DEFENSE-WIDE 

WORKING CAPITAL 

FUND

Action Needed to 

Maintain Cash 

Balances within 

Required Levels

Report to the Subcommittee on 

Readiness and Management Support, 

Committee on Armed Services, U.S. 

Senate

June 2017

GAO-17-465

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-465, a report to the 

Subcommittee on Readiness and 

Management Support, Committee on Armed 

Services, U.S. Senate

June 2017

DEFENSE-WIDE WORKING CAPITAL FUND

Action Needed to Maintain Cash Balances within 

Required Levels

What GAO Found

The Defense-wide Working Capital Fund’s (DWWCF) reported monthly cash 

balances were outside the upper and lower cash requirements as defined by the 

Department of Defense’s (DOD) Financial Management Regulation (FMR) for 87 

of 120 months, and more than 12 consecutive months on three separate 

occasions during fiscal years 2007 through 2016. Reasons why the balances 

were outside the requirements at selected periods of time include the following: 

• The Defense Logistics Agency (DLA) disbursed about $1.3 billion more in

fiscal year 2008 for, among other things, the purchase of fuel than it collected

from the sale of fuel because of higher fuel costs.

• DOD transferred $1.4 billion to the DWWCF in fiscal year 2013 because of

cash shortfalls that resulted from DLA paying higher costs for fuel.

• DLA collected about $3.7 billion more from the sale of fuel than it disbursed

for fuel in fiscal year 2015 because of lower fuel costs.

Although the DOD FMR contains guidance on tools DOD managers can use to 

help ensure that the monthly cash balances are within the requirements, the 

regulation does not provide guidance on when to use the tools. Without this 

guidance, DOD risks not taking prompt action to bring the monthly cash balances 

within requirements. When monthly cash balances are outside requirements for 

long periods of time, the DWWCF is at further risk of not paying its bills on time 

or holding funds that could be used for other higher priorities.

The DWWCF’s Reported Monthly Cash Balances Compared to DOD Upper and Lower Cash 

Requirements

Initially, the DWWCF’s cash plan that supports the fiscal year 2017 President’s 

Budget, dated February 2016, showed the monthly balances were projected to 

be above the upper cash requirement for most of fiscal year 2017. However, its 

October 2016 revised plan showed that the monthly cash balances were 

projected to be within the requirements for all 12 months. The plan changed 

because (1) DOD made unplanned cash transfers out of the DWWCF in the 

second half of fiscal year 2016 and (2) DOD reduced the standard fuel price in 

September 2016, leading to lower projected cash balances for fiscal year 2017. View GAO-17-465. For more information, 

contact Asif A. Khan at (202) 512-9869 or 

khana@gao.gov. 

Why GAO Did This Study

The Defense Finance and Accounting 

Service, the Defense Information 

Systems Agency, and DLA use the 

DWWCF to charge for goods and 

services provided to the military 

services and other customers. The 

DWWCF relies primarily on sales 

revenue rather than annual 

appropriations to finance its continuing 

operations. The DWWCF reported total 

revenue of $45.7 billion in fiscal year 

2016 from (1) providing finance, 

accounting, information technology, 

and energy solution services to the 

military services and (2) managing 

inventory items for the military 

services.

GAO was asked to review issues 

related to DWWCF cash management. 

GAO’s objectives were to determine to 

what extent (1) the DWWCF’s reported 

monthly cash balances were within 

DOD’s upper and lower cash 

requirements from fiscal years 2007 

through 2016 and (2) the DWWCF’s 

projected monthly cash balances were 

within the upper and lower cash 

requirements for fiscal year 2017. To 

address these objectives, GAO 

reviewed relevant DOD cash 

management guidance, analyzed 

DWWCF actual reported and projected 

cash balances and related data, and 

interviewed DWWCF officials.

What GAO Recommends

GAO recommends that DOD update 

the FMR to include guidance on the 

timing of when DOD managers should 

use available tools to help ensure that 

monthly cash balances are within the 

upper and lower cash requirements.

DOD concurred with GAO’s 

recommendation and cited related 

actions planned.
Page i GAO-17-465 Defense-wide Working Capital Fund

Letter 1

Background 4

The DWWCF’s Reported Monthly Cash Balances Frequently Fell 

Outside the Upper and Lower Cash Requirements from Fiscal 

Years 2007 through 2016 9

The DWWCF’s Revised Monthly Cash Balances Are Projected to 

Be within the Upper and Lower Cash Requirements for Fiscal 

Year 2017 18

Conclusions 20

Recommendation for Executive Action 21

Agency Comments 22

Appendix I Scope and Methodology 23

Appendix II Comments from the Department of Defense 25

Appendix III GAO Contact and Staff Acknowledgments 27

Table

Table 1: The Defense-wide Working Capital Fund’s Reported 

Monthly Cash Balances Compared to Upper and Lower 

Cash Requirements for Fiscal Years 2007 through 2016, 

by Fiscal Year 11

Figures

Figure 1: The DWWCF’s Reported Cash Balances Compared to 

Upper and Lower Cash Requirements for Fiscal Years 

2007 through 2016, by Month 10

Figure 2: President’s Budget and Revised Defense-wide Working 

Capital Fund Monthly Cash Plans Compared to the 

Upper and Lower Cash Requirements for Fiscal Year 

2017 19

Contents
Page ii GAO-17-465 Defense-wide Working Capital Fund

Abbreviations

DFAS Defense Finance and Accounting Service

DISA Defense Information Systems Agency

DLA Defense Logistics Agency

DOD Department of Defense

DWWCF Defense-wide Working Capital Fund 

OUSD Office of the Under Secretary of Defense

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

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

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

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

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-465 Defense-wide Working Capital Fund

441 G St. N.W.

Washington, DC 20548

June 30, 2017 

The Honorable James M. Inhofe

Chairman

The Honorable Tim Kaine

Ranking Member

Subcommittee on Readiness and Management Support

Committee on Armed Services

United States Senate

The Defense Finance and Accounting Service (DFAS), the Defense 

Information Systems Agency (DISA), and the Defense Logistics Agency 

(DLA) use the Defense-wide Working Capital Fund (DWWCF) to charge 

for goods and services provided to a variety of customers, including the 

Army, the Navy, the Air Force, other Department of Defense (DOD) and 

non-DOD agencies, and foreign countries. Under the working capital fund 

concept, the DWWCF charges these customers for the anticipated full 

cost of these goods and services. For fiscal year 2016, the three DOD 

agencies reported total revenue of $45.7 billion for the DWWCF, 

including, among other things, (1) DFAS providing finance and accounting 

services to the military services and defense agencies; (2) DISA providing 

global information technology solutions to the military services and 

defense agencies; and (3) DLA managing about 6.2 million inventory 

items and providing comprehensive worldwide energy solutions for the 

military services, which included selling about 99 million barrels of fuel to 

customers.

