, D.C.: March 17, 2011).
 

Page 324 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

According to federal internal control standards, activities should be 

established to monitor performance indicators and controls should be 

aimed at validating the propriety and integrity of such indicators.12 In 

1986, FEMA proposed a $1.00 per capita indicator for Public Assistance 

as a means of gauging state fiscal capacity.13 The indicator was based on 

the 1983 per capita personal income nationwide, then estimated at 

$11,667. FEMA thought it reasonable “that a state would be capable of 

providing $1.00 for each resident of that state to cover the cost of state 

efforts to alleviate the damage which results from a disaster situation” 

given that national per capita personal income was $11,667.14 While the 

proposed rule was not codified in 1986, FEMA began to use the $1.00 per 

capita indicator informally as part of its preliminary damage assessment 

efforts and did not adjust the indicator annually for either inflation or 

increases in national per capita income. In 1998, FEMA had suggested 

that the Public Assistance indicator be adjusted to $1.51 to account for 

inflation since 1986, but due to input from state emergency management 

officials, FEMA decided not to do so. In 1999, FEMA issued a rule 

codifying the per capita indicator at $1.00, which was stipulated to include 

an annual adjustment for inflation, but the rule was silent on whether the 

indicator would continue to be based on nationwide per capita personal 

income.15 As a result, the indicator has risen 35 percent from $1.00 to 

$1.35 in the 12 years since FEMA began its annual inflationary 

adjustments. In proposing and finalizing the rule, FEMA stated that it 

recognized that a straight per capita figure may not be the best 

measurement of a state’s capability, but that it provided a simple, clear, 

consistent and long-standing means of measuring the severity, 

magnitude, and impact of a disaster, while at the same time ensuring that 

the President can respond quickly and effectively to a governor’s request 

for assistance.16

Had the indicator been adjusted for inflation beginning when FEMA 

started using it in 1986, it would have risen more than 100 percent to 

$2.07 by 2012. Furthermore, had the indicator been adjusted for 

increases in per capita personal income, the indicator would have risen to 

$3.42 in 2010, based on 2010 national per capita personal income of 

$39,945. While these alternate adjustment methods would have 

increased the per capita indicator, they are not necessarily indicative of a 

state’s ability to pay for the damage because they do not consider the 

 

12See GAO, Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1. (Washington, D.C.: November 1999).

1351 Fed. Reg. 13,332 (Apr. 18, 1986).

1451 Fed. Reg. at 13,333.

1564 Fed. Reg. 47,697 (Sept. 1, 1999). When FEMA published the rule establishing the 

formal public assistance criteria in 1999, FEMA set the public assistance per capita 

indicator at $1.00.

1664 Fed. Reg. at 47,697; 64 Fed. Reg. 3910, 3911 (Jan. 26, 1999).
 

Page 325 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

substantial differences in states’ financial capacities to respond when 

disasters occur. For example, per capita personal income is a relatively 

poor indicator of a state’s fiscal capacity because it does not 

comprehensively measure income potentially subject to state 

taxation.17

As GAO reported in August 2001, issues exist regarding the criteria that 

FEMA used to recommend to the President that a state disaster 

declaration request be approved or denied. Specifically, GAO reported 

that the per capita indicator was not necessarily indicative of state or local 

capability to respond effectively without federal assistance, and 

recommended that FEMA should consider alternative criteria. FEMA’s 

response noted that GAO provided valuable input for the FEMA team that 

was reviewing the disaster declaration process and the criteria used to 

assess state damages. According to FEMA, in 2001 the President’s 

budget for fiscal year 2002 included a provision for the development of 

improved guidelines for disaster assistance that provided states with 

meaningful criteria that must be met to become eligible for federal 

disaster assistance. FEMA undertook a review of disaster declaration 

guidelines; however, no changes to the established declaration guidelines 

were adopted and, ultimately, FEMA did not change its reliance on the 

per capita indicator. In January 2012, FEMA officials stated that it is a 

balancing act to agree on a good, reasonable measure of a state’s 

capacity to respond to and recover from a disaster.

In addition, reliance on a single damage estimate as the 

primary indicator to determine whether a major disaster declaration is 

warranted does not provide a comprehensive assessment of a state’s 

capacity to respond to a disaster without federal assistance.

At the time of GAO’s recommendation, there was no requirement, as 

there is now, that FEMA develop metrics to assess state capabilities. The 

growing number of major disaster declarations highlights the need to reexamine the criteria used to assess state damages and also augment the 

damage indicator with a means of assessing state capabilities.18

 

17For example, per capita income does not include income produced in a state unless it is 

received as income by a state resident. Thus, profits retained by corporations for business 

investment, though potentially subject to state taxation, are not included in a state percapita income measure because they do not represent income received by state 

residents.

The 

figure below shows the actual increases in the per capita indicator for 

Public Assistance from 1986 to 2010 compared to the increases that 

would have occurred if FEMA had adjusted the indicator for inflation or 

the increase in per capita personal income during this period.

18Another potential method for calculating the public assistance damage estimate 

indicator is through the use of Total Taxable Resources, an indicator developed by the 

Department of the Treasury, which measures resources that are potentially subject to 

state taxation. GAO previously reported in 2001 that Total Taxable Resources provide a 

more sensitive adjustment for growth over time in a state’s fiscal capacity than the 

consumer price index. 
 

Page 326 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

FEMA Per Capita Indicator for Public Assistance and Alternate Measures

Because FEMA’s current per capita indicator does not reflect the rise in 

either (1) per capita personal income since it was created in 1986 or (2) 

inflation from 1986 to 1999, the indicator could be artificially low. Further, 

FEMA officials stated that the rise in construction and other costs to 

respond to and recover from disasters have outpaced the rise in the per 

capita indicator. As a result, states can receive disaster funding for 

relatively small damage estimates. FEMA officials stated that in states with 

smaller populations, damage to a single building or facility, such as a water 

treatment facility, could result in a damage estimate sufficient to meet the 

state per capita damage threshold and warrant a disaster declaration. 

Given the recent increase in disaster declarations, re-examining the basis 

for the per capita indicator would better position FEMA to assess a state’s 

capacity to respond to and recover from a disaster.

Based on GAO’s ongoing work, and given the experiences over the past 

decade and the inclusion of FEMA in DHS in 2003, GAO expects to 

reiterate its August 2001 recommendations and further recommend that 

the Secretary of Homeland Security direct the FEMA Administrator to 

implement them. GAO recommended that the FEMA Administrator

• re-examine the basis for the Public Assistance per capita indicator 

and determine whether it accurately reflects a state’s capacity to 

respond to and recover from a disaster without federal assistance.

Actions Needed and 

Potential Financial or 

Other Benefits
 

Page 327 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

• re-examine the method used to update the per capita indicator to 

ensure that the indicator accurately reflects annual changes in a 

state’s capacity to respond to and recover from a disaster.

We also expect to recommend that once FEMA has established the 

metrics required by both statute and Presidential Policy Directive to 

assess a state’s disaster preparedness and capabilities, FEMA should

• examine their usefulness in supplementing or replacing the per capita 

damage indicator on which FEMA now principally relies.

The data FEMA provided to GAO cannot be used to calculate the 

financial savings that may have been realized for prior disaster 

declarations had FEMA and the President used alternate indicators. For 

example, according to FEMA officials, they frequently stopped estimating 

damages for Public Assistance once the estimate equaled or exceeded 

the per capita indicator. Consequently, GAO cannot determine whether 

the estimated damages would have met or exceeded a higher, alternative 

per capita indicator. However, updating the current indicator to more 

accurately reflect the basis of and changes in a state’s capacity has the 

potential to reduce costs to the federal government in the future.

GAO provided a draft of this report section to DHS for review and 

comment. DHS generally agreed with the content as presented. DHS also 

provided technical comments, which were incorporated as appropriate. 

The information contained in this analysis is based on findings from 

products listed in the related GAO products section and additional work 

GAO conducted to be published as a separate product in 2012. GAO 

analyzed Disaster Relief Fund obligations and the criteria that FEMA uses 

to recommend to the President whether requests for disaster declarations 

should be approved. GAO also reviewed FEMA documents, policies, and 

briefings, as well as GAO’s prior findings and recommendations 

associated with this effort. Further, GAO collected and analyzed financial 

and nonfinancial data for disaster declarations requested and approved 

from fiscal years 2004 through 2011 to identify trends and opportunities 

for cost savings. GAO focused on Public Assistance funding because it 

represents the largest proportion of funds obligated from the Disaster 

Relief Fund for fiscal years 2004 through 2011.

Disaster Recovery: FEMA’s Public Assistance Grant Program 

Experienced Challenges with Gulf Coast Rebuilding. GAO-09-129. 

Washington, D.C.: December 18, 2008.

Disaster Cost Estimates: FEMA Can Improve Its Learning from Past 

Experience and Management of Disaster-Related Resources. 

GAO-08-301. Washington, D.C.: February 22, 2008.

Agency Comments 

and GAO’s Evaluation

How GAO Conducted 

Its Work

Related GAO 

Products 
 

Page 328 GAO-12-342SP Cost Savings or Revenue Enhancement Opportunities 

Disaster Assistance: Improvement Needed in Disaster Declaration 

Criteria and Eligibility Assurance Procedures. GAO-01-837. Washington, 

D.C.: August 31, 2001.

For additional information about this area, contact William O. Jenkins Jr. 

at (202) 512-8757 or jenkinswo@gao.gov. Contact Information
 

Page 329 GAO-12-342SP List of Congressional Addressees 

Appendix I: 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
 

Page 330 GAO-12-342SP List of Congressional Addressees 

The Honorable Tom Coburn

United States Senate

The Honorable Claire McCaskill

United States Senate

The Honorable Mark R. Warner

United States Senate
 

Page 331 GAO-12-342SP Objectives, Scope, and Methodology 

Appendix II: Objectives, Scope, and 

Methodology 

Section 21 of Public Law 111-139, enacted in February 2010, requires 

GAO to conduct routine investigations to identify federal programs, 

agencies, offices, and initiatives with duplicative goals and activities within 

departments and governmentwide. This provision also requires GAO to 

report annually to Congress on its findings, including the cost of such 

duplication, and recommendations for consolidation and elimination to 

reduce duplication and specific rescissions (legislation canceling 

previously enacted budget authority) that Congress may wish to 

consider.1

For the purposes of our analysis, we considered “duplication” to occur 

when two or more agencies or programs are engaged in the same 

activities or provide the same services to the same beneficiaries. We 

used the term “overlap” when multiple agencies or programs have similar 

goals, engage in similar activities or strategies to achieve them, or target 

similar beneficiaries. We used the term “fragmentation” to refer to those 

circumstances in which more than one federal agency (or more than one 

organization within an agency) is involved in the same broad area of 

national need and there may be opportunities to improve how the 

government delivers these services.

As agreed with the key congressional committees, our 

objectives in this report are to (1) identify what potentially significant areas 

of duplication, overlap, and fragmentation as well as opportunities for cost 

savings and enhanced revenues exist across the federal government; 

and (2) identify what options, if any, exist to minimize duplication, overlap, 

and fragmentation in these areas and take advantage of opportunities for 

cost savings and enhanced revenues.

2 This report presents 32 areas of 

duplication, overlap, or fragmentation where greater efficiencies or 

effectiveness in providing government services may be achievable. In 

light of the long-term fiscal imbalances that the federal government faces, 

and consistent with our approach for the first annual report, we also 

highlighted other opportunities for potential cost saving or revenue 

enhancements.

 

1

To date, this work has not identified a basis for proposing specific funding rescissions.

2

We recognize that there could be instances where some degree of program duplication, 

overlap, or fragmentation may be warranted due to the nature or magnitude of the federal 

effort.
 

Page 332 GAO-12-342SP Objectives, Scope, and Methodology 

To identify potentially significant areas of duplication, overlap, and 

fragmentation as well as opportunities for cost savings and enhanced 

revenues, for this and future reports we used a multiphased approach.

• Examination of budget functions and subfunctions of the federal 

government: We examined the OMB’s MAX Information System3

• Examination of key agency documents: When multiple federal 

agencies have similar missions, goals or programs, the potential for 

unnecessary duplication, overlap or fragmentation exists. As a result, 

we examined key agency documents such as strategic plans, 

performance and accountability reports, and budget justifications to 

determine and analyze their missions, goals, or programs.

fiscal year 2010 data to identify and analyze which federal agencies 

obligated funds for budget functions and subfunctions. Budget 

functions provide a system of classifying budget resources so that 

budget authority, outlays, receipts, and tax expenditures can be 

related to the national needs being addressed. Each budget account 

is generally placed in the single budget function (for example, national 

defense or health) that best reflects its major purpose, an important 

national need. A budget function may be divided into two or more 

subfunctions, depending on the complexity of the national need 

addressed. Because federal budget functions classify budget 

resources by important national need, identifying instances when 

multiple federal agencies obligate funds within a budget function or 

subfunction may indicate potential duplication or cost savings 

opportunities.

• Review of key external published sources: We reviewed key 

external published sources of information. For example, we reviewed 

reports published by the Congressional Budget Office, Inspectors 

General, the Congressional Research Service, as well as the 

President’s Budget to identify potential overlap and duplication among 

agency missions, goals, and programs.

Because it is impractical to examine all instances of potential duplication 

or opportunities for cost savings across the federal government, we 

considered a variety of factors to determine whether such potential 

instances or opportunities were significant enough to require additional 

examination. Such factors included, but were not limited to, the extent of 

potential cost savings, opportunities for enhanced program efficiency or 

effectiveness, the degree to which multiple programs may be duplicative, 

overlapping or fragmented, whether issues had been identified by GAO or 

external sources, and the level of coordination among agency programs. 

On the basis of this multiphased approach we identified areas of potential 

 

3

The MAX Information System is used to support the federal budget process. The system 

has the capability to collect, validate, analyze, model, and publish information relating to 

governmentwide management and budgeting activities and can also be used as an 

information sharing and communication portal between government organizations.

GAO’s Approach
 

Page 333 GAO-12-342SP Objectives, Scope, and Methodology 

duplication, overlap and fragmentation and opportunities for costs savings 

or revenue enhancement. GAO programmed work to examine these 

areas for reporting in this or future annual reports.

Each issue area contained in Sections I and II of this report lists any 

respective GAO reports and publications upon which it is based. Those 

prior reports contain more detailed information on our supporting work 

and methodologies. For issues based on GAO work that has not yet been 

published or those that update prior GAO work, we provide additional 

information on the methodologies used in that ongoing work or update in 

the section entitled “How GAO Conducted Its Work” of each issue area.

