United States Government Accountability Office

GAO Report to the Chairman, Subcommittee 

on Interstate Commerce, Trade, and 

Tourism, Committee on Commerce, 

Science, and Transportation, U.S. 

Senate 

ECONOMIC 

DEVELOPMENT 

Formal Monitoring 

Approaches Needed to 

Help Ensure 

Compliance with 

Restrictions on 

Funding Employer 

Relocations 

September 2007 

 

GAO-07-1005 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2007

ECONOMIC DEVELOPMENT 

Formal Monitoring Approaches Needed to 

Help Ensure Compliance with 

Restrictions on Funding Employer 

Relocations 

Highlights of GAO-07-1005, a report to the 

Chairman, Subcommittee on Interstate

Commerce, Trade, and Tourism, 

Committee on Commerce, Science, and 

Transportation, U.S. Senate 

Congress imposed restrictions on

some federal programs to prevent

funding of business relocations. 

You expressed concerns about 

state and local governments using 

federal funds to attract jobs to one 

community at a loss of jobs to

another and about compliance with 

relocation restrictions. This report 

(1) identifies large federal 

economic development programs 

that state and local governments 

can use as incentives, (2) identifies 

which programs contain statutory 

prohibitions on funding 

relocations, and (3) assesses 

whether federal agencies had 

established and implemented 

procedures to help ensure

compliance with prohibitions. To

address these objectives, GAO 

searched federal databases, 

reviewed relevant statutes and

regulations, and conducted limited

testing of agency procedures. 

What GAO Recommends

To improve the management of 

federal economic development

grant programs, GAO recommends 

that the Departments of Labor, 

Agriculture, and Housing and 

Urban Development develop (or 

finalize the development of) and 

implement formal and structured

approaches to monitor compliance.

The Departments of Labor and 

Agriculture concurred with the 

recommendation and reported 

taking steps to implement it. Each 

of the three agencies provided

technical comments that were

incorporated into the report as 

appropriate. 

GAO identified 17 large federal economic development programs that offer 

financial assistance and services that state and local governments can use as 

incentives to attract and retain jobs. While academic studies indicate that it 

is difficult to quantify the funds used as incentives, particularly given 

differing definitions of incentives, the use of federal funds for such purposes 

appears to be more limited than the use of state and local funds. Although 

academic studies question the overall role and significance of incentives in 

firms’ decisions to (re)locate, researchers with whom GAO spoke noted that 

incentives could influence firms that already had narrowed their choices. 

Nine of the 17 large federal economic development programs restrict the use 

of program funds to support employer relocation. Seven are grant programs, 

and two are loan guarantee programs. In many grant programs, initial

recipients of funds (states and local governments) provide funds to others 

(e.g., businesses) to facilitate economic development; in loan guarantee 

programs, third-party lenders approve businesses for eligibility to receive 

funds. All nine programs prohibit using federal funds to support a business 

relocation that causes unemployment, but the thresholds for job loss differ. 

For example, a single lost job would trigger the provision for six programs, 

but for the other three programs, the job loss threshold is higher. 

Federal agencies administering the nine programs with a nonrelocation 

provision used various procedures, including screening applicants and 

monitoring recipients, to help ensure compliance, but the extent to which 

these procedures specifically addressed nonrelocation provisions was 

limited. The two loan guarantee programs emphasized screening procedures 

to help ensure compliance, and both programs had written guidance and 

other mechanisms that specifically addressed nonrelocation provisions. 

Screening may be effective for helping to ensure compliance in loan 

guarantee programs because federal agencies know at the time of initial 

application which businesses are requesting funds and how they plan to use 

them. In contrast, because of the way grant programs are structured, at the 

time of initial application, grant applicants do not always know which 

businesses later will apply for or receive assistance. As a result, officials 

administering grant programs relied more extensively on monitoring than 

screening to help identify instances of potential noncompliance. Despite this 

greater reliance on monitoring, only one of the grant programs GAO 

reviewed had written monitoring guidance that specifically addressed 

business relocation restrictions. Without formal policies and procedures, 

federal agencies have limited assurance that grant recipients and

subrecipients are complying with statutory requirements that restrict the use

of program funds to support employer relocations. 

www.gao.gov/cgi-bin/getrpt?GAO-07-1005.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact William B. 