The DWWCF needs to maintain a sufficient cash balance to pay its bills 

and sustain operations to achieve its mission. The availability of cash in 

the DWWCF depends on the outcome of many decisions made during 

DOD’s budget process with regard to (1) projecting workloads, 

(2) estimating costs, and (3) setting prices to recover the estimated full 

cost of providing goods and services. The DWWCF cash balance1 is 

directly affected by collections from the sale of goods and services; 

1

For the purposes of this report, we will refer to the DWWCF’s Fund Balance with 

Treasury as cash. According to DOD Financial Management Regulation 7000.14-R, vol. 4, 

ch. 2, Accounting for Cash and Fund Balances with Treasury, pp. 2-6 and 2-7 (January 

2016), the Fund Balance with Treasury is the aggregate amount of funds in the entity’s 

accounts with Treasury for which the entity is authorized to make expenditures and pay 

liabilities. Collections and disbursements will correspondingly increase or decrease the 

balance in the account. 

Letter
Page 2 GAO-17-465 Defense-wide Working Capital Fund

disbursements for salaries, inventory purchases, and other items; 

appropriations passed by Congress and enacted into law; and transfers 

into and out of the DWWCF.2 A disbursement in excess of available cash 

would potentially constitute an Antideficiency Act violation.3 Conversely, if 

the DWWCF builds excess cash balances, it could be subject to reduced 

budget requests by DOD, transfers from the DWWCF to other 

appropriation accounts, or rescissions. For example, because of an 

excess cash balance in the DWWCF, Congress rescinded $1.037 billion 

from the DWWCF in fiscal year 2016. Consequently, it is important for the 

DWWCF to manage its cash balance to stay within the upper and lower 

cash requirements.4

You asked us to review issues related to DWWCF cash management. 

Our objectives were to determine to what extent (1) the DWWCF’s 

reported monthly cash balances were within DOD’s upper and lower cash 

requirements from fiscal years 2007 through 2016 and (2) the DWWCF’s 

projected monthly cash balances were within the upper and lower cash 

requirements for fiscal year 2017.

To address the first objective, we (1) obtained the DWWCF reported 

monthly cash balances for fiscal years 2007 through 2016 and 

(2) compared the upper and lower cash requirements to the monthending reported cash balances. If the cash balances were not within the 

upper and lower requirement amounts, we met with DLA, DISA, and 

 2

A transfer is the shifting of budget authority from one appropriation or fund account to 

another. Agencies may transfer budget authority only as authorized by law. DOD’s annual 

appropriations typically include transfer authorities but require, among other things, that 

the Secretary of Defense notify Congress each time these authorities are used. See, e.g., 

Consolidated Appropriations Act, 2016, Pub. L. No. 114-113, div. C, §§ 8005, 8008, 129 

Stat. 2242, 2350-2352 (Dec. 18, 2015).

3

The Antideficiency Act, among other things, provides that no officer or employee of the 

government shall make or authorize an expenditure or obligation exceeding the amount of 

an appropriation, fund, or apportionment available for expenditure or obligation. 31 U.S.C. 

§§ 1341(a)(1), 1517.

4

The DOD Financial Management Regulation establishes the formula to be used for 

calculating the upper and lower cash requirements. The formula includes several factors, 

such as information on disbursements, in determining the upper and lower cash 

requirements. The DWWCF has implemented an altered calculation formula contained in 

a draft update to this portion of the DOD Financial Management Regulation, in advance of 

its formal publication, as instructed by the Office of the Under Secretary of Defense 

(Comptroller). See DOD Financial Management Regulation 7000.14-R, vol. 2B, ch. 9, 

Defense Working Capital Fund Budget Justification Analysis, pp. 9-8 and 9-9 (July 2015 

Draft).
Page 3 GAO-17-465 Defense-wide Working Capital Fund

DFAS officials and reviewed DWWCF budgets and other documentation 

to ascertain the reasons. Further, to determine the extent that cash 

transfers for fiscal years 2007 through 2016 caused the DWWCF cash 

balances to be above or below the cash requirements, we analyzed DOD 

budget and accounting reports to determine the dollar amount of transfers 

made for the period. We analyzed cash transfers to determine if any of 

the transfers contributed to the cash balances falling outside the upper or 

lower cash requirements and, if so, the amount that fell outside those 

requirements. We also obtained and analyzed documents that provide 

information on transfer of funds into and out of the DWWCF and 

interviewed key DLA, DISA, and DFAS officials to determine the reasons 

for the transfers.

To address the second objective, we obtained and analyzed DWWCF 

budget documents and cash management plans for fiscal year 2017. We 

compared the upper and lower cash requirements to the month-ending 

projected cash balances. If the projected monthly cash balances were 

above or below the cash requirement, we discussed these balances with 

DLA officials to ascertain the reasons.

We obtained the DWWCF financial data in this report from DOD budget 

documents and accounting reports. To assess the reliability of these data, 

we (1) obtained the DOD regulation on calculating the upper and lower 

cash requirements; (2) reviewed DLA’s calculations of the cash 

requirements to determine if they were calculated in accordance with 

DOD regulations; (3) interviewed DLA, DISA, and DFAS officials 

knowledgeable about the cash data; (4) compared DWWCF cash balance 

information (including collections and disbursements) contained in 

different reports to ensure that the data reconciled; (5) obtained an 

understanding of the process DFAS used to reconcile DWWCF cash 

balances with Department of the Treasury records; and (6) obtained and 

analyzed documentation supporting the amount of funds transferred into 

and out of the DWWCF. On the basis of these procedures, we have 

concluded that these data were sufficiently reliable for the purposes of 

this report. A more detailed discussion of our scope and methodology is 

contained in appendix I.