To identify what options, if any, exist to minimize duplication, overlap, and 

fragmentation and take advantage of opportunities for cost savings and 

enhanced revenues, we reviewed and updated prior GAO work and 

recommendations to identify what additional actions agencies may need 

to take and Congress may wish to consider. For example, we used a 

variety of previously issued work identifying leading practices that could 

help agencies address challenges associated with interagency 

coordination,4 achieving efficiencies,5 and managing user fees.6

To identify the potential financial and other benefits that might result from 

actions addressing duplication, overlap, or fragmentation, we collected 

and analyzed data on costs and potential savings to the extent it was 

available. Estimating the benefits that could result from eliminating 

unnecessary duplication, overlap, or fragmentation was not possible in 

some cases because information about the extent of unnecessary 

duplication among certain programs was not available. Further, the 

financial benefits that can be achieved from eliminating duplication, 

overlap, or fragmentation were not always quantifiable in advance of 

congressional and executive branch decision making, and needed 

information was not readily available on, among other things, program 

performance, the level of funding devoted to overlapping programs, or the 

implementation costs and time frames that might be associated with 

program consolidations or terminations.

We also included tables in appendix III that provide a detailed listing of 

federally-funded program names and associated budgetary information. 

While there is no standard definition for what constitutes a program, they 

may include grants, tax expenditures, centers, loans, funds, and other 

 

4

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

5

GAO, Streamlining Government: Key Practices from Select Efficiency Initiatives Should 

Be Shared Governmentwide, GAO-11-908 (Washington, D.C.: Sept. 30, 2011).

6

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

2008).

Identifying Options
 

Page 334 GAO-12-342SP Objectives, Scope, and Methodology 

types of assistance. A wide variety of budgetary information may be used 

to convey the federal commitment to these programs. When available, we 

collected obligations information for fiscal year 2010 for consistent 

reporting across issue areas. In some instances, obligations data were 

not available, but we were able to report other budgetary information, 

such as appropriations. In other issue areas, we did not report any 

budgetary information, because such information was either not available 

or sufficiently reliable. For example, some agencies could not isolate 

budgetary information for some programs, because the data were 

aggregated at higher levels.

We assessed the reliability of any computer-processed data that 

materially affected our findings, including cost savings and revenue 

enhancement estimates. The steps that GAO takes to assess the 

reliability of data vary but are chosen to accomplish the auditing 

requirement that the data be sufficiently reliable given the purposes it is 

used for in our products. GAO analysts review published documentation 

about the data system and Inspector General or other reviews of the data.

GAO may interview agency or outside officials to better understand 

system controls and to assure ourselves that we understand how the data 

are produced and any limitations associated with the data. GAO may also 

electronically test the data to see if values in the data conform to agency 

testimony and documentation regarding valid values, or compare data to 

source documents. In addition to these steps, GAO often compares data 

with other sources as a way to corroborate our findings. Per GAO policy, 

when data do not materially affect findings and are presented for 

background purposes only, we may not have assessed the reliability 

depending upon the context in which the data are presented.

This report is based substantially on previously issued GAO products and 

ongoing audits, which were conducted in accordance with generally 

accepted government auditing standards, or with our Quality Assurance 

Framework, as appropriate. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives. For 

issues where information is being reported on for the first time in this 

report, GAO sought comments from the agencies involved and 

incorporated their comments, as appropriate.
 

Page 335 GAO-12-342SP Lists of Programs Identified

Appendix III: Lists of Programs Identified 

This appendix includes lists of federal programs or other activities related 

to issue areas in this report, and their fiscal year 2010 obligations data, 

where such information was available. In some cases, we did not report 

budgetary information because it was either not available or sufficiently 

reliable. For some issue areas, agencies were not able to readily provide 

programmatic information needed to determine whether and to what 

extent programs are actually duplicative. Additionally, in some instances 

of duplication, overlap, or fragmentation, it may be appropriate for multiple 

agencies or entities to be involved in the same programmatic or policy 

area due to the nature or magnitude of the federal effort.
 

Page 336 GAO-12-342SP Lists of Programs Identified

Table 1: Electronic Warfare: List of Programs and Related Budgetary Information

Agency Program 

FY 2010 

obligations 

Department of Defense

Airborne Electronic Attack Systems for Irregular Warfare

Air Force MQ-9 Reaper Electronic Attack Pod $0

Army Communications Electronic Attack with 

Surveillance and Reconnaissance 

13,752,000

Marine Corps Collaborative Online Reconnaissance 

Provider Operationally Responsive 

Attack Link 

8,359,000

Intrepid Tiger II 4,457,000

Total $26,568,000

Airborne Electronic Attack Systems for Near-Peer Conflicts

Air Force Miniature Air Launched Decoy – Jammer 

Increment II

$8,423,044

Navy Airborne Electronic Attack Expendable 3,941,000 

Total $12,264,044

Source: GAO analysis of Department of Defense data. 
 

Page 337 GAO-12-342SP Lists of Programs Identified

Table 2: Unmanned Aircraft Systems: List of DOD Systems and Subsystems and Related Budgetary Information

Unmanned Aircraft Systems

Agency Systems and Subsystemsa,b

FY 2010 

obligationsc

Aircraftd

Air Force MA-9A Reaper $1,928,888

Air Force RQ-4A/B Global Hawk 1,543,111

Navy MQ-4C BAMS/BAMS-D (Broad Area Maritime Surveillance) 438,199

Army A160 Hummingbird e

Army MQ-1C Gray Eagle/Warrior A 951,531

Army MQ-5B Hunter e

Air Force MQ-1A/B Predator 696,704

Navy MQ-8B Fire Scout Vertical Take-off and Landing Tactical Unmanned Air Vehicle 

(VTUAV) 

242,912

Air Force MQ-X e

USMC Cargo Unmanned Aircraft System (UAS) 53,000

Army Vertical Take-off and Landing Unmanned Aircraft System (VTOL UAS) 0 

Navy Medium Range Maritime Unmanned Aircraft System (MRMUAS) 0 

Navy Unmanned Carrier Launched Airborne Surveillance and Strike (UCLASS) 0 

Payloads – Signals Intelligence

Air Force Enhanced Integrated Sensor Suite, Advanced Signals Intelligence Program 

(EISS/ASIP) (Blk 30M)

e

Air Force Advanced Signals Intelligence Program (ASIP) 2-C e

Air Force Blue Moon e

Navy MCS-21 e

Navy LR-100 e

Army ARGUS e

Army TSP 19,393

Air Force ACES HY e

Payloads – EO/IR

Air Force/Navy Integrated Sensor Suite (ISS) (Blk 10) e

Air Force Integrated Sensor Suite (ISS) (Blk 20) e

Air Force Enhanced Integrated Sensor Suite (EISS) (Blk 30) e

Air Force Enhanced Integrated Sensor Suite, Advanced Signals Intelligence Program 

(EISS/ASIP) (Blk 30M)

e

Air Force Gorgon Stare 45,984

Navy/Air Force MTS-B (AN/DAS-1) e

Army/Air Force MTS-B (AN/DAS-2) e

Army ARGUS e

Army MX-15HDi e

Army CSP Upgrade e

Army MOSP 3000 e

Army/Air Force CSP (AN/AAS-53) e

Air Force MTS-A e

Navy Bright Star II e
 

Page 338 GAO-12-342SP Lists of Programs Identified

Unmanned Aircraft Systems

Agency Systems and Subsystemsa,b

FY 2010 

obligationsc

Payloads – Radar

Air Force Multi-Platform Radar Technology Insertion Program (MP-RTIP) 71,901

Air Force DDR e

Air Force Enhanced Integrated Sensor Suite, Advanced Signals Intelligence Program 

(EISS/ASIP) (Blk 30M)

e

Navy MFAS e

Army STARLite ER e

Army LYNX I e

Army/Air Force LYNX II e

Ground Control Stations

Air Force MD-1A/B/C/D e

Navy MQ-4C Broad Area Maritime Surveillance (BAMS) FOB/MOB e

Air Force/Navy RD-2A/B e

Army Hummingbird/Argus GCS e

Army Legacy GCS e

Army UGCS e

Navy Fire Scout GCS e

Army/USMC Shadow GCS e

Navy/USMC Small Tactical Unmanned Aircraft Systems (STUAS GCS) e

Army/USMC OSGCS BLK I/II/III e

Source: GAO analysis of Department of Defense data.

a

List includes Quick Reaction Capability programs used to satisfy near-term urgent warfighting needs.

b

EISS/ASIP (BLK 30M) and ARGUS payloads perform more than one function. 

c

Dollars are then year in thousands. 

d

Aircraft listed include five future programs. 

e

The Department of Defense Programs Funding documentation did not include a budget line for this 

program. 
 

Page 339 GAO-12-342SP Lists of Programs Identified

Table 3: Support for Entrepreneurs: List of Programs and Related Budgetary Information

Support for Entrepreneurs

Agency Program FY 2010 obligations 

Department of Commerce

Economic Development 

Administration 

Grants for Public Works and Economic Development 

Facilities

$158,930,000

Economic Development/ Support for Planning 

Organizations

31,391,000 

Economic Development/ Technical Assistance 9,800,000 

Economic Adjustment Assistance 45,270,000 

Trade Adjustment Assistance 18,987,000 

Global Climate Change Mitigation Incentive Fund 25,000,000 

Minority Business Development 

Agency 

Minority Business Centers (merged the former Minority 

Business Enterprise Centers and Minority Business 

Opportunity Center programs) 

10,113,693 

Native American Business Enterprise Centers 1,351,500 

U.S. Department of Agriculture

Empowerment Zones 500,000

Woody Biomass Utilization Grant Program 5,000,000 

1890 Land Grant Institutions Rural Entrepreneurial 

Outreach Program/Rural Business Entrepreneur 

Development Initiative/Business Information System 

Network

0 

Small Business Innovation Research 22,000,000

Biomass Research and Development Initiative 

Competitive Grants Program

0 

Value Added Producer Grants 19,400,000

Agriculture Innovation Center 0 

Small Socially-Disadvantaged Producer Grants 3,500,000 

Intermediary Re-lending 8,500,000

Business and Industry Loans 52,900,000

Rural Business Enterprise Grants 38,700,000

Rural Cooperative Development Grants 8,300,000 

Rural Business Opportunity Grants 2,500,000 

Rural Microentrepreneur Assistance Program 9,000,000

Department of Housing and Urban Development

Community Development Block Grant/Entitlement 

Grants

2,760,223,970

Community Development Block Grant /Special 

Purpose/Insular Areas

6,930,000 

Community Development Block Grant /States 1,176,594,747 

Community Development Block Grant /Non-entitlement 

Community Development Block Grant Grants in Hawaii

5,791,797 

Community Development Block Grant /Brownfields 

Economic Development Initiative 

17,500,000 

Community Development Block Grant /Section 108 

Loan Guarantees

 6,000,000 

Section 4 Capacity Building for Affordable Housing and 

Community Development

50,000,000 
 

Page 340 GAO-12-342SP Lists of Programs Identified

Support for Entrepreneurs

Agency Program FY 2010 obligations 

Rural Innovation Fund 25,000,000 

Community Development Block Grant Disaster 

Recovery Grants 

100,000,000

Indian Community Development Block Grant 65,000,000 

Hispanic Serving Institutions Assisting Communities 6,250,000

Alaska Native/Native Hawaiian Institutions Assisting 

Communities

3,265,000

Small Business Administration 

8(a) Business Development Program 56,817,000 

7(j) Technical Assistance 3,275,000

Procurement Assistance to Small Businesses 3,164,000

Small Business Investment Companies 24,262,000

7(a) Loan Program 518,869,000 

Surety Bond Guarantee Program 0 

Service Corps of Retired Executives 7,000,000

Small Business Development Centers 112,624,000

504 Loan Program 70,645,000

Women’s Business Centers 13,997,000

Veterans’ Business Outreach Centers 2,500,000

Microloan Program 42,901,000

Program for Investment in Micro-Entrepreneurs 8,000,000

New Markets Venture Capital Program 0 

7(a) Export Loan Guarantees 0 

Historically Underutilized Business Zones 2,189,000

Small Business Technology Transfer Program 0 

Small Business Innovation Research Program 0 

Federal and State Technology Partnership Program 2,000,000

Total $5,561,941,707 

Source: GAO analysis of Department of Commerce, U.S. Department of Agriculture, Department of Housing and Urban Development, 

and Small Business Administration data. 
 

Page 341 GAO-12-342SP Lists of Programs Identified

Table 4: Surface Freight Transportation: List of Programs 

Surface Freight Transportation

Agency Program

Department of Transportation 

Federal Highway Administration National Highway System

Interstate Maintenance

Surface Transportation Program

Highway Bridge Program

Congestion Mitigation & Air Quality

Appalachian Development Highway System

Metropolitan Planning

Highway Safety Improvement Program

Railway-Highway Crossings

Coordinated Border Infrastructure Program

Equity Bonus

Denali Access System Program

Freight Intermodal Distribution Pilot Grant Program

Great Lakes Intelligent Transportation System Implementation

Multimodal Facility Improvements

National Work Zone Clearinghouse

Operation Lifesaver

Pavement Marking Systems

Road Safety (Data and Public Awareness)

Road User Fee Study

Set-aside for Minneapolis/St. Paul-Chicago segment (from Crossing Hazard Elimination)

Set-aside for Alaska, New Jersey, and Washington for projects on the NHS (from Ferry Boats)

Interstate Maintenance Discretionary Program

Territorial Highway Program

Alaska Highway

Indian Reservation Roads

Public Lands Highways

Park Roads and Parkways

Lake Tahoe

Bureau of Transportation Statistics

Highway Use Tax Evasion Program

Rail Highway Crossing Hazard Elimination in High Speed Rail Corridors (after set-aside)

Construction of Ferry Boat and Ferry Terminal Facilities (after set-asides)

Puerto Rico Highway Program

Indian Reservation Road Bridges

Transportation Infrastructure Finance and Innovation Act

Value Pricing Pilot Program

Highways for Life

Truck Parking Facilities

Delta Region Transportation Development Program

Work Zone Safety Grants
 

Page 342 GAO-12-342SP Lists of Programs Identified

Surface Freight Transportation

Agency Program

Undesignated High Priority Projects

Surface Transportation Research, Development, and Deployment Program

Future Strategic Highway Research Program

Training and Education

University Transportation Research

Intelligent Transportation System Research

Emergency Relief Program

Federal Motor Carrier Safety 

Administration

Border Enforcement Grant

Commercial Vehicle Information Systems and Networks Deployment Grant

Federal Railroad Administration Railroad Rehabilitation & Improvement Financing

Rail Line Relocation and Improvement Program

Maritime Administration Federal Ship Financing Program

Small Shipyard Grants

Office of the Secretary Transportation Investment Generating Economic Recovery (TIGER) Program

Source: GAO analysis of Department of Transportation data.