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

Letter 1

Results in Brief 3

Background 6

State and Local Governments Can Use a Variety of Large Federal 

Programs to Attract Businesses 8 

Nine Large Federal Economic Development Programs Have 

Nonrelocation Provisions, but Requirements Vary 14 

Extent to Which Federal Agencies Had Established and 

Implemented Procedures to Help Ensure Compliance with 

Nonrelocation Provisions Was Limited 19 

Conclusions 29

Recommendations for Executive Action 31 

Agency Comments and Our Evaluation 32 

Appendix I Scope and Methodology 34 

Appendix II Description of the Nine Large Federal Economic 

Development Programs with Nonrelocation 

Provisions 37 

HUD CDBG Entitlement and State Programs 37 

HUD and USDA EZ/EC Programs 40 

Labor WIA Adult, Dislocated Workers, and Youth Programs 42 

SBA 504 Loan Program 44 

USDA B&I Program 44 

Appendix III Comments from the Department of Labor 46 

Appendix IV GAO Contact and Staff Acknowledgments 48 

Tables 

Table 1: Description of 17 Large Federal Economic Development 

Programs That Offer Financial Assistance or Services That 

Can Be Used as Business Incentives 9 

Page i GAO-07-1005 Restricting Federal Funds for Employer Relocation
Table 2: Job Loss and Other Statutory or Regulatory Requirements 

for Nine Large Federal Economic Development Programs 

with Nonrelocation Provisions 15 

Table 3: Timeline Showing Congressional Approval of 

Nonrelocation Provisions for Nine Large Federal Programs 18 

Table 4: Federal Agency Mechanisms to Screen for Compliance 

with Nonrelocation Provisions 20 

Table 5: Status of Federal Agency Mechanisms for Monitoring

Compliance with Nonrelocation Provisions, as of July 2007 26 

Figures 

Figure 1: Overview of CDBG Funding Streams for Economic 

Development Projects Involving Businesses 39 

Figure 2: Overview of EZ/EC Funding Streams for Economic 

Development Projects Involving Businesses 41 

Figure 3: Overview of WIA Adult, Dislocated Workers, and Youth 

Funding Streams 43 

Page ii GAO-07-1005 Restricting Federal Funds for Employer Relocation
Abbreviations 

BLS Bureau of Labor Statistics 

B&I Business and Industry Guaranteed Loan program 

CBO Congressional Budget Office 

CDC certified development company 

CDBG Community Development Block Grant 

CFDA Catalogue of Federal Domestic Assistance 

CRS Congressional Research Service 

EDA Economic Development Administration 

EC Enterprise Community 

EZ Empowerment Zone 

EZ/EC Empowerment Zone/Enterprise Community 

GSA General Services Administration 

HHS Department of Heath and Human Services 

HUD Department of Housing and Urban Development 

IRS Internal Revenue Service 

NETS National Establishment Time Series 

SBA Small Business Administration 

USDA U.S. Department of Agriculture 

WIA Workforce Investment Act 

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Page iii GAO-07-1005 Restricting Federal Funds for Employer Relocation
United States Government Accountability Office

Washington, DC 20548 

September 10, 2007 

The Honorable Byron L. Dorgan 

Chairman 

Subcommittee on Interstate Commerce, 

 Trade, and Tourism 

Committee on Commerce, Science, and 

 Transportation 

United States Senate 

Dear Mr. Chairman: 

State and local governments are estimated to spend billions of dollars 

annually in business incentives—financial assistance, tax concessions, and 

other benefits—in an effort to attract and retain jobs. State and local 

governments can directly or indirectly use funds and program services 

from a variety of federal, state, and local programs to induce individual 

businesses to relocate, expand, or maintain their operations in a state or 

community’s jurisdiction. In response to concerns about state and local 

governments using federal funds to attract jobs to one U.S. community at a 

loss of jobs to another community, Congress began to impose restrictions 

in the 1950s on some federal programs to prevent funds from being used to 

relocate businesses. 

In 1997, we provided an overview of eight major federal programs that 

states and localities used at that time for economic development 

purposes.1

 However, relatively little is known about how many other 

federal economic development programs state and local governments 

currently use as incentives to attract employers or about the extent to 

which restrictions exist against using funds to support an employer’s 

relocation. You noted that in recent years the controversy about the costs 

 1

GAO, Economic Development Activities: Overview of Eight Federal Programs, 

GAO/RCED-97-193 (Washington, D.C.: Aug. 28, 1997). In the absence of a standard federal 

definition to describe economic development, for this 2007 report we used a list of 

activities from another GAO report, Rural Economic Development: More Assurance is

Needed That Grant Funding Information Is Accurately Reported, GAO-06-294 

(Washington, D.C.: Feb. 24, 2006). Thus, economic development as we define it includes the 

construction and repair of infrastructure, such as buildings and roads; direct financial 

support and technical assistance to businesses, including job-training assistance; and tax 

expenditure programs that support these activities. 