We conducted this performance audit from June 2016 to June 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 
Page 4 GAO-17-465 Defense-wide Working Capital Fund

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The DWWCF is intended to (1) generate sufficient resources to cover the 

full cost of its operations and (2) operate on a break-even basis over 

time—that is, neither make a gain nor incur a loss. Customers primarily 

use appropriated funds to finance orders placed with the DWWCF. Cash 

generated from the sale of goods and services, rather than annual 

appropriations, is the DWWCF’s primary means of maintaining an 

adequate level of cash to sustain its operations. The ability to operate on 

a break-even basis and generate cash consistent with DOD’s regulations 

depends on accurately (1) projecting workload, (2) estimating costs, and 

(3) setting prices to recover the full costs of producing goods and 

services. DOD policy requires the DWWCF to establish its sales prices 

prior to the start of each fiscal year and to apply these predetermined or 

“stabilized” prices to most orders received during the year—regardless of 

when the work is accomplished or what costs are incurred. Stabilized 

prices provide customers with protection during the year of execution 

from prices greater than those assumed in the budget and permit 

customers to execute their programs as authorized by Congress.

Developing accurate prices is challenging because the process to 

determine the prices begins about 2 years in advance of when the 

DWWCF actually receives customers’ orders and performs the work. In 

essence, the DWWCF’s budget development has to coincide with the 

development of its customers’ budgets so that they both use the same set 

of assumptions. To develop prices, the DWWCF estimates labor, 

material, and other costs based on anticipated demand for work as 

projected by customers. Higher-than-expected costs or lower-thanexpected customer sales for goods and services can result in lower cash 

balances. Conversely, lower-than-expected costs or higher-than-expected 

customer sales for goods and services can result in higher cash 

balances. Because the DWWCF must base sales prices on assumptions 

made as long as 2 years before the prices go into effect, some variance 

between expected and actual costs and sales is inevitable.5

If projections of cash disbursements and collections indicate that cash 

balances will drop below the lower cash requirement, the DWWCF may 

 5

For DOD fuel prices, DOD has the option of raising or lowering the standard price during 

the budget year of execution to account for actual prices for fuel on the world market. 

However, according to DOD officials, this is not their preferred approach.

Background
Page 5 GAO-17-465 Defense-wide Working Capital Fund

need to generate additional cash. One way this may be done is to bill 

customers in advance for work not yet performed. Advance billing 

generates cash almost immediately by billing DWWCF customers for 

work that has not been completed. This method is a temporary solution 

and is used only when cash reaches critically low balances because it 

requires manual intervention in the normal billing and payment processes.

During fiscal year 2016, DLA, DISA, and DFAS reported total revenue of 

$45.7 billion through the DWWCF.

• DLA: During fiscal year 2016, DLA reported total revenue of 

$37.5 billion. In addition to centrally managing DWWCF cash, DLA 

operates three activity groups: Supply Chain Management, Energy 

Management, and Document Services. The Supply Chain 

Management activity group manages material from initial purchase, to 

distribution and storage, and finally to disposal or reutilization. This 

activity group fills about 36.6 million customer orders annually and 

manages approximately 6.2 million consumable items, including 

(1) 2.6 million repair parts and operating supply items to support 

aviation, land, and maritime weapon system platforms; (2) dress and 

field uniforms, field gear, and personal chemical protective items to 

support military servicemembers and other federal agencies;

(3) 1.3 million medical items for military servicemembers and their 

dependents; and (4) subsistence and construction items to support 

our troops both at home and abroad.6 The Energy Management 

activity group provides comprehensive worldwide energy solutions to 

DOD as well as other authorized customers. This activity group 

provides goods and services, including petroleum, aviation, and 

natural gas products; facility and equipment maintenance on fuel 

infrastructure; coordination of bulk petroleum transportation; and 

energy-related environmental assessments and cleanup. The 

Document Services activity group is responsible for DOD printing, 

duplicating, and document automation programs.

• DISA: During fiscal year 2016, DISA reported total revenue of 

$6.8 billion. DISA is a combat support agency responsible for 

planning, engineering, acquiring, fielding, and supporting global 

information technology solutions to serve the needs of the military 

services and defense agencies. It operates the Information Services 

 6

Consumable supply items are consumed in use or discarded when worn out or broken 

because they cannot be repaired economically. 

Description of DWWCF 

Work Performed by DLA, 

DISA, and DFAS
Page 6 GAO-17-465 Defense-wide Working Capital Fund

activity group within the DWWCF. This activity group consists of two 

components: Computing Services and Telecommunications 

Services/Enterprise Acquisition Services. 

The Computing Services component operates eight Defense 

Enterprise Computing Centers, which provide mainframe and server 

processing operations, data storage, production support, technical 

services, and end-user assistance for command and control, combat 

support, and enterprise service applications across DOD. The 

computing centers support over 4 million users through 21 

mainframes and almost 14,500 servers. Among other things, these 

services enable DOD components to (1) provide for the command and 

control of operating forces; (2) ensure weapons systems availability 

through management and control of maintenance and supply; and 

(3) provide operating forces with information on the location, 

movement, status, and identity of units and supplies.

The Telecommunications Services/Enterprise Acquisition Services 

component provides telecommunications services to meet DOD’s 

command and control requirements. One element of this component 

is the Defense Information System Network. The Defense Information

System Network is a collection of telecommunication networks that 

provides secure and interoperable connectivity of voice, data, text, 

imagery, and bandwidth services for DOD, coalition partners, 

combatant commands, and other federal agencies. Another element 

of this component is the Enterprise Acquisition Services, which 

provides contracting services for information technology and 

telecommunications acquisitions from the commercial sector and 

provides contracting support to the Defense Information System 

Network programs as well as to other DISA, DOD, and authorized 

non-Defense customers.

• DFAS: During fiscal year 2016, DFAS reported total revenue of

$1.4 billion. DFAS pays all DOD military and civilian personnel, 

military retirees and annuitants, and DOD contractors and vendors. In 

fiscal year 2016, DFAS processed about 122 million pay transactions, 

paid 12 million commercial invoices, accounted for 1,359 active DOD 

appropriations while maintaining 152 million general ledger accounts, 

and made $535 billion in disbursements to about 6.4 million 

customers.
Page 7 GAO-17-465 Defense-wide Working Capital Fund

DOD requires each of its working capital funds to maintain a minimum 

cash balance sufficient to pay bills, which, for the DWWCF, includes 

payments for (1) consumable items (spare parts) and petroleum products 

from vendors; (2) employees’ salaries to perform material management, 

information services, and finance and accounting functions; and 

(3) expenses associated with the maintenance and operations of DLA, 

DISA, and DFAS facilities.7 The provisions of the DOD Financial 

Management Regulation that provides guidance on the calculation of 

DOD working capital funds’ upper and lower cash requirements, have 

changed several times over the past 10 years—the period covered by our 

audit—as discussed below.8

Prior to June 2010, DOD’s Financial Management Regulation stated that 

“cash levels should be maintained at 7 to 10 days of operational cost and 

cash adequate to meet six months of capital disbursements.”9 Thus, the 

minimum cash requirement consisted of 6 months of capital requirements 

plus 7 days of operational cost, and the maximum cash requirement 

consisted of 6 months of capital requirements plus 10 days of operational 

cost. The regulation further provided that a goal of DOD working capital 

funds was to minimize the use of advance billing of customers to maintain 

cash solvency, unless advance billing is required to avoid Antideficiency 

Act violations.