Note: This table includes grant programs and other forms of financial assistance for freight 

transportation infrastructure. Budgetary data are not included with these programs because the 

majority of these programs benefit both freight and passenger transportation. According to 

Department of Transportation officials, it is not possible to isolate program costs associated with just 

freight transportation. 
 

Page 343 GAO-12-342SP Lists of Programs Identified

Table 5: Department of Justice Grants: List of Agencies and Related Budgetary 

Information

Agency 

FY 2010 obligations for 

grants 

Office of Justice Programsa $2,608,000,000

Community Oriented Policing Services Office 547,000,000 

Office on Violence Against Women 844,000,000 

Source: GAO analysis of Department of Justice data. 

a

Office of Justice Programs is comprised of a number of smaller bureaus and offices, including the 

Bureau of Justice Assistance, the Bureau of Justice Statistics, the Community Capacity Development 

Office, the National Institute of Justice, the Office of Juvenile Justice and Delinquency Prevention, the 

Office of Victims of Crime, and the Sex Offender Sentencing, Monitoring, Apprehending, Registering, 

and Tracking Office. 
 

Page 344 GAO-12-342SP Lists of Programs Identified

Table 6: Homeland Security Grants: List of Major Programs and Related Budgetary 

Information

Agency Program

FY 2010 

obligations 

Department of Homeland Security

Federal Emergency 

Management Agency

State Homeland Security Program $852,000,000

Urban Areas Security Initiative 851,520,000

Port Security Grant Program 288,000,000

Transit Security Grant Programa 268,000,000

Total $2,259,520,000

Source: GAO analysis of Department of Homeland Security data. 

a

These obligations include grants to transit systems, Amtrak, and freight rail. 
 

Page 345 GAO-12-342SP Lists of Programs Identified

Table 7: Information Technology Investment Management: List of Investments and Related Budgetary Information 

Dollars in thousands

Information Technology Investment Management

Agency Investment Similar purpose

Total IT spending 

for fiscal years 

2007-2012

Department of Defense

Executive Performance and Appraisal Tool Civilian Personnel 

Management

$591

Defense Civilian Personnel Data System 503,280

Air Force Contract Writing System Contract Management 4,663

Automated Contract Preparation System 22,604

Contracting Information Database System 9,952

Acquisition and Due In System 2,290

Contract Profit Reporting Systems 1,183

Army Enlisted Distribution and Assignment System Personnel Assignment 

Management

11,545

Assignment Satisfaction Key 6 

Navy Naval Sea Systems Command Acquisition Capabilities Acquisition 

Management

3,347

Space and Naval Warfare Systems Command Acquisition 

Capabilities

129,149

Naval Sea Systems Command Systems Acquisition Management 

Capabilities

3,486

Space and Naval Warfare Systems Command Systems 

Acquisition Management Capabilities

271,084

Navy Decision Knowledge Programming for Logistics Analysis and 

Technical Evaluation

Aviation Maintenance 

and Logistics

50,195

Airborne Weapons Info System 34,308

Navy Integrated Technical Item Management Program Contract Management 10,267

Space and Naval Warfare Systems Command Contract 

Information Management System

858

Space and Naval Warfare Systems Command Systems Center 

Atlantic Contract Information Management System

22

Contract Data Requirements List 539

Acquisition Management Automation System 4,889

Navy APPLY/SLATER Housing Management 671

Commander, Navy Installations Command Manpower/Billets 4,154

Navy Career Management System Interactive Detailing Personnel Assignment 

Management

14,180

Officer Assignment Information System II 1,014

Enlisted Assignment information System 1,408

Reserve Order Writing System 11,527

Navy Fleet Rating Identification System Promotion Rating 2,749

Departmental Systems 610

Navy Total Force Administration System Workforce Management 89,601

Manpower Models 13,819

Total Workforce Management System 5,704
 

Page 346 GAO-12-342SP Lists of Programs Identified

Information Technology Investment Management

Agency Investment Similar purpose

Total IT spending 

for fiscal years 

2007-2012

Department of Energy

Energy Programs Office of Science Headquarters Back-end Infrastructure Back-end Infrastructure 250

Office of Science Oak Ridge Back-end Infrastructure 648

Office of Science Chicago Back-end Infrastructure 93

Environmental and 

Other Defense 

Activities

Environmental Management Carlsbad Field Office Electronic 

Records and Document Mgmt System

Electronic Records and 

Document Management

4,337

Health and Safety Electronic Document Review System 1,418

Office of Legacy Management Record Management System 1,003

Total $1,217,444a

Source: GAO analysis of Department of Defense and Department of Energy data.

a

The $2 million difference between the $1.219 billion total presented in the report, and the $1.217 

billion total presented in this appendix table, is due to rounding. 
 

Page 347 GAO-12-342SP Lists of Programs Identified

Table 8: Diesel Emissions: List of Programs and Related Budgetary Information 

Agency Program

FY 2010 

obligations 

Department of Energy Clean Cities Programa $301,635,084

Energy Efficiency and Conservation Block Grant Programa 121,030,300

State Energy Program 0 

Department of Transportation

Federal Aviation Administration Voluntary Airport Low Emissions Program 5,971,868

Federal Highway Administration Congestion Mitigation and Air Quality Improvement Program 22,046,617

Ferry Boat Discretionary Programa 4,285,422

State Infrastructure Banks Program 0 

Federal Transit Administration Bus and Bus Facilities Program b

Clean Fuels Grants Program 2,732,667

National Fuel Cell Bus Technology Development Program 45,000

Transit in Parks Program 0 

Transit Investments for Greenhouse Gas and Energy Reduction Programa 40,010,000

Urbanized Area Formula Grant Programa b

Environmental Protection 

Agency

Diesel Emissions Reduction Act Programa 238,511,081

Total $736,268,039

Source: GAO analysis of Department of Energy, Department of Transportation, and Environmental Protection Agency documents.

Notes: Three tax expenditures—biodiesel producer tax credits, a diesel fuel emulsion excise tax 

credit, and an excise tax exemption for idling reduction devices—also provide incentives for owners 

and operators of diesel engines and vehicles to reduce emissions. 

GAO identified these 14 programs as providing funding for activities that reduce mobile source diesel 

emissions. While one program—the Environmental Protection Agency's Diesel Emissions Reduction 

Act Program—has a specific purpose of reducing mobile source diesel emissions, the remaining 13 

programs focus on other goals or purposes, and may not fund mobile source diesel emissions 

reduction activities in a particular year. 

a

The American Recovery and Reinvestment Act of 2009 provided a portion of these funds. 

b

The Department of Transportation was unable to determine the amount of funding this program 

awarded for projects that reduced mobile source diesel emissions. 
 

Page 348 GAO-12-342SP Lists of Programs Identified

Table 9: Green Building: List of Initiatives 

Green Building

Agency Initiative 

U.S. Department of Agriculture 

High Energy Cost Grant Program

Rural Energy for America 

Rural Housing Service Section 502 Direct and Guaranteed Loan 

Assistance and Section 504 Loan and Grant Assistance for the 

Rural Economic Development Energy Efficiency initiative

Rural Housing Service Section 502 Direct and Guaranteed Loan 

Assistance for the Rural Energy Plus Program

Rural Housing Service Section 514 and Section 516 Assistance for 

Farm Labor Housing 

Rural Housing Service Section 515 Assistance for Low-income, 

Elderly, and Handicapped Housing

Rural Utilities Service Electric Loan Programs

Section 538 Guaranteed Rural Rental Housing Program

Department of Defense

Environmental Security Technology Certification Program

Department of Education

Impact Aid Construction Program

State Fiscal Stabilization Fund

Department of Energy

Building Technologies Program/Commercial Building 

Integration/Commercial Building Initiative 

Building Technologies Program/Emerging Technologies 

Building Technologies Program/Home Energy Score Pilot Program 

Building Technologies Program/Residential Buildings Integration

Building Technologies Program/Residential Buildings 

Integration/Solar Decathlon 

Building Technologies Program/Technology Validation and Market 

Introduction/Building Energy Codes 

Energy Efficient Building Systems Regional Innovation Cluster 

Initiative 

Energy Transformation Acceleration Fund/Advanced Research 

Projects Agency/Building Energy Efficiency Through Innovative 

Thermodevices 

Small Business Innovation Research and Small Business 

Technology Transfer programs 

State Energy Efficient Appliance Rebate Program 

Superior Energy Performance Program 

Title 17 Loan Guarantee Program 

Weatherization and Intergovernmental Activities/Energy Efficiency 

and Conservation Block Grant 

Weatherization and Intergovernmental Activities/State Energy 

Program

Weatherization and Intergovernmental Activities/Tribal Energy 

Program 

Weatherization and Intergovernmental Activities/Weatherization 

Assistance Program

Weatherization Innovation Pilot Program

Department of Health and Human Services

Low Income Home Energy Assistance Program
 

Page 349 GAO-12-342SP Lists of Programs Identified

Green Building

Agency Initiative 

Department of Housing and Urban Development

Capital Fund Recovery Act Competitive Grant Program

Choice Neighborhoods

Green Retrofit Program for Multifamily Housing 

Healthy Homes Program 

HOME Investment Partnerships Program 

Hope VI Revitalization Grant Program 

Indian Community Development Block Grant Program 

Indian Housing Block Grant Program

Mark to Market Green Initiative 

Moving to Work Demonstration Program

Multifamily Energy Innovation Fund 

PowerSaver Pilot Program 

Public Housing Environmental and Conservation Clearinghouse 

Public Housing Operating Fund, Energy Performance Contract 

Incentives 

Public Housing Operating Fund, Streamlining Energy Performance 

Contracting 

Section 203(b) Mortgage Insurance, Energy Efficient Mortgage

Section 203(b) Mortgage Insurance, Weatherization

Section 203(k) Mortgage Insurance, Section 203(k) Streamlined 

Mortgage Insurance

Supportive Housing for Persons with Disabilities (Section 811)

Supportive Housing for the Elderly (Section 202) 

Sustainable Communities Initiative, Capacity-building Program and 

Tools Clearinghouse

Sustainable Communities Initiative, Housing-Transportation 

Integration Research

Sustainable Communities Initiative, Sustainable Communities 

Regional Planning Grants

Sustainable Communities Initiative, Sustainable Community 

Challenge Grants

Title I Property Improvement Loan Insurance Program (Title I 

Program) 

Transformation Initiative, Energy Efficiency and Green Building 

Across Affordable Housing Program

Transformation Initiative, Green and Healthy Homes

Transformation Initiative, Sustainable Building Practice

Transformation Initiative, Sustainable Communities Grant Program 

Department of Transportation

Federal Transit Administration Bus and Bus Facilities Program

Federal Transit Administration Environmental Management 

Systems Training and Technical Assistance

Federal Transit Administration Transit Investments for Greenhouse 

Gas and Energy Reduction

Federal Transit Administration Urbanized Area Formula Program 

Formula Grants for Other than Urbanized Areas

Department of the Treasury

Accelerated Depreciation Deduction for Specified Energy Property

Energy Efficient Commercial Buildings Deduction 

Energy Investment Tax Credit

New Energy Efficient Home Credit

Nonbusiness Energy Property Tax Credit 
 

Page 350 GAO-12-342SP Lists of Programs Identified

Green Building

Agency Initiative 

Payments for Specified Energy Property in Lieu of Tax Credits 

Residential Energy Conservation Subsidy Exclusion 

Residential Energy Efficient Property Credit 

Environmental Protection Agency

Brownfields Program

Design for the Environment Program

Energy Star Program 

Environmentally Preferable Purchasing Program

Environmentally Responsible Redevelopment and Reuse

Green Communities Program

Green Infrastructure Program

Green Power Partnership

Healthy Communities—Clean, Green, and Healthy Schools

Heat Island Reduction Program 

Indoor Environments Program 

Industrial Materials Recycling Program

Pesticide Environmental Stewardship Program 

Small Business Innovation Research Program

Smart Growth Program 

Tribal Green Building Initiative

WasteWise

WaterSense

National Institute of Standards and Technology 

Advanced Building Energy Technologies Program

Embedded Intelligence in Buildings Program

Improved Building Energy Performance Program 

Small Business Administration

Certified Development Company 504 Loan Program

Small Business Energy Audit and Energy Efficiency Program

Source: GAO analysis of agency information and questionnaire responses. 

Note: GAO requested funding information for all initiatives, but the information agencies provided was 

incomplete and unreliable for the purposes of describing the size of green building initiatives. Agency 

officials stated that many of the initiatives are part of broader programs and, as such, the agencies do 

not track green building funds separately from other program activities. 
 

Page 351 GAO-12-342SP Lists of Programs Identified

Table 10: Housing Assistance: List of Programs, Activities, and Tax Expenditures and Related Budgetary Information

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Purpose: Assistance for buying, selling, or financing a home

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Department of Housing and Urban 

Development

Self-Help Homeownership 

Opportunity Program 

$26,500,000 

One- to Four-Family Home 

Mortgage Insurance (Section 

203(b)) 

-$2,546,000,000 For loan programs these 

obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured, which in some cases 

may be 30 years. The 

obligations reported are for 

guarantees of single family loans 

insured under the Mutual 

Mortgage Insurance Fund. The 

loan program called One- to 

Four-Family Home Mortgage 

Insurance (Section 203(b)) is the 

single largest loan program in 

this Fund. 

Mortgage Insurance for Disaster 

Victims (Section 203(h)) 

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)). 

Rehabilitation Loan Insurance 

(Section 203(k)) 

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)).

Single Family Property 

Disposition Program (Section 

204(g)) 

Included in obligations 

under Mutual Mortgage 

Insurance Fund

Costs/savings associated with 

property disposition are among 

the items factored into subsidy 

rates. See note for One- to FourFamily Home Mortgage 

Insurance (Section 203(b)).

Self-Help Housing Property 

Disposition

Included in obligations 

under Mutual Mortgage 

Insurance Fund

Costs/savings associated with 

property disposition are among 

the items factored into subsidy 

rates. See note for One- to FourFamily Home Mortgage 

Insurance (Section 203(b)).

Loss Mitigation Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)).

Graduated Payment Mortgage 

(Section 245(a)) 

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)). 

Adjustable Rate Mortgages 

(Section 251) 

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)). 
 