Page 1 GAO-07-1005 Restricting Federal Funds for Employer Relocation
and benefits of using limited government funds to recruit businesses has 

been growing and expressed concerns about efforts to help ensure 

compliance with restrictions on the use of federal funds. The objectives of 

this report are to (1) identify large federal economic development 

programs that state and local governments can use as incentives to 

businesses for attracting new jobs into their jurisdictions, (2) identify 

which of these programs contain statutory prohibitions on using program 

funds to relocate businesses, and (3) assess whether federal agencies had 

established and implemented procedures to help ensure compliance with 

these provisions. 

To identify large federal economic development programs that state and 

local governments can use in incentive packages for businesses, we 

searched the General Services Administration’s (GSA) online Catalog of 

Federal Domestic Assistance (CFDA) for economic development 

programs that CFDA reported as having budget obligations of at least $500 

million.2

 We also searched the Congressional Research Service’s (CRS) 

2006 Tax Expenditure Compendium for economic development tax 

expenditure programs with reported estimated tax revenue losses of $500 

million or more for fiscal year 2006.3

 We then narrowed the list according

to criteria that enabled us to identify the largest programs most likely to be

candidates as a business incentive. Further, we reviewed the Web sites for 

each of the 50 states’ economic development agencies to identify federal 

programs typically marketed as business incentives. To identify the 

programs with nonrelocation provisions, we reviewed relevant statutes 

and regulations and focused on those programs that we identified as the 

largest based on our review of CFDA and the CRS Tax Expenditure 

Compendium. To assess the completeness of our search results, we 

interviewed representatives of selected federal agencies, economic 

development trade associations, and policy groups. To assess the extent to

which federal agencies had procedures in place to help ensure compliance 

 2

The General Services Administration and Office of Management and Budget maintain the

CFDA database, which lists federal programs available to state and local governments 

(including the District of Columbia); federally recognized Indian tribal governments; 

territories (and possessions) of the United States; domestic public, quasi public, and 

private for-profit and nonprofit organizations and institutions; specialized groups; and 

individuals. See appendix I for more information on CFDA and how we used it in this

report. 

3

The Tax Expenditure Compendium is a biennial publication that provides CRS estimates 

of revenue costs of individual tax provisions for the U.S. Senate’s Committee on the

Budget. We used the 2006 Report (CRS, 109th Congr., 2nd sess.; S. Prt. 109-072). 

Page 2 GAO-07-1005 Restricting Federal Funds for Employer Relocation
with nonrelocation provisions, we obtained documents from federal 

agencies that described the procedures for helping to ensure compliance 

and then conducted limited testing of these procedures (typically a 

nongeneralizable sample of 10 cases for each program) to determine their 

implementation. We did not conduct an overall evaluation of the 

programs, evaluate how well the programs served their intended purposes, 

or evaluate how nonrelocation provisions affect the relative success of the 

programs in achieving their intended purposes. We also did not address 

the impact these programs had on development efforts by state and local

governments. We interviewed representatives of six federal agencies—

Department of Labor (Labor), Department of Housing and Urban 

Development (HUD), Department of Agriculture (USDA), Small Business 

Administration (SBA), the Department of Commerce’s Economic 

Development Administration (EDA), and the Department of the Treasury’s 

Internal Revenue Service (IRS). In addition, we interviewed academics, 

researchers, representatives of economic development trade groups, and 

consultants that businesses hire to identify and select new business 

locations (site-selection consultants). We conducted our work in 

Washington, D.C., and San Francisco and Fresno, California, from October 

2006 through August 2007 in accordance with generally accepted 

government auditing standards. Appendix I provides a more detailed 

description of our scope and methodology. 