The DOD Financial Management Regulation was amended in June 2010. 

As a result, from June 2010 through June 2015, DOD working capital 

funds were allowed—with the approval of the Office of the Under 

Secretary of Defense (Comptroller), Director of Revolving Funds—to 

 7

See DOD Financial Management Regulation 7000.14-R, vol. 2B, ch. 9, Defense Working 

Capital Fund Budget Justification Analysis, p. 9-7 (December 2014). 

8

In determining cash requirements, the DOD Financial Management Regulation requires 

DOD working capital funds to determine (1) an upper estimate or maximum cash level 

expected based on budgeted assumptions and historical trends and (2) a lower estimate 

or minimum cash level expected based on budgeted assumptions and historical trends. 

Thus, monthly cash levels are expected to be between the upper and lower estimates 

during the fiscal year. 

9

Capital disbursements are purchases of assets that equal or exceed capitalization 

thresholds and have a useful life of 2 or more years. For minor construction projects, the 

capitalization threshold is $100,000; for all other assets, the capitalization threshold is 

$250,000. See DOD Financial Management Regulation 7000.14-R, vol. 2B, ch. 9, 

Defense Working Capital Funds Activity Group Analysis, pp. 9-5 and 9-6 (September 

2008).

DOD Cash Management 

Policy
Page 8 GAO-17-465 Defense-wide Working Capital Fund

incorporate three new adjustments into the formula for calculating the 

minimum and maximum cash requirements.10 These adjustments would 

increase the minimum and maximum cash requirements. First, a working 

capital fund could increase the cash requirements by the amount of 

accumulated profits planned for return to customer accounts. A working 

capital fund returns accumulated profits to its customers by reducing 

future prices so it can operate on a break-even basis over time. The 

second adjustment allowed by the revised DOD Financial Management 

Regulation was for funds appropriated to the working capital fund that 

were obligated in the year received but not fully spent until future years. 

The adjustment allowed the working capital fund to retain these amounts 

as an addition to their normal operational costs. Finally, a working capital 

fund could increase the minimum and maximum cash requirements by 

the marginal cash required to purchase goods and services from the 

commodity or business market at a higher price than that submitted in the 

President’s Budget. The adjustment reflected the cash impact of the 

specified market fluctuation.

Beginning in July 2015, DOD revised its cash management policy to 

maintain a positive cash balance throughout the year and an adequate 

ending balance to support continuing operations into the subsequent 

year.11 In setting the upper and lower cash requirements, DOD working 

capital funds are to consider the following four elements:

• Rate of disbursement. The rate of disbursement is the average 

amount disbursed between collection cycles. It is calculated by 

dividing the total amount of disbursements planned for the year by the 

number of collection cycles planned for the year. The rate describes 

the average amount of cash needed to cover disbursements from one 

collection cycle to the next.

• Range of operation. The range of operation is the difference 

between the highest and lowest expected cash levels based on 

budget assumptions and past experience. The DOD Financial 

Management Regulation noted that cash balances are not static and 

 10See DOD Financial Management Regulation 7000.14-R, vol. 2B, ch. 9, Defense 

Working Capital Fund Activity Group Analysis, p. 9-6 (June 2010).

11See DOD Financial Management Regulation 7000.14-R, vol. 2B, ch. 9, Defense 

Working Capital Fund Budget Justification Analysis, p. 9-7 (July 2015 Draft). Although this 

update has not yet been officially published, the DWWCF is implementing the cash 

management policies in the draft regulation, as instructed by the Office of the Under 

Secretary of Defense (Comptroller).
Page 9 GAO-17-465 Defense-wide Working Capital Fund

volatility can be expected because of annual, quarterly, and more 

frequent seasonal trends and significant onetime events.

• Risk mitigation. Some amount of cash is required, beyond the range 

of operation discussed above, to mitigate the inherent risk of 

unplanned and uncontrollable events. The risks may include budget 

estimation errors, commodity price fluctuations, and crisis response 

missions.

• Reserves. Cash reserves are funds held for known future 

requirements. This element provides for cash on hand to cover 

specific requirements that are not expected to disburse until 

subsequent fiscal years.

Our analysis of DWWCF cash data showed that the DWWCF monthly 

cash balances fluctuated significantly from fiscal years 2007 through 2016 

and were outside the upper and lower cash requirements for 87 of the 

120 months—about 73 percent of the time for this period. Reasons why 

the monthly cash balances were outside the cash requirements included, 

among other things, (1) DLA charging its customers more or less than it 

cost to purchase, refine, transport and store fuel and (2) DOD transferring 

funds into or out of the DWWCF to pay for combat fuel losses or other 

higher priorities. During this 10-year period, DOD took actions to adjust 

the DWWCF cash balance, such as transferring funds to other 

appropriation accounts, but the actions did not always bring the balances 

within the requirements in a timely manner. As a result, the monthly cash 

balances were above or below the cash requirements for more than 12 

consecutive months on three separate occasions from fiscal years 2007 

through 2016. Figure 1 shows the DWWCF monthly cash balances 

compared to the upper and lower cash requirements from fiscal years 

2007 through 2016.

The DWWCF’s 

Reported Monthly 

Cash Balances 

Frequently Fell 

Outside the Upper 

and Lower Cash 

Requirements from 

Fiscal Years 2007 

through 2016
Page 10 GAO-17-465 Defense-wide Working Capital Fund

Figure 1: The DWWCF’s Reported Cash Balances Compared to Upper and Lower Cash Requirements for Fiscal Years 2007 

through 2016, by Month

Further, for the 10-year period, the DWWCF’s reported monthly cash 

balances were above the cash requirement 62 times, between the upper 

and lower cash requirements 33 times, and below the cash requirement 

25 times. Table 1 shows the number of months the DWWCF monthly 

cash balances were above, between, or below the upper and lower cash 

requirements for each of the 10 years reviewed.
Page 11 GAO-17-465 Defense-wide Working Capital Fund

Table 1: The Defense-wide Working Capital Fund’s Reported Monthly Cash Balances Compared to Upper and Lower Cash 

Requirements for Fiscal Years 2007 through 2016, by Fiscal Year

Source: GAO analysis of Defense-wide Working Capital Fund cash data. | GAO-17-465

The monthly cash balances were above or below the cash requirements 

more than 12 consecutive months on three separate occasions from fiscal 

years 2007 through 2016. Specifically, the monthly cash balances were 

(1) below the lower cash requirement for 13 consecutive months 

beginning in October 2007, (2) above the upper cash requirement for 29 

consecutive months beginning in March 2010, and (3) above the upper 

cash requirement for 15 consecutive months beginning in April 2015.