Page 352 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Home Equity Conversion 

Mortgage Program (Section 255)

-$106,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured. The Home Equity 

Conversion Mortgage Program is 

part of the Mutual Mortgage 

Insurance Fund but has separate 

subsidy costs which are reported 

here.

Manufactured Homes Loan 

Insurance (Title I) 

-$1,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments under this 

program made in fiscal year 

2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured, which in some cases 

may be 30 years. This loan 

program is part of the General 

Insurance and Special Risk 

Insurance Fund, which houses a 

wide range of mortgage 

insurance products, including 

insurance for loans to develop, 

rehabilitate, and refinance 

multifamily rental housing, 

nursing home facilities, and 

hospitals. The General 

Insurance and Special Risk 

Insurance Fund programs also 

include loan guarantees for Title 

I Property Improvement loans. 

Property Improvement Loan 

Insurance (Title I) 

see note Expected credit subsidy costs 

are less than $500,000. See 

note for Manufactured Homes 

Loan Insurance.

Good Neighbor Next Door Included in obligations 

under Mutual Mortgage 

Insurance Fund

Costs/savings associated with 

property disposition are among 

the items factored into subsidy 

rates. See note for One- to FourFamily Home Mortgage 

Insurance (Section 203(b)). 

Energy Efficient Mortgage 

Insurance 

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)). 

Energy Efficient Mortgage 

Innovation Pilot

None Program created in fiscal year 

2010; however no funds were 

obligated in that year. In fiscal 

year 2011 $13 million was 

obligated to the Energy Efficient 

Mortgage Innovation Pilot.

Insured Mortgages on Hawaiian 

Home Lands (Section 247) 

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)). 
 

Page 353 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Insured Mortgages on Indian 

Land (Section 248)

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)). 

Mortgage Insurance for 

Condominium Units (Section 

234(c))

None Program is not active. 

Condominiums are now insured 

under Section 203(b) program.

Mortgage Insurance for Older, 

Declining Areas (Section 223(e))

None No loans made in fiscal year 

2010. 

Growing Equity Mortgage 

Insurance (Section 245(a))

None No loans made in fiscal year 

2010. 

Mortgage Insurance for 

Cooperative Housing (Section 

213)

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)).

Single Family Cooperative 

Housing Mortgage Insurance

Included in obligations 

under Mutual Mortgage 

Insurance Fund

See note for One- to Four-Family 

Home Mortgage Insurance 

(Section 203(b)). 

Homeownership Voucher 

Assistance 

Included in obligations for 

Housing Choice Voucher 

Program

 

Public Housing Homeownership 

(Section 32)

None Program is no longer active.

Loan Guarantees for Indian 

Housing (Section 184)

$4,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.

Loan Guarantees for Native 

Hawaiian Housing (Section 

184A)

$1,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.

Department of Agriculture Section 523 Self-Help Housing None No loans were made in fiscal 

year 2010.

Section 524 Site Development None No loans were made in fiscal 

year 2010.

Section 523 Mutual and SelfHelp Housing Technical 

Assistance Grants

$43,000,000 

Section 502 Rural Housing 

Single Family Loans-Direct

$78,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010, including loans 

authorized under the American 

Recovery and Reinvestment Act 

of 2009. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.
 

Page 354 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Section 502 Rural Housing 

Single Family LoansGuaranteed

$204,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010, including loans 

authorized under the American 

Recovery and Reinvestment Act 

of 2009. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.

Section 509(f) Housing 

Application Packaging Grants 

None No grants were made in fiscal 

year 2010.

Section 502 Mutual Self-Help 

Housing Loan 

Included in obligations for 

Section 502 Direct loan 

 

Department of Veterans Affairs Veterans Administration Home 

Loan Guaranty 

-$107,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.

Veterans Housing Manufactured 

Home Loans

None No loans were made in fiscal 

year 2010.

Native American Veterans Direct 

Loan Program

-$5,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.

Agency/entity Activity/program

FY 2010 estimated 

revenue lossesa Explanatory notes

Internal Revenue Service Capital gains exclusion on home 

sales

$22,160,000,000

Deduction for mortgage 

insurance premiums

$300,000,000 Revenue losses for fiscal year 

2010 were estimated by the Joint 

Committee on Taxation in 

Estimates of Federal Tax 

Expenditures for Fiscal Years 

2010-2014, JCS-3-10. This 

provision expired on December 

31, 2011.

District of Columbia first-time 

homebuyer tax credit

see note Revenue losses for fiscal year 

2010 were not estimated by the 

Department of the Treasury in 

Analytical Perspectives, Budget 

of the U.S. Government, Fiscal 

Year 2012, nor by the Joint 

Committee on Taxation in 

Estimates of Federal Tax 

Expenditures for Fiscal Years 

2010-2014, JCS-3-10. This 

provision expired on December 

31, 2011.
 

Page 355 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Purpose: Supports housing and other activities

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Federal Home Loan Banks Community Investment Program None The Community Investment 

Program is not included in the 

federal budget. 

Department of Housing and Urban 

Development

Community Development Block 

Grants (CDBG) Entitlement

$1,025,687,000 Obligations represent an 

estimate of the total used for 

activities related to housing.

CDBG States and Small Cities Included in obligations 

under CDBG Entitlement

 

CDBG Section 108 Loan 

Guarantee

see note Obligations for CDBG Section 

108 Loan Guarantee in fiscal 

year 2010 were $4 million; some 

amount of the obligations may 

be attributable to activities 

related to housing. Obligations 

represent the expected credit 

subsidy costs for loan 

commitments made in fiscal year 

2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.

CDBG Disaster Recovery 

Assistance 

see note Obligations for CDBG Disaster 

Recovery Assistance in fiscal 

year 2010 were $4.304 billion; 

some amount of obligations may 

be attributable to activities 

related to housing.

CDBG Section 107 see note Obligations for CDBG Section 

107 in fiscal year 2010 were $2.1 

million; some amount of 

obligations may be attributable to 

activities related to housing. 

CDBG Insular Areas Included in obligations 

under CDBG Entitlement

 

HOME Investment Partnerships $1,857,423,000 

Housing Trust Fund None Program authorized in 2008, 

however no funding has been 

appropriated.

Capacity Building for Community 

Development and Affordable 

Housing

$34,000,000 

Housing Opportunities for 

Persons With AIDS 

$314,220,000 

Counseling for Homebuyers, 

Homeowners, and Tenants 

(Section 106) 

$65,168,000 

Manufactured Home 

Construction and Safety 

Standards

$8,731,000 
 

Page 356 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Dollar Home Sales Included in obligations 

under Mutual Mortgage 

Insurance Fund

Costs/savings associated with 

property disposition are among 

the items factored into subsidy 

rates. See note for One- to FourFamily Home Mortgage 

Insurance (Section 203(b)). 

Choice Neighborhoods Included in obligations for 

HOPE VI

 

Indian Community Development 

Block Grant 

see note Obligations for the Indian 

Community Development Block 

Grant in fiscal year 2010 were 

$65.332 million; some amount of 

obligations may be attributable to 

activities related to housing.

Native American Housing Block 

Grants

$761,650,000 

Federal Guarantees for 

Financing for Tribal Housing 

Activities (Title VI) 

see note Expected credit subsidy costs 

are less than $500,000 for loan 

commitments made in fiscal year 

2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured. 

Native Hawaiian Housing Block 

Grant Program

$13,333,000 

Healthy Homes Initiative $19,765,000 

Sustainable Communities 

Initiative

$66,000 

Lead Hazard Control Grants $66,600,000 

Lead Hazard Demonstration 

Project 

$48,000,000 

Lead Hazard Reduction 

Technical Studies and Support

$4,000,000 

Housing Assistance Council $5,000,000 

Neighborhood Reinvestment 

Corporation

Neighborhood Reinvestment 

Corporation, also known as 

“NeighborWorks America”

$233,000,000 Federal obligations provided 

$168 million in base funding and 

an additional $65 million for 

activities related to foreclosure 

counseling mitigation and 

prevention. The Neighborhood 

Reinvestment Corporation 

receives both federal and nonfederal funding to finance its 

program activities.
 

Page 357 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Department of the Treasury Community Development 

Financial Institutions Fund

see note The Community Development 

Financial Institutions Fund 

provides funding for multiple 

initiatives that may support 

housing. In fiscal year 2010 $108 

million was obligated to providing 

awards to Community 

Development Financial 

Institutions for financial and 

technical assistance to further 

affordable housing, among other 

goals. Additionally, in fiscal year 

2010 $80 million was obligated 

for the Capital Magnet Fund to 

increase capital investment for 

affordable housing.

Department of Agriculture Section 525 Technical and 

Supervisory Assistance Grants

None No grants were made in fiscal 

year 2010.

Rural Community Development 

Initiative Grants

$6,512,000 

Internal Revenue Service Historic preservation tax credit 

(20 percent)

see note Historic preservation tax credit is 

administered by both the 

National Park Service and the 

IRS. The Department of the 

Treasury estimated revenue 

losses of $390 million for fiscal 

year 2010 in Analytical 

Perspectives, Budget of the U.S. 

Government, Fiscal Year 2012

which includes both residential 

and non-residential historic 

structures. 

Purpose: Assistance for financing rental housing

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Federal Home Loan Banks Affordable Housing Program $216,000,000 Created by the Financial 

Institutions Reform, Recovery, 

and Enforcement Act of 1989.

The act requires each of the 

twelve Federal Home Loan 

Banks to contribute 10 percent of 

its previous year’s net earnings 

to an Affordable Housing 

Program to be used to subsidize 

the cost of affordable 

homeownership and rental 

housing.

Department of Housing and Urban 

Development

Supportive Housing for the 

Elderly (Section 202)

$580,250,000 

Assisted-Living Conversion 

Program 

Included in obligations 

under Supportive Housing 

for the Elderly (Section 202)

Mortgage Insurance for 

Manufactured Home Parks 

(Section 207) 

None No loans made in fiscal year 

2010. 
 

Page 358 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Existing Multifamily Rental 

Housing (Section 207/223(f)) 

-$261,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments under this 

program made in fiscal year 

2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured, which in some cases 

may be 30 years. This loan 

program is part of the General 

Insurance and Special Risk 

Insurance Fund, which houses a 

wide range of mortgage 

insurance products, including 

insurance for loans to develop, 

rehabilitate, and refinance 

multifamily rental housing, 

nursing home facilities, and 

hospitals. General Insurance and 

Special Risk Insurance Fund 

programs also include loan 

guarantees for Title I 

manufactured housing and for 

property improvement loans.

This estimate also includes 

expected credit subsidy costs for 

refinances of current FHA loans 

under Section 223(a)(7) made in 

fiscal year 2010.

Mortgage and Major Home 

Improvement Loan Insurance for 

Urban Renewal Areas (Section 

220)

-$18,000,000 Also includes loans under 

Section 231, and some made 

under Section 207. Also see 

note for Existing Multifamily 

Rental Housing (Section 

207/223(f)).

Multifamily Cooperatives 

(Section 221(d)(3)) 

$9,000,000 See note for Existing Multifamily 

Rental Housing (Section 

207/223(f)). 

Multifamily Rental Housing 

(Section 221(d)(4))

-$45,000,000 See note for Existing Multifamily 

Rental Housing (Section 

207/223(f)). 

Mortgage Insurance for Housing 

for the Elderly (Section 231) 

Included in obligations for 

Mortgage and Major Home 

Improvement Loan

Insurance for Urban 

Renewal Areas (Section 

220)

 

Mortgage Insurance for Single 

Room Occupancy Projects 

(Section 221(d)) pursuant to 

Section 223(g)

None No loans made in fiscal year 

2010. 

Supplemental Loans for 

Multifamily Projects (Section 

241)

see note Expected credit subsidy costs 

are less than $500,000. Also see 

note for Existing Multifamily 

Rental Housing (Section 

207/223(f)).
 

Page 359 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Supportive Housing for Persons 

with Disabilities (Section 811)

$130,359,000 

Housing Finance Authority Risk 

Sharing (Section 542(c)) 

-$2,000,000 See note for Existing Multifamily 

Rental Housing (Section 

207/223(f)). 

Government Sponsored 

Enterprise Risk Sharing (Section 

542(b))

see note Expected credit subsidy costs 

are less than $500,000. See 

note for Existing Multifamily 

Rental Housing (Section 

207/223(f)). 

Mark-to-Market Program Included in obligations 

under the General 

Insurance and Special Risk 

Insurance Fund 

Costs/savings associated with 

this are among the items 

factored into subsidy rates. See 

note for Existing Multifamily 

Rental Housing (Section 

207/223(f)).

Interest Reduction Payments for 

Rental and Cooperative Housing 

for Lower Income Families

None Payments are made from 

obligations recorded in prior 

years. No new commitments 

since 1973. 

Multifamily Operating Loss 

Loans (Section 223(d))

see note Expected credit subsidy costs 

are less than $500,000. Also see 

note for Existing Multifamily 

Rental Housing (Section 

207/223(f)).

Multifamily Property Disposition Included in obligations 

under the General 

Insurance and Special Risk 

Insurance Fund

Costs/savings associated with 

property disposition are among 

the items factored into subsidy 

rates. See note for Existing 

Multifamily Rental Housing 

(Section 207/223(f)).

Revitalization of Severely 

Distressed Public Housing 

(HOPE VI)

$120,456,000 

Department of Agriculture Section 515 Multifamily Direct 

Rural Rental Housing Loans 

$39,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.

Section 538 Rural Rental 

Housing Guaranteed Loans

$1,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.
 

Page 360 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Section 514 and 516 Farm Labor 

Housing Loan and Grant 

Program

$16,000,000 Grants under this program 

obligated $10 million and the 

expected credit subsidy costs for 

loans originated in fiscal year 

2010 was $6 million. These 

estimates of credit subsidy costs 

are revised in subsequent years 

and the ultimate cost will not be 

known until the loans have 

matured.

Multifamily Rental Housing 

Preservation and Revitalization 

$1,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates of 

credit subsidy costs are revised 

in subsequent years and the 

ultimate cost will not be known 

until the loans have matured.

Agency/entity Activity/program

FY 2010 estimated 

revenue lossesa Explanatory notes

Internal Revenue Service Low-income housing tax credit $5,650,000,000 

Rental housing bonds interest 

exclusion

$1,050,000,000 

Purpose: Emergency assistance to housing market or current homeowner

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Department of Housing and Urban 

Development

Tax Credit Assistance Program None During fiscal year 2009, the 

American Recovery and 

Reinvestment Act of 2009, 

provided $2.25 billion to the 

HOME program to make 

available to state housing credit 

agencies for low-income housing 

tax credit projects via a formulabased allocation. All of the 

appropriated funds were 

obligated in fiscal year 2009.