We identified 17 large federal economic development programs that state 

and local governments can use to attract and retain jobs. The 17 

programs—which include grants, direct loans and loan guarantees, and tax 

incentives for job training, infrastructure development, and business 

financing—are administered by five agencies—HUD, Labor, USDA, SBA, 

and IRS. State and local governments could combine federal economic 

development funds from various programs with their own resources to 

attract businesses. Based on our review of state economic development 

Web sites, the programs that appear to be marketed more than others 

were HUD’s Community Development Block Grant (CDBG), SBA’s 7(a) 

and 504 loan guarantee programs, and IRS’s tax-exempt private activity 

bond programs (at least 19 states advertised each of these as incentives). 

The results of our state Web site reviews were largely consistent with the 

comments of the site-selection consultants with whom we spoke. While 

academic studies indicate that differing definitions of incentives and the

ability to interchange funds at the state and local level make it difficult to 

quantify the amount of federal, state, and local funds spent on business 

incentives, the use of federal funds as incentives appears to be more 

limited than the use of state and local funds. However, state and local 

Results in Brief 

Page 3 GAO-07-1005 Restricting Federal Funds for Employer Relocation
governments could use federal economic development funds to attract 

additional investment or to free up their own funds for other purposes. 

Academic researchers with whom we spoke estimated that state and local 

governments spend from $20 billion to $50 billion annually on business 

incentives, mostly in the form of tax incentives, such as property and sales 

tax abatements. But the discretion that state and local governments have 

over the use of federal economic development funds varies. For some 

programs, such as SBA’s 7(a) and 504 programs, third-party lenders and 

nonprofit development corporations make funding decisions. Others, such 

as Labor’s Workforce Investment Act (WIA) and industrial development 

bond programs, provide state and local governments with more control 

over how to allocate resources to businesses. Finally, academic studies we 

reviewed questioned the importance of business incentives in firms’ 

decisions to relocate, but according to the studies we reviewed and 

consultants with whom we spoke, state and local incentives could 

influence relocation decisions after businesses already had narrowed their 

choices. 

Nine of the 17 programs that we identified prohibit using program funds to 

relocate a business if the move would cause unemployment in the original

location. They are the two HUD CDBG programs, three Labor WIA 

programs, a HUD Empowerment Zone (EZ) program, a USDA 

Empowerment Zone/Enterprise Community (EZ/EC) program, a USDA 

Business and Industry (B&I) Guaranteed Loan program, and SBA’s 504 

program (see app. II for a more detailed description of the nine programs). 

The first seven are grant programs in which a federal agency provides 

funds to recipients, such as state or local governments, that, in turn, may 

provide funds to other entities, which we refer to as subrecipients, to 

facilitate economic development.4

 The remaining two programs guarantee 

loans that third-party lenders and nonprofit development corporations 

make. All prohibit the funding of relocations that result in unemployment, 

but the amount of job loss that triggers the nonrelocation provision differs 

by program. For example, in six programs, a single loss would trigger the 

provision, but in the other three programs, higher thresholds trigger the 

provision. The three programs with higher thresholds also require 

applicants to exceed other thresholds before triggering the provision, such 

as requiring that relocations occur across defined geographic areas. For 

example, HUD’s CDBG program, consistent with its statutory requirement, 

prohibits funding for a business that relocates to a different labor market. 

 4

For purposes of this report, subrecipients include nonprofit organizations and businesses. 

Page 4 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Recently, USDA, for its B&I program, has requested but not obtained 

congressional removal of the nonrelocation provision, saying enforcement 

of the provision was not cost-effective given the few complaints received 

over the course of many years. 

Federal agencies administering the nine programs with nonrelocation 

provisions used various procedures, including screening applicants and 

monitoring recipients, to help ensure compliance, but the extent to which 

these procedures specifically addressed nonrelocation provisions was 

limited. The two loan guarantee programs—USDA’s B&I and SBA’s 504 

programs—emphasized screening procedures to help ensure compliance. 

For example, both programs had written guidance and other mechanisms 

that specifically addressed nonrelocation provisions. The emphasis on 

screening for loan guarantee programs seemed appropriate given the 

structure of these programs. While agencies administering the seven grant

programs with nonrelocation provisions also screened applicants, agency 

officials noted inherent limitations in using screening mechanisms for 

grant programs. For example, under grant programs, applicants (such as 

state and local governments) do not always know at the time they apply 

for funds which specific businesses later will seek and obtain assistance 

through the program. Because of the inherent limitations of screening 

procedures for grant programs, agencies administering grant programs 

primarily relied on monitoring to help identify instances of potential 

noncompliance. However, only one of the seven grant programs we 

reviewed—HUD’s EZ program—had developed written monitoring 

guidance specific to the nonrelocation provision. Officials at all agencies 

stated that they have received few or no complaints of noncompliance 

with nonrelocation provisions, and some officials said that they do not 

consider noncompliance to pose a significant risk to the programs. 