The draft DOD Financial Management Regulation currently being 

implemented by the DWWCF provides information on the management 

tools DOD cash managers can use to bring cash balances within the 

upper and lower cash requirements.12 The draft regulation states that 

these tools include, but are not limited to,

• changing the frequency of collections;

 12See DOD Financial Management Regulation 7000.14-R, vol. 2B, ch. 9, Defense 

Working Capital Fund Budget Justification Analysis, pp. 9-7 and 9-9 (July 2015 Draft). 

Although this update has not yet been officially published, the DWWCF is implementing 

the cash management policies in the draft regulation, as instructed by the Office of the 

Under Secretary of Defense (Comptroller).

Fiscal year

Number of months compared to upper and lower cash requirements

Above Between Below

2007 2 6 4

2008 0 0 12

2009 2 7 3

2010 7 2 3

2011 12 0 0

2012 10 2 0

2013 4 5 3

2014 10 2 0

2015 6 6 0

2016 9 3 0

Total 62 33 25

The DWWCF’s Reported 

Monthly Cash Balances 

Were Outside Upper and 

Lower Cash Requirements 

for More Than 12 

Consecutive Months Three 

Times during Fiscal Years 

2007 through 2016
Page 12 GAO-17-465 Defense-wide Working Capital Fund

• controlling the timing of contract renewals and large obligations or 

disbursements;

• negotiating the timing of customer orders and subsequent work; and

• requesting policy waivers, when necessary.

In addition, the draft DOD Financial Management Regulation also 

provides guidance on transfers of cash between DOD working capital 

fund activities or between DOD working capital fund activities and 

appropriation-funded activities. DOD has used transfers to increase or 

decrease cash balances in the past, under authorities provided in annual 

appropriations acts.

We determined that DOD took actions during fiscal years 2007 through 

2016 to increase or decrease cash balances in the DWWCF. An Office of 

the Under Secretary of Defense (OUSD) (Comptroller) official informed us 

that DLA provides the OUSD (Comptroller) monthly information on 

DWWCF cash balances compared to the upper and lower cash 

requirements. This information is used by the OUSD (Comptroller) and 

DWWCF officials to determine whether actions are needed to increase or 

decrease the DWWCF cash balance, such as transferring funds into or 

out of the DWWCF. Our analysis of accounting documentation and 

discussions with OUSD (Comptroller) and DLA officials showed that DOD 

used two types of actions to increase or decrease the monthly cash 

balances to help bring the cash balances within the cash requirements 

during the 10-year period of our review.

First, DOD transferred a total of about $9 billion into and out of the 

DWWCF to adjust the cash balance during this period.13 For example, 

DOD transferred about $3 billion from the DWWCF to other DOD 

appropriation accounts throughout fiscal year 2016. This reduced the 

DWWCF cash balance to within the cash requirements after remaining 

above the upper cash requirement for 15 consecutive months from April 

2015 to July 2016. Second, the OUSD (Comptroller), in coordination with 

DLA, adjusted the standard fuel prices upward or downward a total of 16 

times outside of the normal budget process. For example, in fiscal year 

2012, DOD lowered the standard fuel price three times from October 

2011 through July 2012 to help offset cash increases by DLA Energy 

 13We obtained and analyzed documentation supporting the $9 billion that DOD transferred 

into and out of the DWWCF during fiscal years 2007 through 2016. Based on our analysis, 

we determined that each of these transfers was either directed by statute or made under 

general transfer authority and accompanied by the required congressional notification.
Page 13 GAO-17-465 Defense-wide Working Capital Fund

Management on the sale of fuel to its customers. These price changes 

helped offset further increases in the cash balances, but they did not 

reduce the monthly cash balances to within the cash requirements during 

this period.

Although DOD managers used management tools such as transfers and 

price adjustments to help bring the DWWCF monthly cash balances 

within upper and lower cash requirements, such actions did not always 

bring the balances within the requirements in a timely manner. 

Specifically, as noted above, the DWWCF monthly cash balances were 

outside the upper and lower cash requirements for 12 consecutive 

months on three separate occasions during the 10-year period of our 

audit. We selected the 12-month period for comparing the monthly cash 

balances to the cash requirements because (1) DOD develops a budget 

every 12 months; (2) the DWWCF annual budget projects fiscal year-end 

cash balances and the upper and lower cash requirements based on 12-

month cash plans that include information on projected monthly cash 

balances, and whether those projected monthly cash balances fall within 

the cash requirements; and (3) DOD revises the DWWCF stabilized 

prices that it charges customers for goods and services every 12 months 

during the budget process.

Our analysis of both the current official DOD Financial Management 

Regulation and the provisions of the draft version that DOD has begun 

implementing determined that the regulations do not provide guidance on 

the timing of when DOD managers should use available management 

tools so that they would be effective in helping to ensure monthly cash 

balances are within the upper and lower cash requirements. Without this 

guidance, DOD risks not taking prompt action to bring the monthly cash 

balances within the cash requirements.

When DWWCF monthly cash balances are below the lower cash 

requirements for long periods, the DWWCF is at greater risk of either 

(1) not paying its bills on time or (2) making a disbursement in excess of 

available cash, which would potentially constitute an Antideficiency Act 

violation. In cases of cash balances above the upper requirement, the 

DWWCF may be holding funds that could be used for higher priorities.
Page 14 GAO-17-465 Defense-wide Working Capital Fund

The DWWCF monthly cash balances were below the lower cash 

requirement for 19 of the 36 months from fiscal years 2007 through 2009, 

as shown in table 1. During the 3-year period, the DWWCF reported that 

monthly cash balances were below the lower cash requirement for 13 

consecutive months from October 2007 through October 2008, falling to 

their lowest point in December 2007 at $574 million—$890 million below 

the lower cash requirement.

According to DLA and DISA officials and our analysis of financial 

documentation, the monthly cash balances were below the lower cash 

requirement for more than half of the 3-year period for four primary 

reasons.