HOPE for Homeowners $3,000,000 Obligations represent the 

expected credit subsidy costs for 

loan commitments made in fiscal 

year 2010. These estimates are 

revised in subsequent years and 

the ultimate cost will not be 

known until the loans have 

matured.
 

Page 361 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Neighborhood Stabilization 

Program 

$1,980,000,000 The Neighborhood Stabilization 

Program was established by the 

Housing and Economic 

Recovery Act of 2008 and 

funded by that legislation at a 

level of $3.92 billion, obligated 

during fiscal year 2009. The 

American Recovery and 

Reinvestment Act of 2009 

provided $1.98 billion in 

additional funding, obligated in 

2010. The Dodd-Frank Wall 

Street Reform and Consumer 

Protection Act provided another 

$1 billion available in fiscal year 

2011.

Department of the Treasury New Issue Bond Program: 

Purchase securities of Fannie 

Mae and Freddie Mac backed by 

new housing bonds issued by 

the Housing Finance Agencies 

(HFA Initiative)

-$79,000,000 Represents the expected credit 

subsidy costs for securities 

purchased in fiscal year 2010, 

worth $15.3 billion. Ultimate cost 

will not be known until the 

securities mature or are sold. 

The Department of the 

Treasury’s authority to purchase 

securities under the program 

expired on December 31, 2009. 

Temporary Credit and Liquidity 

Program: Purchased 

participation interests in 

government-sponsored 

enterprises liquidity facilities 

available for outstanding housing 

bonds issued by state and local 

HFAs (HFA Initiative)

-$552,000,000 Represents the expected credit 

subsidy costs for purchases in 

fiscal year 2010, worth $8.2 

billion. Ultimate cost will not be 

known until the Department of 

the Treasury’s interests are 

dissolved. The Department of 

the Treasury’s authority to enter 

additional obligations under the 

program expired on December 

31, 2009. 

Housing Finance Authority (HFA) 

Hardest Hit Fund

$7,600,000,000 In fiscal year 2010, the 

Department of the Treasury 

obligated $7.6 billion for the HFA 

Hardest Hit Fund to be available 

until December 31, 2017. Actual 

payments made in fiscal year 

2010 to the 19 HFAs 

participating in the program was 

$56 million.
 

Page 362 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Grants to States for Low-Income 

Housing Projects in Lieu of LowIncome Housing Credits 

Program (Section 1602 

Program) 

$3,083,000,000 Designed to be used in lieu of 

tax credits, the Section 1602 

Program allowed state HFAs to 

exchange a portion of their 2009 

credit ceiling (up to 100 percent 

of 2008 unused LIHTC and 

credit returned during 2009 and 

40 percent of their 2009 

allocation) for grant funds from 

Treasury at the rate of 85 cents 

for every tax credit dollar, and 

then award proceeds to finance 

the construction or acquisition 

and rehabilitation of qualified 

low-income buildings. 

Making Home Affordable (MHA) see note In February 2009, the 

Department of the Treasury 

announced a program to assist 

homeowners in danger of 

foreclosure—the centerpiece of 

which was the Home Affordable 

Modification Program (HAMP)—

that would use up to $50 billion 

in funds from the Troubled Asset 

Relief Program (TARP). The 

Department of the Treasury 

subsequently reduced its total 

obligations of its TARP-funded 

housing programs to $45.6 

billion, of which $29.9 billion has 

been allocated to the Making 

Home Affordable program which 

includes HAMP. Treasury 

officials estimated that the last 

MHA incentive payment would 

likely occur sometime in mid2018. Actual payments made in 

fiscal year 2010 for all programs 

under the MHA program were 

$484 million.

Preferred Stock Purchase 

Agreements with Fannie Mae 

and Freddie Mac

see note Purchase of governmentsponsored enterprises’ stock in 

fiscal year 2010 was worth $52.6 

billion. Ultimate value the 

Department of the Treasury will 

receive for preferred stock is to 

be determined.

Purchase of mortgage-backed 

securities issued by Fannie Mae 

and Freddie Mac

-$1,114,000,000 Represents the expected credit 

subsidy costs for purchases in 

fiscal year 2010, worth $29.9 

billion. Ultimate cost will not be 

known until the securities mature 

or are sold. The Department of 

the Treasury’s authority to enter 

additional obligations under the 

program expired on December 

31, 2009.
 

Page 363 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Department of the Treasury and 

Department of Housing and Urban 

Development

Federal Housing Administration 

Short Refinance program 

$8,120,000,000 The Department of the Treasury 

entered into a letter of credit 

facility to fund up to $8 billion of 

losses, if any, associated with 

providing Federal Housing 

Administration Short Refinance 

loans originated on or before 

December 31, 2012. Actual 

payments made in fiscal year 

2010 were $3 million. No loans 

had been refinanced under this 

program in fiscal year 2010; 

payments were used to maintain 

the letter of credit.

Federal Reserve System Purchase of mortgage-backed 

securities issued by Fannie Mae, 

Freddie Mac and Ginnie Mae

see note Purchases of mortgage-backed 

securities issued by Fannie Mae, 

Freddie Mac and Ginnie Mae in 

fiscal year 2010 were valued at 

$346.1 billion. Ultimate cost will 

not be known until the securities 

mature or are sold.

Purchase of Fannie Mae, 

Freddie Mac and Federal Home 

Loan Bank debt

see note Purchases of Fannie Mae, 

Freddie Mac and Federal Home 

Loan Bank debt in fiscal year 

2010 were valued at $40.8 

billion. Ultimate cost is not yet 

known.

Agency/entity Activity/program

FY 2010 estimated 

revenue lossesa Explanatory notes

Internal Revenue Service Exclusion of forgiven mortgage 

debts

$1,480,000,000 

First-Time Homebuyer Tax 

Credit 

$13,680,000,000 Revenue losses were estimated 

by the Department of the 

Treasury for fiscal year 2010. 

This provision expired April 30, 

2010. 

Increased standard deduction for 

property taxes

$500,000,000 Revenue losses for fiscal year 

2010 were estimated by the Joint 

Committee on Taxation in 

Estimates of Federal Tax 

Expenditures for Fiscal Years 

2010-2014, JCS-3-10. This 

provision expired on December 

31, 2009. 
 

Page 364 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Purpose: Regulatory requirements

Consumer Financial Protection 

Bureau and Federal Financial 

Regulators

(Federal Reserve Board, Federal 

Deposit Insurance Corporation, 

National Credit Union 

Administration, and Office of the 

Comptroller of the Currency) and 

the Federal Financial Institutions 

Examination Council

Real Estate Settlement 

Procedures Act of 1974 

(RESPA) 

see note Responsibility for Rulemaking 

under RESPA moved to the 

Consumer Financial Protection 

Bureau on July 21, 2011.

The Consumer Financial 

Protection Bureau and the 

federal financial regulators are 

responsible for examination and 

enforcement of RESPA at 

certain institutions.

The Federal Financial 

Institutions Examination Council 

promotes uniformity in the 

supervision of financial 

institutions.

Costs for RESPA are not 

quantified or tracked separately.

Secure and Fair Enforcement for 

Mortgage Licensing Act of 2008 

(SAFE Act)

see note Responsibility for Rulemaking 

under the SAFE Act moved to 

the Consumer Financial 

Protection Bureau on July 21, 

2011.

The Consumer Financial 

Protection Bureau and the 

federal financial regulators are 

responsible for examination and 

enforcement of the SAFE Act at 

certain institutions.

The Federal Financial 

Institutions Examination Council 

promotes uniformity in the 

supervision of financial 

institutions.

Costs for the SAFE Act are not 

quantified or tracked separately.
 

Page 365 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Home Mortgage Disclosure Act 

of 1975 (HMDA)

see note Responsibility for Rulemaking 

under HMDA moved to the 

Consumer Financial Protection 

Bureau on July 21, 2011.

The Consumer Financial 

Protection Bureau and the 

federal financial regulators are 

responsible for examination and 

enforcement of HMDA at certain 

institutions.

The Federal Financial 

Institutions Examination Council 

promotes uniformity in the 

supervision of financial 

institutions and facilitates public 

access and aggregation of data 

that depository institutions must 

disclose under HMDA. 

Obligations in calendar year 

2010 were $13 million; of this 

amount, approximately $3 million 

was related to costs associated 

with the processing, aggregation, 

and reporting of HMDA data.

Source of funds for The Federal 

Financial Institutions 

Examination Council are 

collections from other federal 

sources. 

Truth in Lending Act see note Responsibility for Rulemaking 

under the Truth in Lending Act 

moved to the Consumer 

Financial Protection Bureau on 

July 21, 2011. However, 

rulemaking for certain aspects of 

the Truth in Lending Act remain 

with the federal financial 

regulators for real estate 

appraisals. 

The Consumer Financial 

Protection Bureau and the 

federal financial regulators are 

responsible for examination and 

enforcement of the Truth in 

Lending Act at certain 

institutions.

The Federal Financial 

Institutions Examination Council 

promotes uniformity in the 

supervision of financial 

institutions.

Costs for the housing related 

aspects of the Truth in Lending 

Act are not quantified or tracked 

separately. 
 

Page 366 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Equal Credit Opportunity Act see note Responsibility for Rulemaking 

under the Equal Credit 

Opportunity Act moved to the 

Consumer Financial Protection 

Bureau on July 21, 2011.

The Consumer Financial 

Protection Bureau and the 

federal financial regulators are 

responsible for examination and 

enforcement of the Equal Credit 

Opportunity Act at certain 

institutions.

The Federal Financial 

Institutions Examination Council 

promotes uniformity in the 

supervision of financial 

institutions.

Costs for the housing related 

aspects of the Equal Credit 

Opportunity Act are not 

quantified or tracked separately.

Federal Financial Regulators

(Federal Reserve Board, Federal 

Deposit Insurance Corporation, 

and Office of the Comptroller of 

the Currency)

and the Federal Financial 

Institutions Examination Council

Community Reinvestment Act 

(CRA)

see note Federal financial regulators are 

responsible for Rulemaking and 

enforcement of CRA. However, 

they do not quantify or track 

costs separately for the housing 

related aspects of the CRA.

The Federal Financial 

Institutions Examination Council 

promotes uniformity in the 

supervision of financial 

institutions.

Federal Financial Institutions 

Examination Council

Appraisal Subcommittee see note The Appraisal Subcommittee 

ensures that real estate 

appraisals used in federallyrelated transactions are 

performed in accordance with 

uniform standards by appraisers 

certified and licensed by the 

States.

Obligations for the 

Subcommittee in fiscal year 

2010 were $4 million; some 

amount of obligations may be 

attributable to activities related to 

housing. 

Source of funds for 

Subcommittee operations are

fee income from State-licensed 

and certified real estate 

appraisers in the national 

registry.

Department of Housing and Urban 

Development

Enforcement of the Fair Housing 

Act (Title VIII)

Included in obligations for 

Fair Housing Assistance 

Program and Fair Housing 

Initiatives Program

 

Fair Housing Assistance 

Program

$25,000,000 See also Enforcement of the Fair 

Housing Act (Title VIII)
 

Page 367 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Fair Housing Initiatives Program $25,000,000 See also Enforcement of the Fair 

Housing Act (Title VIII)

Purpose: Increase availability of mortgage loans

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Fannie Mae Purchase mortgage loans and 

issue mortgage-backed 

securities

see note Fannie Mae is not included in the 

federal budget. 

Also see activities listed under 

emergency assistance to 

housing market or current 

homeowner.

Freddie Mac Purchase mortgage loans and 

issue mortgage-backed 

securities

see note Freddie Mac is not included in 

the federal budget. 

Also see activities listed under 

emergency assistance to 

housing market or current 

homeowner.

Federal Home Loan Banks Provide advances to member 

institutions

see note The Federal Home Loan Banks 

are not included in the federal 

budget. 

Also see activities listed under 

emergency assistance to 

housing market or current 

homeowner.

Farm Credit System Institutions of the Farm Credit 

System, which include the 

Agricultural Credit Bank and 

Farm Credit Banks, provide 

financed credit to agricultural 

and rural communities.

None Entities of the Farm Credit 

System are not included in the 

federal budget. 

Farm Credit System Insurance 

Corporation

Ensure the timely payment of 

principal and interest on insured 

Farm Credit System debt 

obligations purchased by 

investors. 

see note Obligations for the Farm Credit 

System Insurance Corporation in 

fiscal year 2010 were $209 

million; some amount of 

obligations may be attributable to 

activities related to lending for 

rural housing. 

The Corporation derives its 

revenues from insurance 

premiums collected from insured 

Farm Credit System banks and 

from the investment income 

earned on its investment 

portfolio. 

Federal Agricultural Mortgage 

Corporation (Farmer Mac)

Purchases agricultural or rural 

housing mortgage loans and 

securitizes loans into guaranteed 

securities or agricultural 

mortgage-backed securities

None Farmer Mac is not included in 

the federal budget. 

Department of Housing and Urban 

Development

Government National Mortgage 

Association (Ginnie Mae): 

Guarantee the timely payment of 

principal and interest on 

securities issued by private 

lenders and backed by pools of 

federally insured or guaranteed 

mortgage loans

-$991,000,000 Represents expected credit 

subsidy costs for Ginnie Mae’s 

guarantees of mortgage-backed 

securities in fiscal year 2010. 

These estimates are revised in 

subsequent years and the 

ultimate cost is not yet known.
 

Page 368 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Agency/entity Activity/program

FY 2010 estimated 

revenue lossesa Explanatory notes

Internal Revenue Service Mortgage subsidy bonds interest 

exclusion

$1,230,000,000 

Veterans housing bonds interest 

exclusion

$20,000,000 

Purpose: Assistance for homeowners

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Department of Agriculture Section 504 Very Low-income 

Repair Loans and Grants 

$35,000,000 Grants under this program 

obligated $32 million and the 

expected credit subsidy costs for 

loans originated in fiscal year 

2010 was $3 million. These 

estimates are revised in 

subsequent years and the 

ultimate cost will not be known 

until the loans have matured.

Section 504 Direct Housing 

Loans and Grants for Natural 

Disasters 

$3,000,000 This number represents only the 

grant portion of the program. The 

loan portion is included in the 

Section 504.

Department of Veterans Affairs Specially Adapted Housing for 

Disabled Veterans 

$68,000,000 Includes obligations for the 

Special Housing Adaptation for 

Disabled Veterans and 

Temporary Residence 

Adaptation programs.