However, without structured guidance and procedures in place to monitor 

compliance, agencies have limited assurance that grant recipients and 

subrecipients are complying with statutory and regulatory requirements 

and spending funds on allowable activities. 

We are making recommendations in this report intended to provide Labor, 

USDA, and HUD with greater assurance that fund recipients and, where 

applicable, subrecipients are complying with nonrelocation provisions and 

spending federal economic development funds on allowable activities. We 

provided a draft of this report to Labor, USDA, HUD, SBA, Commerce, and 

IRS for review and comment. Labor provided written comments that are 

reprinted in appendix III. USDA’s Acting Assistant Deputy Administrator 

for Cooperative Programs provided oral comments on August 8, 2007. In

its written comments, Labor stated that the department concurred with 

Page 5 GAO-07-1005 Restricting Federal Funds for Employer Relocation
our recommendation and described actions to implement it. Specifically,

Labor said that the department is implementing two complementary 

strategies. First, Labor said that it is developing a formal policy guidance 

letter that will clarify allowable and unallowable uses of WIA funds for 

economic-development-related activities. This guidance will specifically 

address prohibitions related to the nonrelocation provision. Second, Labor 

said that its draft Formula Grant Supplement to its Core Monitoring 

Guide includes indicators of compliance along with each governor’s 

responsibility to determine which costs are allowable or unallowable 

under WIA, including prohibitions against using WIA funds to encourage 

business relocation and related restrictions. Labor stated that regional 

office reviewers have extensively tested the draft Formula Grant 

Supplement and that it expects the supplement to enter the final clearance 

process shortly and be completed by December 31, 2007. In oral comments 

on our report, USDA’s Acting Assistant Deputy Administrator for 

Cooperative Programs stated that USDA concurred with our 

recommendation and provided us with documentation showing that the 

department is taking initial steps to implement the recommendation. 

Labor, USDA, HUD, SBA, and IRS provided technical comments that we 

have incorporated in the report where appropriate. Commerce did not 

provide comments on the draft report. 

In 2000, the Council of State Governments reported that more than 40 

states offered tax and financial incentives to businesses for activities such 

as relocating, expanding, buying equipment, or creating and maintaining 

jobs. The use of incentives to attract and retain businesses has been an 

issue of debate for many years. Proponents maintain that economic 

development incentives are an effective means by which states and 

communities can compete for jobs. Opponents contend that the dollars 

spent to provide incentives would be better used to support activities 

believed to have more impact on a community’s economic development, 

such as improvements to infrastructure and investments in education to 

develop a competitive labor pool. 

Background 

While states and localities compete with one another to attract businesses, 

some states and localities have attempted to curtail the use of economic 

development funds to relocate jobs. According to two policy groups 

promoting accountability in economic development, three cities—Austin, 

Texas; Gary, Indiana; and Vacaville, California—and nine states—

Alabama, Connecticut, Florida, Iowa, Maryland, New Mexico, New York, 

Ohio, and Wisconsin—prohibit using city and state resources, respectively,

to relocate jobs within their boundaries. For example, both policy groups

Page 6 GAO-07-1005 Restricting Federal Funds for Employer Relocation
state that the Gary, Indiana, city ordinance prohibits tax abatements for 

the relocation of existing jobs from outside the corporate limits of the city. 

One of the groups also said that in Puerto Rico, the governor may refuse 

any business application for tax incentives if doing so would adversely 

affect the business’ employees in any state in the United States. Regional 

entities also have established formal and informal agreements to curtail 

the competition for businesses and jobs within their boundaries. These 

entities include the Metro Denver Economic Development Corporation; 

the tri-county region comprising Broward, Miami-Dade and Palm Beach

counties in Florida; and Contra Costa and Alameda counties in California.

In 2006, the total number of unemployed workers was 6.8 million in the 

fourth quarter, compared to 145.6 million employed. According to the 

Bureau of Labor Statistics (BLS), employers reported that a total of 

894,739 workers lost their jobs because of extended layoffs in 2006 that 

resulted from a variety of economic factors, such as bankruptcy and

reorganizations.5

 A BLS survey of employers found that 20,199 of these 

losses (about 2 percent) occurred because of business relocations within 

the United States, the majority across state lines. Another source—the 

National Establishment Time Series (NETS)—uses proprietary Dun & 

Bradstreet data on U.S. companies to track business relocations. 