• First, during the first 4 months of fiscal year 2007, DISA disbursed 

$340 million more than it collected because (1) DISA’s customers 

received funding late in the first quarter of fiscal year 2007, which 

delayed certain support service contracts with DISA that in turn 

delayed DWWCF collections until the second quarter of fiscal year 

2007, and (2) DISA reduced fiscal year 2007 prices to return prior 

year accumulated profits to its customers.

• Second, DOD transferred $262 million in November 2006 from the 

DWWCF to the Air Force Working Capital Fund to cover increased 

fiscal year 2006 Air Force fuel costs.

• Third, DLA monthly cash balances declined during the first 4 months 

of fiscal year 2007 because of financial systems issues affecting 

collections when certain DLA activities transitioned to another 

financial system.

• Fourth, in fiscal year 2008, DLA disbursed about $1.3 billion more for, 

among other things, the purchase, refinement, transportation, and 

storage of fuel than it collected for the sale of fuel to its customers 

because of higher fuel costs.

When DWWCF monthly cash balances are below the lower cash 

requirements for long periods, the DWWCF is at greater risk of either 

(1) not paying its bills on time or (2) or making a disbursement in excess 

of available cash, which would potentially constitute an Antideficiency Act 

violation.

Fiscal Years 2007 through 

2009: DWWCF-Reported 

Cash Balances Were 

Below the Lower Cash 

Requirement for 19 

Months
Page 15 GAO-17-465 Defense-wide Working Capital Fund

The DWWCF reported monthly cash balances increased from about 

$1.5 billion at the beginning of fiscal year 2010 (October 1, 2009) to 

$3 billion at the end of fiscal year 2010—about $1.5 billion more than the 

beginning balance and $1.1 billion above the upper cash requirement. 

The reported monthly cash balance remained high for most of the next 2 

fiscal years, with an average monthly cash balance of $3.1 billion. During 

the 3-year period, the monthly cash balances were above the upper cash 

requirement for 29 of the 36 months, as shown in table 1. All 29 months 

were consecutive.

According to DLA officials and our analysis of financial documentation, 

the monthly cash balances were above the upper cash requirement for 

four primary reasons.

• First, DWWCF monthly cash balances increased when the DWWCF 

received $1.4 billion in appropriations from fiscal year 2010 through 

fiscal year 2012 to pay mostly for, among other things, combat fuel 

losses and fuel transportation charges associated with operations in 

Iraq and Afghanistan.

• Second, in fiscal year 2010, DLA Energy Management charged its 

customers more per barrel of fuel than it cost to purchase, refine, 

transport, and store the product (among other things), causing an 

increase in cash of approximately $659 million.

• Third, DLA Supply Chain Management collected more from the sale of 

inventory to its customers than it disbursed for the purchase of 

inventory from its suppliers in the second half of fiscal year 2010, 

resulting in a $296 million increase in cash.

• Fourth, in June 2012, DOD transferred $1 billion into the DWWCF 

from the Afghanistan Security Forces Fund (a onetime infusion of 

cash) to compensate for the reduced price that DLA Energy 

Management was charging its customers for fuel.

Fiscal Years 2010 through 

2012: DWWCF-Reported 

Cash Balances Were 

Above the Upper Cash 

Requirement for 29 

Consecutive Months 

Beginning in March 2010
Page 16 GAO-17-465 Defense-wide Working Capital Fund

DWWCF monthly cash balances were below the lower cash requirement 

three times in the beginning of fiscal year 2013 before ending the fiscal 

year at a level above the upper cash requirement. During fiscal year 

2013, the DWWCF monthly cash balances were outside the cash 

requirements for 7 of 12 months, as shown in table 1. There was a wide 

range in the reported monthly cash balances, from a low of $929 million in 

January 2013 to a high of $2.8 billion in June 2013.

According to DLA officials and our analysis of financial documentation, 

the monthly cash balances were below the cash requirements in 

November 2012, January 2013, and February 2013 for two primary 

reasons.

• First, in the first 5 months of fiscal year 2013, DLA Energy 

Management disbursed $588 million more to purchase, refine, 

transport, and store fuel than it was paid from its customers for the 

sale of fuel.

• Second, DLA Supply Chain Management disbursed $280 million more 

for the purchase of inventory than it collected from the sale of 

inventory to its customers in the first 5 months of fiscal year 2013.

On the other hand, the monthly cash balances were above the cash 

requirement for the last 4 months of fiscal year 2013 because funds were 

transferred into the DWWCF in June and September 2013. Specifically, 

DOD transferred $1.4 billion into the DWWCF from various defense 

appropriations accounts to mitigate cash shortfalls that resulted from DLA 

Energy Management paying higher costs for refined fuel products.

DWWCF monthly cash balances were above the upper cash 

requirements for 25 of 36 months from fiscal years 2014 through 2016. 

During the 3-year period, the reported monthly cash balances averaged 

$2.9 billion, reaching a high point of $4.7 billion in May 2016—about 

$1.9 billion above the upper cash requirement. Furthermore, the monthly 

cash balances remained above the upper cash requirement for 15 

consecutive months, from April 2015 through June 2016.

According to DLA officials and our analysis of financial documentation, 

the monthly cash balances were above the upper cash requirement for 

three primary reasons.

Fiscal Year 2013: 

DWWCF-Reported 

Monthly Cash Balances 

Were Below the Lower 

Cash Requirement Three 

Times Before Ending the 

Fiscal Year Above the 

Upper Cash Requirement

Fiscal Years 2014 through 

2016: DWWCF-Reported 

Cash Balances Were 

Above the Upper Cash 

Requirement for 25 

Months
Page 17 GAO-17-465 Defense-wide Working Capital Fund

• First, the DWWCF cash balance at the beginning of fiscal year 2014 

was above the upper cash requirement because of the $1.4 billion 

transferred into the fund during the last 4 months of fiscal year 2013.

• Second, in fiscal year 2015, DLA Energy Management’s price for the 

sale of fuel to its customers was considerably more than the cost to 

purchase, refine, transport, and store fuel. As a result, DLA Energy 

Management collected about $3.7 billion more than it disbursed for 

fuel during the year.14

• Third, in fiscal year 2016, DLA Energy Management continued to 

charge its customers more for fuel than it cost.