Direct Loans for Certain 

Disabled Veterans

None No loans were made in fiscal 

year 2010.

Special Housing Adaptation for

Disabled Veterans 

Included in obligations for 

Specially Adapted Housing 

for Disabled Veterans

 

Temporary Residence 

Adaptation 

Included in obligations for 

Specially Adapted Housing 

for Disabled Veterans

 

Department of the Interior Housing Improvement Program $15,943,367 

Agency/entity Activity/program

FY 2010 estimated 

revenue lossesa Explanatory notes

Internal Revenue Service Mortgage interest deduction $79,150,000,000 

Property tax deduction $15,120,000,000 

Purpose: Assistance for rental property owners

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Department of Housing and Urban 

Development

Project-Based Rental Assistance 

(Section 8 Contracts)

$8,764,224,000 

Rental Housing Assistance 

Payments (Section 236)

$10,232,000 Obligations are for amendments 

to existing contracts. No new 

commitments since 1973.

Rent Supplement Program $4,401,000 Obligations are for amendments 

to existing contracts. No new 

commitments since 1973.

Project-Based Voucher Program Included in obligations for 

Housing Choice Voucher 

Program

 
 

Page 369 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Section 8 Moderate 

Rehabilitation Program

Included in obligations for 

Project-Based Rental 

Assistance 

 

Department of Agriculture Section 521 Rural Rental 

Assistance Payments

$979,000,000 

Agency/entity Activity/program

FY 2010 estimated 

revenue lossesa Explanatory notes

Internal Revenue Service Passive rental losses $8,790,000,000 

Accelerated depreciation on 

rental housing 

-$1,490,000,000 Tax expenditure revenue loss 

estimates are generally reported 

in the President’s budget on a 

cash basis. When incoming tax 

receipts from past deferrals are 

greater than deferred receipts 

from new activity, the cash-basis 

tax expenditure estimate can be 

negative. For certain tax 

expenditures that take the form 

of deferrals of tax liability, the 

President’s budget also presents 

estimates made on a present 

value basis. The President’s 

budget for fiscal year 2012 

reported that the estimated 

present value of revenue losses 

for activities undertaken in 

calendar year 2010 for this tax 

expenditure would be $6.570 

billion.

Purpose: Rental assistance for tenants

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Department of Housing and Urban 

Development

Housing Choice Voucher 

Program 

$15,160,991,261 

Mainstream Vouchers $85,236,000 

Family Unification Program $15,877,000 

Section 8 Moving to Work 

Demonstration

$2,823,379,109 

Department of Labor National Farmworker Jobs 

Program - Housing Assistance

$5,700,000 Obligations represent allocations 

for housing activities in program 

year 2010.

Department of Agriculture Section 542 Rural Housing 

Voucher Program 

$8,000,000 

Purpose: Operation/management of rental housing

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Department of Housing and Urban 

Development

Multifamily Energy Pilot None Program created in fiscal year 

2010, however no funds were 

obligated in that year. 

Emergency Capital Repairs 

Program 

Included in obligations 

under Supportive Housing 

for the Elderly (Section 202)

 

Public Housing Operating Fund $4,754,393,000 

Public Housing Capital Fund $2,485,538,000 
 

Page 370 GAO-12-342SP Lists of Programs Identified

Housing Assistance

Agency/entity Activity/program

Related budgetary 

information Explanatory notes

Green Retrofit Program for 

Multifamily Housing

$235,000,000 Grants under this program 

obligated $167 million and the 

expected credit subsidy costs for 

loans originated in fiscal year 

2010 were $68 million. These 

estimates are revised in 

subsequent years and the 

ultimate cost will not be known 

until the loans have matured.

Department of Agriculture Section 533 Rural Housing 

Preservation Grants 

$11,000,000 

Purpose: Regulator of government-sponsored enterprises

Agency/entity Activity/program FY 2010 obligations Explanatory notes

Federal Housing Finance Agency Regulator and conservator of 

Fannie Mae and Freddie Mac 

and the regulator of the Federal 

Home Loan Banks (FHLBanks)

$133,000,000 The Federal Housing Finance 

Agency receives direct funding 

for its activities from mandatory 

assessments on Fannie Mae, 

Freddie Mac, and the Federal 

Home Loan Banks. 

Farm Credit Administration Regulator and examiner of the 

banks, associations, and related 

entities of the Farm Credit 

System, including the Federal 

Agricultural Mortgage 

Corporation (Farmer Mac)

see note Fiscal year 2010 obligations 

were $50 million; some amount 

of obligations may be attributable 

to activities related to housing. 

Source of funds for Farm Credit 

Administration are assessments 

collected from institutions in the 

System, including Farmer Mac.

Source: GAO. 

Note: Activities/programs may have multiple purposes. Listing does not include housing counseling 

programs nor energy efficiency tax expenditures that are covered in another section of this report and 

homeless housing programs that GAO discussed in its March 2011 reports: Opportunities to Reduce 

Potential Duplication in Government Programs, Save Tax Dollars, and Enhance Revenue, 

GAO-11-318SP (Washington, D.C.: Mar. 1, 2011) and List of Selected Federal Programs That Have 

Similar or Overlapping Objectives, Provide Similar Services, or Are Fragmented Across Government 

Missions, GAO-11-474R (Washington, D.C.: Mar. 18, 2011). Listing also does not include tax 

expenditures for employment-related housing allowances or costs.

a

Revenue losses are estimated by the Department of the Treasury in Analytical Perspectives, Budget 

of the U.S. Government, Fiscal Year 2012, unless otherwise specified. 
 

Page 371 GAO-12-342SP Lists of Programs Identified

Table 11: Early Learning and Child Care: List of Programs and Related Budgetary Informationa 

Early Learning and Child Care

Agency or subagency Program

FY 2010 

obligationsb

Programs with an Explicit Early Learning or Child Care Purpose

Department of Education

Office of the Deputy Secretary Race to the Top - Early Learning Challenge c

State Fiscal Stabilization Fund - Education State Grants, 

Recovery Act 

d

Office of Elementary and Secondary Education Indian Education - Grants to Local Educational Agencies $104,000,000 

Striving Readers Comprehensive Literacye 35,000,000 

Office of Postsecondary Education Child Care Access Means Parents in School 16,000,000 

Office of Special Education and Rehabilitative Services Special Education - Grants for Infants and Families 439,000,000 

Special Education - Preschool Grants 374,000,000 

Department of Health and Human Services 

Administration for Children and Families Child Care and Development Block Grant 2,127,000,000 

Child Care Mandatory and Matching Funds of the Child 

Care and Development Fund

2,917,000,219 

Head Start 7,235,514,000 

Department of the Interior

Bureau of Indian Education Indian Child and Family Education (FACE) 15,370,870 

General Services Administration

Public Buildings Service The General Services Administration’s Child Care 

Program

3,144,000 

Programs That Support Early Learning and Child Care or Allow Use of Funds for That Purposea

Appalachian Regional Commission

Appalachian Area Development 73,000,000 

Department of Agriculture

Food and Nutrition Service Child and Adult Care Food Program 2,640,923,000 

National School Lunch Program 9,967,068,000 

School Breakfast Program 29,200,391,000 

Special Milk Program for Children 12,673,000 

Department of Education

Office of Innovation and Improvement Full-Service Community Schools 1,166,000,000 

Promise Neighborhoods 10,000,000 

Office of Elementary and Secondary Education Alaska Native Educational Programs 33,000,000 

Education for Homeless Children and Youth 65,000,000 

English Language Acquisition Grants 743,000,000 

Indian Education - Special Programs for Indian Children 19,060,000 

Migrant Education - State Grant Program 394,771,000 

Native Hawaiian Education 34,000,000 

Title I Grants to Local Educational Agencies f

Office of Special Education and Rehabilitative Services Special Education - State Personnel Development 48,000,000 

Special Education - Grants to States g
 

Page 372 GAO-12-342SP Lists of Programs Identified

Early Learning and Child Care

Agency or subagency Program

FY 2010 

obligationsb

Special Education - Technology and Media Services for 

Individuals with Disabilities

44,000,000 

Department of Health and Human Services

Administration for Children and Families Community Services Block Grant 699,999,000 

Social Services Block Grant h

Temporary Assistance for Needy Families i

Office of Community Planning and Development Community Development Block Grants/Entitlement 

Grants

j

Community Development Block Grants/Special Purpose 

Grants/Insular Areas

j

Community Development Block Grants/State’s program 

and Non-Entitlement Grants in Hawaii

j

Department of Justice 

Office of Juvenile Justice and Delinquency Prevention Reduction and Prevention of Children’s Exposure to 

Violence (Safe Start)

5,000,000 

Violence Against Women Office Children and Youth Exposed to Violence 614,000 

Transitional Housing Assistance for Victims of Domestic 

Violence, Dating Violence, Stalking, or Sexual Assault

15,305,000 

Department of Labor 

Employment Training Administration National Farmworker Jobs Program 87,398,000 

Native American Employment and Training 53,000,000 

Workforce Investment Act Adult Program 861,540,000 

Workforce Investment Act Dislocated Worker Formula 

Grants

1,183,847,000 

Department of the Interior

Bureau of Indian Affairs Indian Child Welfare Act-Title II Grants k

Indian Education - Assistance to Schools 21,214,545 

General Services Administration

Federal Acquisition Service Donation of Federal Surplus Personal Property 0 

Source: GAO analysis of FY 2010 obligations based on agencies’ federal budget justifications and other sources. 

a

This table classifies fiscal year 2010 obligations for early learning and child care into two groups: (a) 

obligations for programs with an explicit early learning or child care purpose and (b) obligations for 

programs that support early learning and child care or allow use of funds for that purpose. However, 

obligations cited for the latter (programs that support or allow use of funds) do not represent funds 

specifically for early learning and child care services but rather for those programs overall. 

b

In addition to FY 2010 obligations, some programs received Recovery Act funds in fiscal year 2010. 

These programs include, for example, Temporary Assistance for Needy Families, Child Care and 

Development Block Grant, Special Education – Grants for Infants and Families, and Special 

Education – Preschool Grants programs. Additionally, Head Start Recovery Act appropriations were 

made available in 2009 for two fiscal years.

c Race to the Top - Early Learning Challenge was created as part of the American Recovery and 

Reinvestment Act of 2009 and may not continue to be funded after the Act’s funds expire. It received 

a $500 million appropriation in fiscal year 2011 and had no previous appropriation. It is jointly 

administered by the Departments of Education and Health and Human Services. 

d State Fiscal Stabilization Fund - Education State Grants, Recovery Act was created as part of the 

American Recovery and Reinvestment Act of 2009 and may not continue to be funded after the act’s 

funds expire. It received an $18,170,000 obligation through Recovery Act funds in fiscal year 2010. 

e In its budget justification, the Department of Education stated that it was not requesting separate 

funding for the Striving Readers program for fiscal year 2012. In place of this and several other 

programs that seek to promote improvement of reading, writing, and language arts instruction, the 

department proposed creating a new program: Effective Teaching and Learning: Literacy. 
 

Page 373 GAO-12-342SP Lists of Programs Identified

f

Title I had fiscal year 2010 obligations of approximately $14.5 billion. About 2 percent of total 

obligations were spent on early education programs in fiscal year 2009, the latest date for which 

expenditure data are available. 

g

Although Special Education Grants to States had fiscal year 2010 obligations of approximately $11.5 

billion to provide children with free appropriate public education, not all of this funding served children 

under 5. 

h

The Social Services Block Grant is a large, multipurpose block grant with fiscal year 2009 obligations 

of about $391 million spent on child care, or 14 percent of total funds. 

i

Temporary Assistance for Needy Families is a large, multipurpose block grant with fiscal year 2010 

obligations of approximately $17 billion. It accounted for $3.5 billion in child care funding in fiscal year 

2009. Funds that are eventually transferred to the Child Care and Development Fund at state option 

are included in Temporary Assistance for Needy Families totals. 

j

Less than 1 percent of Community Development Block Grants funds were used for child care 

services or child care facilities.

k

Agency officials told us that, although child care is an allowable use, no funds were used for this 

purpose in fiscal year 2010. 
 

Page 374 GAO-12-342SP Lists of Programs Identified

Table 12: Early Learning and Child Care: List of Tax Expenditures and Estimated 

Revenue Loss 

Tax expenditure

Total estimated 

revenue loss FY 2010 

Exclusion of Benefits Provided Under Cafeteria Plans

26 U.S.C. § 125(a)

a

Exclusion of Income Earned By Voluntary Employees’ 

Beneficiary Associations

26 U.S.C. § 419

b 

Credit For Child and Dependent Care Expenses

26 U.S.C. § 21 $3,100,000,000 Exclusion of Employer-Provided Child and Dependent Care

26 U.S.C. § 129

Credit For Employer-Provided Child Care

26 U.S.C. § 45F

Less than 50,000,000

Source: Congressional Research Service, Tax Expenditures: Compendium of Background Material on Individual Provisions 

(Washington, D.C.: December 2010).

a

The total estimated revenue loss for “cafeteria plans” was $26.4 billion in fiscal year 2010.This figure 

does not exclusively represent revenue lost for child care but also includes accident and health 

insurance, and other benefits. 

b

The total estimated revenue loss for the Exclusion of Income Earned By Voluntary Employees’ 

Beneficiary Associations tax expenditure was $3.2 billion in fiscal year 2010. This figure does not 

exclusively represent child care expenditures but also includes a range of benefits including life 

insurance, disability, and health insurance. 
 