According to a representative of the company that maintains the NETS 

data, more than 2.8 million businesses have relocated since 1990 and about 

100,000 of these (or almost 4 percent) occurred across state lines. 

A number of federal programs fund or support economic development 

activities. In prior work, we identified activities that are directly related to

economic development—planning economic development activities; 

constructing or renovating nonresidential buildings; establishing business 

incubators; constructing industrial parks; constructing and repairing roads 

and streets; and constructing water and sewer systems.6

 These programs 

typically are available to applicants that include individuals; local, state,

 5

BLS collects these data under its Mass Layoff Statistics program using each state’s 

unemployment insurance database. Extended mass layoff events consist of 50 or more

initial claims for unemployment insurance from an establishment during a 5-week period,

with at least 50 workers separated for more than 30 days. According to BLS, establishments

with at least 50 workers represented 4.6 percent of all U.S. establishments and 56.5 percent

of all U.S. workers in 2006. We consider the BLS data to be reliable based on our use of the 

data in prior reports. 

6

GAO, Economic Development; Multiple Federal Programs Fund Similar Economic

Development Activities, GAO/RCED/GGD-00-220 (Washington, D.C.: Sept. 29, 2000).

Page 7 GAO-07-1005 Restricting Federal Funds for Employer Relocation
territorial, and tribal governments; and nonprofit organizations through 

loans, loan guarantees, and project and formula grants. Appendix II 

provides a description of the nine federal economic development 

programs that we identified as having nonrelocation provisions, including 

information about program funding and how the programs operate. 

We identified 17 large federal programs that state and local governments 

can use to attract businesses. These programs offer assistance to 

businesses in the form of loans and loan guarantees, grants, job-training 

services, and tax benefits as incentives to businesses. Of the 17 economic 

development programs, states appear to have marketed 14 as incentives 

for businesses. However, according to academic experts who study 

economic development incentives and site-selection consultants, the 

amount of federal funds used as incentives is likely more limited than the 

amount of state and local funds used as incentives. State and local 

governments have varying discretion over the use of the federal funds, but 

can leverage federal funds to free their own resources for incentives or for 

other purposes that support businesses. Finally, academic studies on 

incentives and site-selection consultants have questioned whether 

incentives offered by state and local governments influence a business’ 

decision to relocate or expand operations. 

We identified 17 large federal economic development programs that state 

and local governments can use as incentives to attract and retain 

businesses, based on a search of the CFDA database, Tax Expenditure 

Compendium, and state economic development Web sites. As shown in 

table 1, five agencies administer the 17 programs, which offer a range of 

assistance or services (such as loans, grants, tax benefits, and training 

programs) to businesses. 

State and Local 

Governments Can Use 

a Variety of Large 

Federal Programs to 

Attract Businesses 

State and Local 

Governments Can Use 

Various Types of Federal 

Programs as Business 

Incentives 

Page 8 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Table 1: Description of 17 Large Federal Economic Development Programs That Offer Financial Assistance or Services That 

Can Be Used as Business Incentives 

Agency Program Program Description

HUD CDBG Entitlement Grants to large cities and urban counties to benefit the community development 

needs of low- and moderate-income people 

HUD CDBG State Grants to states to benefit the community development needs of low- and 

moderate-income people living in non-entitlement areas 

HUD EZ (urban) Grants, loans, and tax relief to federally designated urban areas to help them 

overcome economic and social problems 

HUD Renewal Communities Tax incentives and regulatory relief for federally designated urban and rural

areas to help them overcome economic and social problems 

IRS/TreasuryaNew Markets Tax Credit Tax credits for investments in qualified community development entities that 

make investments in designated low-income communities 

IRS Private activity bonds Tax incentives for construction of public airports, docks, and mass-commuting 

facilities 

IRS Private activity bonds Tax incentives for the construction of sewage, water, and hazardous waste 

facilities 

Labor WIA Adult Employment and training services to adults ages 18 years and over 

Labor WIA Dislocated Workers Employment and training services to dislocated workers 

Labor WIA Youth Employment and training services to economically disadvantaged youth ages 14 

to 21 possessing specific barriers to employment 

SBA Certified Development Company 

504 Loans 

Loans that development companies make and SBA guarantees, providing small 

businesses with proceeds to acquire or renovate fixed assets, including land, 

buildings, machinery, and equipment. This program does not cover working 

capital or refinancing. 