 14DLA officials informed us that DOD lowered the standard fuel price in February 2015 

from $155.40 a barrel to $136.92 a barrel—a difference of $18.48 per barrel of fuel. Even 

though DOD lowered the standard fuel price, the DWWCF monthly cash balance 

continued to remain high for the last 6 months of fiscal year 2015 because of lower fuel 

costs.
Page 18 GAO-17-465 Defense-wide Working Capital Fund

Initially, the DWWCF monthly cash plan that supports the fiscal year 2017 

President’s Budget, dated February 2016, showed the monthly cash 

balances were projected to be above the upper cash requirement for 

most of fiscal year 2017. However, after the DWWCF revised its fiscal 

year 2017 cash plan in October 2016, cash balances were projected to be 

within the upper and lower cash requirement for all 12 months, in 

accordance with the DOD Financial Management Regulation.

According to DOD officials, the DWWCF changed its plan after the 

President’s Budget was issued because (1) DOD made unplanned cash 

transfers out of the DWWCF in the second half of fiscal year 2016 and 

(2) DOD reduced the fiscal year 2017 standard fuel price in September 

2016, leading to lower projected cash balances. Figure 2 shows the 

DWWCF’s initial cash plan under the President’s Budget and the revised 

monthly cash plans compared to the upper and lower cash requirements 

for fiscal year 2017.

The DWWCF’s 

Revised Monthly 

Cash Balances Are 

Projected to Be within 

the Upper and Lower 

Cash Requirements 

for Fiscal Year 2017
Page 19 GAO-17-465 Defense-wide Working Capital Fund

Figure 2: President’s Budget and Revised Defense-wide Working Capital Fund Monthly Cash Plans Compared to the Upper 

and Lower Cash Requirements for Fiscal Year 2017

As shown in figure 2, the DWWCF’s revised cash plan for fiscal year 2017 

shows that the cash balance at the end of fiscal year 2016 (September 

2016) was about $1.1 billion lower than the President’s Budget cash plan. 

According to DOD officials and our review of documentation on transfers, 

this decrease was largely due to DOD’s transfer of about $2 billion out of 

the DWWCF in the second half of fiscal year 2016, which occurred after 

the fiscal year 2017 President’s Budget cash plan was submitted in 

February 2016.15 The $2 billion of DWWCF cash was transferred to other 

DOD appropriations accounts to pay for, among other things, unforeseen 

military requirements to maintain a larger troop presence in Afghanistan 

 15The DWWCF fiscal year 2016 year-end cash balance contained in the revised cash plan 

did not decline by a total of $2 billion over the President’s Budget cash plan because the 

DWWCF collected about $907 million more than it disbursed compared to the President’s 

Budget cash plan. 
Page 20 GAO-17-465 Defense-wide Working Capital Fund

than that planned for in the President’s Budget and funding shortfalls in 

fuels, consumable inventory items, repair parts, and medical supplies and 

services.

The DWWCF monthly cash balances under the revised cash plan are 

projected to remain within the upper and lower cash requirements for all 

12 months in fiscal year 2017. This is a significant change from the 

President’s Budget cash plan that showed the DWWCF monthly cash 

balances exceeding the upper cash requirement for 9 of the 12 months. 

Another factor that contributed to the improved results reflected in the 

revised plan is that the OUSD (Comptroller) lowered the standard fuel 

price in September 2016 from $105.00 per barrel to $94.92—a $10.08 

difference. DOD lowered the standard fuel price for refined petroleum 

products because the fiscal year 2017 costs for those products were 

expected to remain lower than initially projected when the fiscal year 2017 

President’s Budget was developed. In connection with its decision to 

lower fuel prices, DOD stated that the lower refined product costs have 

had a positive impact on the DWWCF cash balance (i.e., higher cash 

balances), and the department anticipated an associated congressional 

reduction as a result of the positive cash balance. Thus, DOD reduced 

the fiscal year 2017 standard fuel price effective October 1, 2016.

In November 2016, DLA officials informed us that several factors could 

nevertheless cause the DWWCF monthly cash balances to fall outside 

the upper and lower cash requirements in fiscal year 2017. These factors 

could include (1) higher or lower fuel product costs than expected, 

(2) higher or lower customer sales than expected, (3) the timing of vendor 

payments on a daily basis versus collections from customers on a weekly 

or monthly basis, and (4) nonpayment from customers for goods or 

services provided to them. While DWWCF officials stated that these 

factors could affect whether the DWWCF monthly cash balances are 

within the cash requirements for all 12 months in fiscal year 2017, the 

officials believe that the cash balances will remain within the cash 

requirements for the entire period.

The DWWCF supports military readiness by providing energy solutions, 

inventory management, information system solutions, and financial 

services for DOD in times of peace and war. Maintaining the DWWCF 

cash balance within the upper and lower cash requirements as defined by 

DOD regulation is critical for the DWWCF to continue providing these 

services for its customers. During fiscal years 2007 through 2016, DOD 

transferred a total of $9 billion into and out of the DWWCF and adjusted 

Conclusions
Page 21 GAO-17-465 Defense-wide Working Capital Fund

fuel prices 16 times outside of the normal budget process to try to bring 

the cash balances within the cash requirements. However, the cash 

balances were outside the upper and lower cash requirements almost 

three quarters of that time and for more than a year on three separate 

occasions.

Although the DOD Financial Management Regulation provides guidance 

on tools DOD managers can use to help bring the monthly cash balances 

within the upper and lower cash requirements, the regulation does not 

provide guidance on the timing of when DWWCF managers should use 

these tools to help ensure that the monthly cash balances are within the 

cash requirements. Without this guidance, DOD risks not taking prompt 

action in response to changes in fuel costs, inventory costs, 

appropriations, or other events to bring the monthly cash balances within 

the cash requirements. When DWWCF monthly cash balances are below 

the lower cash requirements for long periods of time, the DWWCF is at 

greater risk of either (1) not paying its bills on time or (2) making a 

disbursement in excess of available cash, which would potentially result 

in an Antideficiency Act violation. In cases of cash balances above the 

upper requirement, the DWWCF may restrict funds that could be used for 

other higher priorities.

We recommend that the Secretary of Defense direct the Office of the 

Under Secretary of Defense (Comptroller) to provide guidance in the 

DOD Financial Management Regulation on the timing of when DOD 

managers should use available tools to help ensure that monthly cash 

balances are within the upper and lower cash requirements.