Page 375 GAO-12-342SP Lists of Programs Identified

Table 13: Employment for People with Disabilities: List of Programs and Related Budgetary Information 

Employment for People with Disabilities

Agency Program FY 2010 obligations 

Portion of FY 2010 obligations 

for employment-related 

services and support for 

people with disabilitiesa

U.S. AbilityOne Commission AbilityOne Program $5,380,775 $0

Department of Agriculture Assistive Technology Program for 

Farmers with Disabilities: AgrAbility 

Project 

4,667,107 4,667,107 

Department of Defense Air Force Warrior and Survivor 

Care

Program could not provideb 0 

Army Warrior Care and Transition 

Programc 1,353,680,000d Program could not provide

Computer/Electronic 

Accommodations Program

8,847,404 8,847,404 

Marine Corps Wounded Warrior 

Program

0 0 

National Resource Directoryc (joint 

with Department of Veterans 

Affairs)

No response No responsee

Navy Safe Harbor Program 2,400,000 24,000 

National Organization on Disability 

Wounded Warrior Careers 

Demonstration Programf

Program could not provide Program could not provide

Recovery Care Coordinator 

Program

3,825,960 0 

Recovery Coordination Program – 

Operation Warfighter

966,502 966,502

U.S. Special Operations Command 

Care Coalition

3,592,700 Program could not provide

Department of Education American Indian Vocational 

Rehabilitation Services

42,822,202 42,822,202 

Helen Keller National Center for 

Youths and Adults Who Are DeafBlind

9,181,000 9,181,000 

Migrant and Seasonal 

Farmworkersg

2,197,283 2,197,283 

Model Comprehensive Transition 

and Postsecondary Programs for 

Students with Intellectual 

Disabilitiesg

11,000,000 11,000,000

Projects with Industryh 17,842,595 17,842,595 

Randolph-Sheppard Vending 

Facilities Program

0 0 

Rehabilitation Services 

Demonstration and Training 

Programs 

11,601,000 5,800,000 

State Grant for Assistive 

Technology Program

25,660,000 0 

Supported Employment Services 

for Individuals with the Most 

Significant Disabilitiesg,i

28,889,190 28,889,190 
 

Page 376 GAO-12-342SP Lists of Programs Identified

Employment for People with Disabilities

Agency Program FY 2010 obligations 

Portion of FY 2010 obligations 

for employment-related 

services and support for 

people with disabilitiesa

Vocational Rehabilitation Services 

Programi 2,437,797,600 2,437,797,600 

Department of Health and 

Human Services

1915(c) Home and Community 

Based Services Waiver

No response Program could not provide

1915(i) State Plan Home and 

Community-Based Services

Program could not provide 0 

Medicaid Infrastructure Grant 

Programh 74,606,990 No response

Medicaid State Plan Services No response No response

Money Follows the Person 

Rebalancing Demonstration

105,596,872 0 

Department of Labor America's Heroes at Work 300,000 300,000 

Work Incentive Grants/Disability 

Program Navigator Initiativej

0 0 

Disabled Veterans' Outreach 

Program 

81,251,000 Program could not provide

Employer Assistance and 

Resource Network

1,600,000 1,600,000

Job Accommodation Network 2,366,318 2,366,318 

Job Corpsk 1,712,000,000 Program could not provide

Local Veterans’ Employment 

Representatives Program 

76,481,000 Program could not provide

REALifelines Program Program could not provide Program could not provide

Registered Apprenticeship for 

Youth and Young Adults with 

Disabilities Initiative

0 0 

Community Service Employment 

for Older Americans 

825,400,000 0 

Veterans' Workforce Investment 

Program

9,493,707 Program could not provide

Work Opportunity Tax Credit (joint 

with the Internal Revenue 

Service)

18,520,000l 0 

Workforce Investment Act Youth 

Activities

910,207,965 Program could not provide

Workforce Recruitment Program 

(joint with the Department of 

Defense)

211,377 211,377 

YouthBuildi 69,020,000 Program could not provide

Department of Veterans 

Affairs

Compensated Work Therapy 

Program

0 0 

Disabled Transition Assistance 

Program

Program could not provide Program could not provide

Vocational Rehabilitation and 

Employment

768,000,000 768,000,000 
 

Page 377 GAO-12-342SP Lists of Programs Identified

Employment for People with Disabilities

Agency Program FY 2010 obligations 

Portion of FY 2010 obligations 

for employment-related 

services and support for 

people with disabilitiesa

Vocational Training and 

Rehabilitation for Vietnam 

Veterans' Children with Spina 

Bifida or Other Covered Birth 

Defects

Program could not provide Program could not provide

Social Security 

Administration

Benefit Offset National 

Demonstration

13,510,873 13,510,873 

Mental Health Treatment Studyh 971,274 699,317 

Work Incentives Planning and 

Assistance Programh 27,328,266 27,328,266 

State Vocational Rehabilitation 

Cost Reimbursement Program

106,000,000 106,000,000 

Ticket to Work Program 22,100,000 m 22,100,000 

Youth Transition Demonstration 

Projecth 4,860,286 768,628 

Total $8,800,177,246 $3,512,919,662

Source: GAO survey of programs that support employment for people with disabilities.

a

Some programs were not able to identify obligations related to providing employment supports to 

people with disabilities. 

b

“Program could not provide” indicates that the program reported in GAO’s survey that they were not 

able to provide obligations data. 

c

In commenting on a draft of this report, the Department of Defense indicated that this program 

should be added to the scope. GAO will pursue additional information on this program for a final 

report.

d

A significant portion of these obligations ($578,500,000) was for constructing healing campuses for 

wounded, ill, and injured soldiers.

e

“No response” indicates that the program did not respond to this survey question or otherwise 

provide this information.

f

This program is a collaboration between the Army and the National Organization on Disability. The 

memorandum of understanding between the Army and the National Organization on Disability was 

terminated in July 2010. 

g

This program was proposed to be consolidated or eliminated in the Department of Education’s fiscal 

year 2012 budget request, but the department reported that funds were appropriated in fiscal year 

2012.

h

Indicates programs that have been eliminated or are planned to end by fiscal year 2012. Two of 

these are research studies that have concluded. For example, the Social Security Administration’s 

Mental Health Treatment Study has concluded and the results are available at 

http://socialsecurity.gov/disabilityresearch/mentalhealth.htm.

i

Program reported appropriated funds instead of obligations. 

j

The Work Incentives Grants/Disability Program Navigator was funded for 7 years as a pilot program 

and is being expanded and replicated as a new program, the Disability Employment Initiative. 

k

Total program obligations for Job Corps includes $102 million in American Recovery and 

Reinvestment Act obligations. 

l

Reported obligations for the Work Opportunity Tax Credit are for the Department of Labor’s 

administration of the program, according to agency officials. According to the Internal Revenue 

Service, in tax year 2009—the most recent data available—there were more than $600 million in 

Work Opportunity Tax Credits that were eligible to be claimed by individuals. In addition, for tax year 

2009, there were more than $1 billion in Work Opportunity Tax Credits that were eligible to be 

claimed by corporations (including S corporations). 

mObligations reported for the Ticket to Work program in fiscal year 2010 represent the cost of funding 

the Employment Networks and not the total cost of the program. Data on total obligations for fiscal 

year 2010 will be available later in fiscal year 2012. 
 

Page 378 GAO-12-342SP Lists of Programs Identified

Table 14: Science, Technology, Engineering, and Mathematics (STEM) Education: 

List of Programs and Related Budgetary Information

Science, Technology, Engineering, and Mathematics (STEM) Education

Agency and 

subagency Program 

FY 2010 

obligationsa

National Aeronautics and Space Administration

Aeronautics Research Directorate - STEM Education 

activities

$4,153,000

Exploration Systems Directorate - STEM Education 

activities

6,400,000

Higher Education 18,346,329

K-12 STEM Program 36,291,069

Minority University Research and Education Program 28,862,619

National Aeronautics and Space Administration 

Informal Education Opportunities 

14,295,934

National Aeronautics and Space Administration 

Science Mission Directorate Education and Public 

Outreach

30,057,100

Space Grant/EPSCoR Program 68,910,696

Space Operations Directorate - STEM Education 

activities

2,293,000

National Science Foundation

Advanced Technological Education 64,510,000

Alliances for Graduate Education and the Professoriate 16,730,000

Broadening Participation in Computing 14,000,000

Centers for Ocean Science Education Excellence $5,700,000

Computer Information Science & Engineering 

Directorate Pathways to Revitalized Undergraduate 

Computing Education 

4,370,000

Cyberinfrastructure Training, Education, Advancement, 

and Mentoring for Our 21st Century Workforce 

4,850,000

Discovery Research K-12 118,380,000

East Asia & Pacific Summer Institutes for U.S. 

Graduate Students 

1,740,000

Engineering Education 13,740,000

Enhancing the Mathematical Sciences Workforce in the 

21st Century 

15,070,000

Ethics Education in Science & Engineering 2,650,000

Federal Cyber Service: Scholarship for Service 14,870,000

Geoscience Education 2,020,000

Geoscience Teacher Training 2,980,000

Global Learning and Observations to Benefit the 

Environment 

1,100,000

Graduate Research Fellowship Program 136,130,000

Graduate STEM Fellows in K-12 Education Program 55,970,000

Historically Black Colleges and Universities 

Undergraduate Program 

32,060,000

Informal Science Education 65,850,000
 

Page 379 GAO-12-342SP Lists of Programs Identified

Science, Technology, Engineering, and Mathematics (STEM) Education

Agency and 

subagency Program 

FY 2010 

obligationsa

Integrative Graduate Education and Research 

Traineeship Program

69,700,000

Interdisciplinary Training for Undergraduates in 

Biological and Mathematical Sciences 

2,700,000

International Research Experiences for Students 3,430,000

Louis Stokes Alliances for Minority Participation 44,550,000

Math and Science Partnership 57,930,000

Nanotechnology Undergraduate Education in 

Engineering

1,830,000

Opportunities for Enhancing Diversity in the 

Geosciences

4,180,000

Polar Education Program 1,500,000

Research and Evaluation on Education in Science and 

Engineering 

45,670,000

Research Experiences for Teachers in Engineering and 

Computer Science

5,410,000

Research Experiences for Undergraduates 80,990,000

Research in Disabilities Education 6,920,000

Research on Gender in Science and Engineering 11,570,000

Robert Noyce Teacher Scholarship Program 54,930,000

Science, Technology, Engineering, and Mathematics 

Talent Expansion Program 

31,640,000

Transforming Undergrad Education in STEM 41,600,000

Tribal Colleges and Universities Program 13,350,000

Undergraduate Research and Mentoring in the 

Biological Sciences

9,000,000

Nuclear Regulatory Commission

Integrated University Program 15,000,000

Minority Serving Institutions Program 2,838,500

Nuclear Education Curriculum Development Grants 4,700,997

U.S. Department of Agriculture

Animal and Plant Health Inspection Service 

AgDiscovery Program 15,000

National Institute of Food and Agriculture 

1890 Institution Teaching, Research and Extension 

Capacity Building Grants Program

17,167,994

Agriculture in the Classroom 314,912

Food and Agricultural Sciences National Needs 

Graduate and Postdoctoral Fellowships Grants 

Program

3,664,127

Higher Education Challenge Grants Program 5,654,000

Higher Education Multicultural Scholars Program 1,126,000

Hispanic Education Partnership Grants 8,809,568

New Era Rural Technology Competitive Grants 

Program

875,000

Resident Instruction Grants for Institutions of Higher 

Education in Insular Areas

859,547
 

Page 380 GAO-12-342SP Lists of Programs Identified

Science, Technology, Engineering, and Mathematics (STEM) Education

Agency and 

subagency Program 

FY 2010 

obligationsa

Secondary Education, Two-Year Postsecondary 

Education and Agriculture in the K-12 Classroom 

Grants

983,000

Office of the Assistant Secretary for Departmental Management

U.S. Department of Agriculture /1890 National Scholars 

Program

2,398,947

U.S. Department of Commerce

National Institute of Standards and Technology 

National Institute of Standards and Technology 

Summer Institute for Middle School Science Teachers

300,000

Recovery Act Measurement Science and Engineering 

Fellowship Program

20,000,000

Summer Undergraduate Research Fellowship Program 595,641

National Oceanic and Atmospheric Administration 

Bay Watershed Education and Training Program 9,700,000

Climate Communications and Education Program 536,000

Coral Reef Conservation Program 838,000

Dr. Nancy Foster Scholarship Program 603,125

Educational Partnership Program with Minority Serving 

Institutions

14,309,000

Environmental Literacy Grants 10,388,185

Ernest F. Hollings Undergraduate Scholarship Program 6,450,638

Global Learning and Observations to Benefit the 

Environment

3,000,000

National Environmental Satellite, Data, and Information 

Service Education

2,700,000

National Estuarine Research Reserve System 

Education Program

1,020,000

National Marine Fisheries Service Education 3,084,750

National Marine Sanctuaries Education Program 908,150

National Ocean Service Education 426,000

National Sea Grant College Program - Education 

Component

9,378,529

National Weather Service Outreach Program 3,070,000

Teacher at Sea Program 600,000

U.S. Department of Defense

Air Force

Awards to Stimulate and Support Undergraduate 

Research Experience 

4,500,000

National Defense Science and Engineering Graduate 

Fellowship

38,695,132

University NanoSatellite Program 660,000

Army 

Army Educational Outreach Program 7,885,000

Consortium Research Fellows Program 1,634,050

National Science Center 1,982,000
 

Page 381 GAO-12-342SP Lists of Programs Identified

Science, Technology, Engineering, and Mathematics (STEM) Education

Agency and 

subagency Program 

FY 2010 

obligationsa

Office of the Secretary of Defense

Autonomous Robotic Manipulation 8,180,000

Computer Science in Science, Technology, 

Engineering, and Mathematics Education 

2,661,000

Department of Defense STARBASE Program 20,000,000

ENGAGE 2,100,000

National Defense Education Program K-12 13,595,000

National Defense Education Program Science, 

Mathematics And Research for Transformation 

47,400,000

Military Health System

Uniformed Services University of the Health Sciences 447,000

Navy

Historically Black College and Universities/Minority 

Institutions Research Education Partnership

700,000

Iridescent Learning 810,000

Science and Engineering Apprentice Program 755,000

SeaPerch 700,000

The Naval Research Enterprise Intern Program 1,960,000

University / Laboratory Initiative 2,350,000

Department of Education

Developing Hispanic-Serving Institutions: STEM and 

Articulation Programs (mandatory)