SBA 7(a) Loans Loan guarantees providing small businesses with proceeds to acquire land, 

buildings, machinery, equipment, furniture or fixtures, and funds to cover building 

renovation, leasehold expenses, working capital, and refinancing 

USDA EZ/EC (rural) Grants, loans, tax, and regulatory relief to federally designated rural areas to

help them overcome economic and social problems 

USDA B&I Guaranteed Loans Guaranteed loans to businesses for purchasing or improving land, facilities, 

equipment, and certain agricultural production projects 

USDA Community Facilities Loans and 

Grants 

Direct loans, loan guarantees and grants to rural communities to develop public 

facilities, including industrial park sites 

USDA Farm Ownership Loans Direct and guaranteed loans for purchase of family-size farms 

USDA Farm Operating Loans Direct and guaranteed loans for operation of family-size farms 

Sources: GAO, GSA, and CRS. 

a

IRS enforces compliance with relevant portions of the federal tax code for the New Markets Tax 

Credit program. The Department of the Treasury’s Community Development Institutions Fund awards

New Markets Tax Credit allocations to qualified community development entities. 

Page 9 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Out of the 17 programs we identified, 

• five were direct loan or loan guarantee programs: the SBA 7(a) and 504, 

USDA B&I, Farm Ownership Loans, and Farm Operating Loans; 

• four were tax incentive programs: IRS’s New Markets Tax Credit, its two 

private activity bond programs, and HUD’s Renewal Communities; 

• three were programs that support job training services: WIA Adult, 

Dislocated Workers, and Youth programs; and 

• five were programs that offer more than one type of financial assistance 

(grants, direct or guaranteed loans, or tax incentives): the two HUD CDBG

programs, HUD EZ, USDA EZ/EC, and USDA Community Facilities. 

State and local governments also can use federal economic development 

resources to supplement their existing resources to attract additional 

investment and potentially use federal economic development funds to 

free up money for incentives they otherwise would have spent on 

economic development.7

 For example, according to USDA officials, EZs 

and ECs often leverage federal program resources to obtain other funds, 

thereby attracting businesses. Similarly, businesses located in EZs and 

ECs can claim various state and federal tax credits, including IRS’s Work 

Opportunity Tax Credit, which provides tax credits to employers hiring 

individuals residing in an EZ or EC. According to our January 2007 report 

on the New Markets Tax Credit program, these credits can be packaged

with other types of incentives, such as EZ/EC incentives or state and local 

tax abatements, to make the investments in economically distressed 

communities more attractive to investors such as banks. We previously 

have reported that more than one-fourth of New Markets Tax Credit 

projects were located in federally designated EZs.8

 State and local 

governments also can use federal economic development funds to support 

 7

For additional information on the leveraging of federal economic development funds, see 

GAO, Leveraging Federal Funds for Housing, Community, and Economic Development, 

GAO-07-768R (Washington, D.C.: May 25, 2007). 

8

GAO, Tax Policy: New Markets Tax Credit Appears to Increase Investment by Investors

in Low-Income Communities, but Opportunities Exist to Better Monitor Compliance, 

GAO-07-296 (Washington, D.C.: Jan. 31, 2007). 

Page 10 GAO-07-1005 Restricting Federal Funds for Employer Relocation
economic development activities, thereby freeing up state and local funds 

for business incentives or other uses.9

Based on our review of state economic development Web sites, states 

appear to market all but 3 of the 17 programs (Community Facilities Loans 

and Grants, Farm Ownership Loans, and Farm Operating Loans being the 

exceptions). The programs that appear to be marketed more than others 

are the CDBG programs, SBA’s 7(a) and 504 loan guarantees, and private

activity bonds (at least 19 states appear to advertise each of these as 

incentives). Benefits from EZs, ECs, or Renewal Communities, and jobtraining programs funded with WIA funds were the next most marketed 

incentives, with at least nine states offering them. This appears to be 

somewhat consistent with what site-selection consultants told us about 

the specific federal incentives they see in business incentive packages. The 

consultants told us that they see CDBG loans funded with Entitlement and 

State block grants, private activity bonds, EZ/EC benefits and, 

increasingly, customized job-training funds in incentive packages. In 

contrast to the results of our Web site reviews, the consultants did not cite

SBA loans as being among federal resources included in business 

incentive packages.10

Although federal programs are marketed as business incentives, the 

amount of federal funds used as incentives appears to be more limited 

than the amount of state and local funds used. While the precise amount of 

federal funds used as incentives is not available, the Congressional Budget

Office (CBO) estimated that the federal government spent $27.9 billion to 

support commerce and business in addition to $2.2 billion on credit 

programs in 1995.