Recommendation for 

Executive Action
Page 22 GAO-17-465 Defense-wide Working Capital Fund

We provided a draft of this report to DOD for comment. In its written 

comments, which are reprinted in appendix II, DOD concurred with our

recommendation and stated that it plans to update the DOD Financial 

Management Regulation as we recommended to provide additional 

guidance on the timing of when DOD managers should use available 

tools to help ensure that monthly cash balances are within the upper and 

lower cash requirements. DOD also stated that this change will be 

incorporated for the fiscal year 2019 President’s Budget submission and 

subsequent budgets. DOD also provided a technical comment, which we

incorporated as appropriate.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, the Under Secretary of Defense 

(Comptroller), and the Directors of the Defense Logistics Agency, the 

Defense Finance and Accounting Service, and the Defense Information 

Systems Agency. In addition, the report is available at no charge on the 

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

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

contact me at (202) 512-9869 or khana@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix III.

Asif A. Khan

Director

Financial Management and Assurance

Agency Comments
Appendix I: Scope and Methodology

Page 23 GAO-17-465 Defense-wide Working Capital Fund

To determine to what extent the Defense-wide Working Capital Fund’s 

(DWWCF) reported monthly cash balances were within the Department of 

Defense’s (DOD) upper and lower cash requirements from fiscal years 

2007 through 2016, we (1) obtained the DWWCF’s reported monthly cash 

balances for fiscal years 2007 through 2016, (2) used the DOD Financial 

Management Regulation that was in effect at that time to determine the 

upper and lower cash requirements, and (3) compared the upper and 

lower cash requirements to the month-ending reported cash balances. If 

the cash balances were not within the upper and lower requirement 

amounts, we met with the Defense Logistics Agency (DLA), the Defense 

Information Systems Agency (DISA), and the Defense Finance and 

Accounting Service (DFAS) officials and reviewed DWWCF budgets and 

other documentation to ascertain the reasons. We also identified 

instances in which monthly cash balances were outside the upper and 

lower cash requirements for 12 consecutive months or more to assess 

the timeliness of DOD actions to bring them within the upper and lower 

cash requirements. We selected the 12-month period for comparing the 

monthly cash balances to the cash requirements because (1) DOD 

develops a budget every 12 months; (2) the DWWCF annual budget 

projects fiscal year-end cash balances and the upper and lower cash 

requirements based on 12-month cash plans that include information on 

projected monthly cash balances, and whether those projected monthly 

cash balances fall within the cash requirements; and (3) DOD revises the 

DWWCF stabilized prices that it charges customers for goods and 

services every 12 months during the budget process.

In addition, we performed a walk-through of DFAS processes for 

reconciling the Department of the Treasury trial balance monthly cash 

amounts for the DWWCF to the balances reported on the DWWCF cash 

management reports. Further, to determine the extent cash transfers for 

fiscal years 2007 through 2016 contributed to the DWWCF cash balances 

being above or below the cash requirements, we (1) analyzed DOD 

budget and accounting reports to determine the dollar amount of transfers 

made for the period and (2) obtained journal vouchers from DFAS that 

documented the dollar amounts of the cash transfers. We analyzed cash 

transfers to determine if any of the transfers contributed to the cash 

balances falling outside the upper or lower cash requirements and, if so, 

the amount outside those requirements. We also obtained and analyzed 

documents that provide information on transfer of funds into and out of 

the DWWCF and interviewed key DLA, DISA, and DFAS officials to 

determine the reasons for the transfers.

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 24 GAO-17-465 Defense-wide Working Capital Fund

To determine to what extent the DWWCF’s projected monthly cash 

balances were within the upper and lower cash requirements for fiscal 

year 2017, we obtained and analyzed DWWCF budget documents and 

cash management plans for fiscal year 2017. We compared the upper 

and lower cash requirements to the month-ending projected cash 

balances. If the projected monthly cash balances were above or below 

the cash requirement, we discussed these balances with DLA officials to 

ascertain the reasons.

We obtained the DWWCF financial data in this report from budget 

documents and accounting reports. To assess the reliability of these data, 

we (1) obtained the DOD regulation on calculating the upper and lower 

cash requirements; (2) reviewed DLA’s calculations of the cash 

requirements to determine if they were calculated in accordance with 

DOD regulations; (3) interviewed DLA, DISA, and DFAS officials 

knowledgeable about the cash data; (4) compared DWWCF cash balance 

information (including collections and disbursements) contained in 

different reports to ensure that the data reconciled; (5) obtained an 

understanding of the process DFAS used to reconcile DWWCF cash 

balances with the Department of the Treasury records; and (6) obtained 

and analyzed documentation supporting the amount of funds transferred 

in and out of the DWWCF. On the basis of these procedures, we have 

concluded that these data were sufficiently reliable for the purposes of 

this report. We performed our work at the headquarters of the Office of 

the Under Secretary of Defense (Comptroller), Washington, D.C.; DLA, 

Fort Belvoir, Virginia; DISA, Columbus, Ohio; and DFAS, Indianapolis, 

Indiana.

We conducted this performance audit from June 2016 to June 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Defense

Page 25 GAO-17-465 Defense-wide Working Capital Fund

Appendix II: Comments from the Department 

of Defense
Appendix II: Comments from the Department 

of Defense

Page 26 GAO-17-465 Defense-wide Working Capital Fund
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 27 GAO-17-465 Defense-wide Working Capital Fund

Asif A. Khan, (202) 512-9869 or khana@gao.gov

In addition to the contact named above, Greg Pugnetti (Assistant 

Director), John Craig, Steve Donahue, and Keith McDaniel made key 

contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100965)
The Government Accountability Office, the audit, evaluation, and investigative 

arm of Congress, exists to support Congress in meeting its constitutional 

responsibilities and to help improve the performance and accountability of the 

federal government for the American people. GAO examines the use of public 

funds; evaluates federal programs and policies; and provides analyses, 

recommendations, and other assistance to help Congress make informed 

oversight, policy, and funding decisions. GAO’s commitment to good government 

is reflected in its core values of accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no cost is 

through GAO’s website (http://www.gao.gov). Each weekday afternoon, GAO 

posts on its website newly released reports, testimony, and correspondence. To 

have GAO e-mail you a list of newly posted products, go to http://www.gao.gov

and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of production and 

distribution and depends on the number of pages in the publication and whether 

the publication is printed in color or black and white. Pricing and ordering 

information is posted on GAO’s website, http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, MasterCard, 

Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, LinkedIn, Twitter, and YouTube.

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.

Visit GAO on the web at www.gao.gov and read The Watchblog.

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-4400, 

U.S. Government Accountability Office, 441 G Street NW, Room 7125, 

Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

James-Christian Blockwood, Managing Director, spel@gao.gov, (202) 512-4707

U.S. Government Accountability Office, 441 G Street NW, Room 7814, 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Strategic Planning and 

External Liaison

Please Print on Recycled Paper.