0b

Graduate Assistance in Areas of National Need 31,005,248

Mathematics and Science Partnerships 180,478,000

Minority Science and Engineering Improvement 

Program

9,503,000

National Science and Mathematics Access to Retain 

Talent Program

379,775,972

Predominantly Black Institutions Competitive Grant 

Program

0b

Research in Special Education 11,000,000

Research, Development, and Dissemination 39,986,940

Teachers for a Competitive Tomorrow: Baccalaureate 

Degrees in STEM and Critical Foreign Languages

1,092,000

Teachers for a Competitive Tomorrow: Master’s 

Degrees in STEM and Critical Foreign Languages

1,092,000

Upward Bound Math-Science 34,873,057

Women’s Educational Equity 2,423,000

U.S. Department of Energy

Academies Creating Teacher Scientists 3,721,600

Advanced Vehicle Competitions 2,000,000

American Chemical Society Summer School in Nuclear 

and Radiochemistry

546,813

Advanced Scientific Computing Research - Oak Ridge 

National Laboratory Research Alliance in Math and 

Science

250,000
 

Page 382 GAO-12-342SP Lists of Programs Identified

Science, Technology, Engineering, and Mathematics (STEM) Education

Agency and 

subagency Program 

FY 2010 

obligationsa

Community College Institute of Science and 

Technology

685,000

Computational Science Graduate Fellowship 7,800,000

Faculty and Student Teams 1,019,000

Fusion Energy Sciences Graduate Fellowship Program 800,000

Graduate Automotive Technology Education 1,000,000

Hampton University Graduate Studies 48,000

Historically Black Colleges and Universities 

Mathematics, Science & Technology, Engineering and 

Research Workforce Development Program

8,967,507

Industrial Assessment Centers 6,086,000

Integrated University Program 5,000,000

Laboratory Equipment Donation Program 150,000

Mickey Leland Energy Fellowship 700,000

Minority Serving Institutions Program 840,000

Minority University Research Associates Program 591,880

National Science Bowl 2,449,900

National Undergraduate Fellowship Program in Plasma 

Physics and Fusion Energy Sciences

370,000

Office of Science Graduate Fellowship program 17,500,000

Pan American Advanced Studies Institute 200,000

Plasma/Fusion Science Educator Programs 779,000

Pre-Service Teacher Program 429,000

QuarkNet 750,000

Science Undergraduate Laboratory Internships 3,802,500

Solar Decathlon 5,000,000

Summer Applied Geophysical Experience 100,000

Technical Career Intern Program 0c

Wind for Schools 630,000

U.S. Department of Health and Human Services

Health Resources and Services Administration

Health Careers Opportunity Program 22,086,000

Public Health Traineeship Program 1,510,000

National Institutes of Health

Bridges to the Baccalaureate Program 6,460,988

Bridges to the Doctorate 2,977,075

Cancer Education Grants Program 6,756,869

Cancer Research Interns 191,608

Center for Cancer Research/Johns Hopkins University 

Master of Science in Biotechnology Concentration in 

Molecular Targets and Drug Discovery Technologies

445,000

Clinical Research Training Program 1,100,000

Community College Summer Enrichment Program 105,000

Curriculum Supplement Series 341,849
 

Page 383 GAO-12-342SP Lists of Programs Identified

Science, Technology, Engineering, and Mathematics (STEM) Education

Agency and 

subagency Program 

FY 2010 

obligationsa

Education Programs for Population Research (R25) 750,154

Graduate Program Partnerships 16,720,000

Initiative for Maximizing Student Development 21,412,146

Intramural National Institute of Allergy and Infectious 

Diseases Research Opportunities

129,111

Minority Access to Research Careers Undergraduate 

Student Training in Academic Research National 

Research Service Award Program 

20,386,651

Material Development for Environmental Health 

Curriculum

1,544,868

National Cancer Institute Cancer Education and Career 

Development Program

20,442,233

National Center for Research Resources Science 

Education Partnership Award 

16,653,015

National Heart, Lung, and Blood Institute Minority 

Undergraduate Biomedical Education Program

$475,970

National Institute of Allergy and Infectious Diseases 

Science Education Awards

1,069,978

National Institute of Diabetes and Digestive and Kidney 

Diseases Education Program Grants

432,000

National Institutes of Health Academy 249,866

National Institutes of Health Summer Research 

Experience Programs

1,679,422

National Institute of Neurological Disorders and Stroke 

Diversity Research Education Grants in Neuroscience

821,800

National Library of Medicine Institutional Grants for 

Research Training in Biomedical Informatics

10,143,676

Office of Science Education K-12 Program 2,270,151

Post-baccalaureate Intramural Research Training 

Award Program

24,810,000

Postbaccalaureate Research Education Program 5,780,503

Recovery Act Limited Competition: National Institutes of 

Health Challenge Grants in Health and Science 

Research 

4,953,293

Research Scientist Award for Minority Institutions 82,146

Research Supplements to Promote Diversity in HealthRelated Research68,981,252

Research Initiative for Scientific Enhancement 24,441,722

Ruth L. Kirschstein National Research Service Award 

Institutional Research Training Grants**(T32, T35)

230,840,328

Ruth L. Kirschstein NRSA for Individual Predoctoral 

Fellows, including Underrepresented Racial/Ethnic 

Groups, Students from Disadvantaged Backgrounds

56,882,642

Science Education Drug Abuse Partnership Award 2,294,996

Short Courses in Integrative and Organ Systems 

Pharmacology

665,937

Short Courses on Mathematical, Statistical, and 

Computational Tools for Studying Biological Systems

695,460
 

Page 384 GAO-12-342SP Lists of Programs Identified

Science, Technology, Engineering, and Mathematics (STEM) Education

Agency and 

subagency Program 

FY 2010 

obligationsa

Short Term Educational Experiences for Research in 

the Environmental health Sciences for Undergraduates 

and High School Students

568,298

Short-Term Research Education Program to Increase 

Diversity in Health-Related Research

4,188,763

Student Intramural Research Training Award Program 5,868,500

Summer Genetics Institute 53,935

Summer Institute for Training in Biostatistics 1,449,092

Technical Intramural Research Training Award 2,240,000

Training in Computational Neuroscience: From Biology 

to Model and Back Again

1,443,450

Training in Neuroimaging: Integrating First Principles 

and Applications

1,356,252

Undergraduate Scholarship Program for Individuals 

from Disadvantaged Backgrounds

2,426,137

U.S. Department of Homeland Security 

Science and Technology Directorate 

Homeland Security-related STEM Career Development 

Grants Program

2,300,000

Homeland Security-related STEM Scholars Program 1,920,000

Homeland Security-related STEM Summer Internship 

Program

363,000

Minority Serving Institutions - Scientific Leadership 

Awards

2,400,000

Minority Serving Institutions - Summer Research Team 116,000

U.S. Department of the Interior

U.S. Geological Survey 

EDMAP Component of the National Cooperative 

Geologic Mapping Program

566,161

National Association of Geoscience Teachers - U.S. 

Geological Survey Cooperative Summer Field Training 

Program

200,000

Student Intern in Support of Native American Relations 204,013

U.S. Department of Transportation 

Federal Aviation Administration 

Joint University Program 300,000

National Center of Excellence for Aviation Operations 

Research 

5,393,000

Federal Highway Administration 

Garrett A. Morgan Technology and Transportation 

Education Program 

1,250,000

National Summer Transportation Institute Program 2,602,999

Summer Transportation Internship Program for Diverse 

Groups

1,425,000

Research and Innovative Technology Administration 

University Transportation Centers Program 83,370,600
 

Page 385 GAO-12-342SP Lists of Programs Identified

Science, Technology, Engineering, and Mathematics (STEM) Education

Agency and 

subagency Program 

FY 2010 

obligationsa

U.S. Environmental Protection Agency

Cooperative Training in Environmental Sciences 

Research 

1,593,184

Environmental Education Grants 3,450,882

Environmental Protection Agency Greater Research 

Opportunities Fellowships for Undergraduate 

Environmental Study

1,532,099

Environmental Protection Agency Marshall Scholars 

Program

205,888

National Environmental Education and Training 

Partnership 

2,259,500

National Network for Environmental Management 

Studies Fellowship Program

469,403

P3 Award: National Student Design Competition for 

Sustainability

2,000,000

President’s Environmental Youth Awards 50,000

Science to Achieve Results Graduate Fellowship 

Program

6,387,830

University of Cincinnati/ Environmental Protection 

Agency Research Training Grant 

333,153

Source: GAO analysis of survey data, Science, Technology, Engineering, and Mathematics Education: Strategic Planning Needed to 

Better Manage Overlapping Programs across Multiple Agencies, GAO-12-108 (Washington, D.C.: Jan. 20, 2012). 

a

This number equals the total program obligations for fiscal year 2010, unless the survey respondent 

provided obligations for the STEM only activities within the program. 

b

Program funding was authorized in 2010, but was not obligated until 2011. 

c

Fiscal year 2010 obligations for the Technical Career Intern Program are reflected in the Mickey 

Leland Program. 
 

Page 386 GAO-12-342SP Lists of Programs Identified

Table 15: Financial Literacy: List of Programs and Activities and Related Budgetary Information

Agency Program or activity

FY 2010 estimate 

for portion of 

program costs 

attributed to 

financial literacy 

activitiesa Notes

Financial literacy

Board of Governors of the 

Federal Reserve System

Division of Consumer and Community Affairs $1,029,885 Estimate of calendar year 

2010 costs provided by 

agency staff

Consumer Financial 

Protection Bureau

Office of Financial Education and other offices Not applicable Agency had not yet been 

created at the beginning of 

FY 2010

Department of Agriculture Family and Consumer Economics programs 8,433,500 Estimate of FY 2010 costs 

provided by agency staff

Department of Defense Family Support Centers (including Financial 

Readiness Campaign)

Estimate pendingb

Department of Education Excellence in Economic Education Program 1,447,000C FY 2010 obligations 

Financial Education for College Access and 

Success Program

1,700,000C FY 2010 obligations 

Department of Health and 

Human Services

National Education and Resource Center on 

Women and Retirement Planning

245,763 FY 2010 obligations 

Department of Labor Retirement Savings Education Campaign 365,387 Estimate of FY 2010 costs 

provided by agency staff

Wi$eUp 170,000 Estimate of FY 2010 costs 

provided by agency staff

Department of the Treasury Office of Financial Education and Financial 

Access (including staff support for the 

Financial Literacy and Education Commission, 

and other initiatives)

2,100,000 Estimate of FY 2010 costs 

provided by agency staff

Federal Deposit Insurance 

Corporation

Money Smart Financial Education Program 2,749,594 Estimate of FY 2010 costs 

provided by agency staff

Federal Trade Commission Division of Consumer and Business Education 784,904 Estimate of FY 2010 costs 

provided by agency staff

Office of the Comptroller of 

the Currency

Consumer education activities 450,000d Estimate of FY 2010 costs 

provided by agency staff.

Securities and Exchange 

Commission 

Office of Investor Education and Advocacy 2,000,000 Estimate of FY 2010 costs 

provided by agency staff

Social Security Administration Financial Literacy Research Consortium 9,221,000e Estimate of FY 2010 costs 

provided by agency staff

Total (Financial literacy activities) $30,697,033

Housing Counseling and Foreclosure Mitigationf

Department of Housing and 

Urban Development

Housing Counseling Assistance Program $65,420,000g FY 2010 obligations 

Department of the Treasury Financial Education and Counseling Pilot 

Program

4,150,000h FY 2010 appropriation

NeighborWorks Americai National Foreclosure Mitigation Counseling 

Program

65,000,000 FY 2010 obligations 

Other housing counseling activities 2,000,000 Estimate of FY 2010 costs 

provided by agency staff

Total (Housing counseling and foreclosure mitigation activities) $136,570,000

Source: GAO analysis of federal financial literacy programs and activities.
 

Page 387 GAO-12-342SP Lists of Programs Identified

a

Cost estimates represent the portion of the program or activity related specifically to financial literacy 

and education, which in most cases included the estimated cost of staff time. However, because 

agencies may have used slightly different methods in estimating costs, dollar figures across agencies 

may not be fully comparable. 

b

As of February 1, 2012, we were still developing a cost estimate related to these activities and we 

expect to provide this estimate in a future report. 

C

The Excellence in Economic Education Program and the Financial Education for College Access 

and Success Program did not receive funding in fiscal year 2012. 

d

Represents midpoint of the staff estimate of costs as ranging from $400,000-$500,000. 

e

The Financial Literacy Research Consortium did not receive new funding after fiscal year 2010, 

according to agency staff.

f

In addition to the agencies listed below, some programs of the Department of Defense and the 

Department of Veterans Affairs include some element of housing counseling. 

g

Program received no appropriation in fiscal year 2011. Fiscal year 2010 amount includes HUD 

grants to NeighborWorks America of $1,250,501 for comprehensive counseling and $500,000 for 

counseling under the Home Equity Conversion Mortgage program. These grants were separate from 

the congresssional appropriations to Neighborworks cited below. 

h

The Financial Education and Counseling Pilot Program was not appropriated funds in fiscal years 

2011 and 2012. 

i

NeighborWorks America is a federally chartered nonprofit corporation that receives an annual 

appropriation from Congress. 
 

Page 388 GAO-12-342SP Agency Comments

Appendix IV: Agency Comments 

For issues where information is being reported on for the first time in this 

report, we sought comments from the agencies involved, and 

incorporated those comments as appropriate. This appendix includes only 

those letters that agencies provided on official letterhead.
 

Page 389 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 7: 

Support for 

Entrepreneurs.
 

Page 390 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 7: 

Support for 

Entrepreneurs.
 

Page 391 GAO-12-342SP Agency Comments
 

Page 392 GAO-12-342SP Agency Comments
 

Page 393 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 14: 

Health Research 

Funding.
 

Page 394 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 14: 

Health Research 

Funding.
 

Page 395 GAO-12-342SP Agency Comments
 

Page 396 GAO-12-342SP Agency Comments
 

Page 397 GAO-12-342SP Agency Comments
 

Page 398 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 23: 

Space Launch Contract 

Costs.
 

Page 399 GAO-12-342SP Agency Comments
 

Page 400 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 29: 

Early Learning and Child 

Care.
 

Page 401 GAO-12-342SP Agency Comments
 

Page 402 GAO-12-342SP Agency Comments
 

Page 403 GAO-12-342SP Agency Comments
 

Page 404 GAO-12-342SP Agency Comments
 

Page 405 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 30: 

Employment for People 

with Disabilities.
 

Page 406 GAO-12-342SP Agency Comments
 

Page 407 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 31: 

Science, Technology, 

Engineering, and 

Mathematics Education.
 

Page 408 GAO-12-342SP Agency Comments
 

Page 409 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 32: 

Financial Literacy.
 

Page 410 GAO-12-342SP Agency Comments
 

Page 411 GAO-12-342SP Agency Comments
 

Page 412 GAO-12-342SP Agency Comments
 

Page 413 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 32: 

Financial Literacy.
 

Page 414 GAO-12-342SP Agency Comments
 

Page 415 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 39: 

Auto Recovery Office.
 

Page 416 GAO-12-342SP Agency Comments
 

Page 417 GAO-12-342SP Agency Comments
 

Page 418 GAO-12-342SP Agency Comments
 

Page 419 GAO-12-342SP Agency Comments
 

Page 420 GAO-12-342SP Agency Comments
 

Page 421 GAO-12-342SP Agency Comments
 

Page 422 GAO-12-342SP Agency Comments

Note: This letter includes 

comments on Area 42: 

U.S. Currency.
 

Page 423 GAO-12-342SP Agency Comments
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