11 CBO also indicated that the federal government 

provides the bulk of its support to businesses through tax provisions. CBO 

estimated tax revenue losses of at least $32.2 billion for the provision of 

the tax code that yielded the largest amount of direct support for 

businesses—depreciation of capital assets in excess of the alternative 

deprecation system—but did not provide total estimates of foregone 

Use of Federal Funds as 

Business Incentives 

Appears to Be More 

Limited Than Use of State 

and Local Funds 

 9

GAO-07-768R. 

10At least 7 of the 50 state Web sites that we reviewed marketed SBA programs in the form

of links to federal Web sites rather than as direct incentives for businesses. 

11Congressional Budget Office, Federal Financial Support of Business (Washington, D.C:

July 1995). CBO has not updated this report since 1995. 

Page 11 GAO-07-1005 Restricting Federal Funds for Employer Relocation
revenue associated with all tax provisions.12 It is not clear from the CBO 

report whether and to what extent state and local governments also used 

these programs and tax provisions as incentives. We reviewed academic 

studies on economic development business incentives offered from 1995 

to 2005 and interviewed the authors of these studies. The academic 

literature on economic business incentives generally focuses on state and

local government incentives rather than federal incentives. Academic 

studies estimate that state and local governments spent from $20 to $50 

billion annually on business incentives.13 While the amount of federal funds 

used as business incentives has not been measured to any great extent, 

some researchers with whom we spoke said that the amount of federal 

funds used as business incentives is likely limited compared to the amount 

of state and local funds used as incentives.14

One limitation in developing estimates of federal, state, and local funds 

spent on incentives is defining what constitutes a business incentive. For 

example, a state or local government might offer indirect benefits, such as 

infrastructure improvements, to attract or retain businesses, but these 

might not be counted in estimates as business incentives.15 Moreover, 

although the amount of federal economic development funds available as 

incentives appears to be limited, money can be fungible, or freely 

interchangeable, at the state and local level. Thus, even though the amount 

of federal funds used as incentives might be limited, state and local 

governments could leverage those funds to free up their own resources for 

incentives or for other purposes that support businesses. 

 12CBO indicated that it is difficult to provide a total revenue loss estimate because the 

interactions between different provisions of the tax code do not equal the arithmetic sum 

of revenue losses from individual tax provisions. 

13Tim Bartik, “Evaluating the Impacts of Local Economic Development Policies on Local 

Economic Outcomes: What Has Been Done and What is Doable?” Upjohn Institute Staff 

Working Paper No. 03-89, prepared for the Organization for Economic Cooperation and

Development’s (OECD) Conference on “Evaluating Local Economic and Employment 

Development” (Kalamazoo, Mich.: The Upjohn Institute, November 2002); Kenneth 

Thomas, Competing for Capital: Europe and North America in a Global Era 

(Washington, D.C.: Georgetown University Press, 2000); and Peter Fisher and Alan Peters, 

“The Failure of Economic Development Incentives,” Journal of the American Planning 

Association 70, no. 1 (Chicago, Ill.: Winter, 2004).

14Bartik. 

15Thomas. 

Page 12 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Furthermore, state and local governments have less discretion over the 

use of federal resources than they do over their own, but the degree of 

discretion varies with the program. For at least four of the programs 

(SBA’s 7(a) and 504 loan programs, USDA’s B&I loan program, and IRS’s 

New Markets Tax Credit), state and local governments have no direct role

in funding decisions. For these programs, third-party lenders, development 

corporations, or the federal government decide which businesses receive

funds. In contrast, other programs provide states with more discretion 

over how they can use funds. For example, under WIA, states and local 

areas can use the discretionary and statutory funding from Labor to 

develop job training and employer service programs, including customized 

job training, which we previously have reported can be an important 

factor in a company’s decision to locate in a particular area.

16

Finally, the academic literature we reviewed questioned the importance of 

incentives in location or relocation decisions. These studies, as well as 

published articles in site selection industry magazines, indicate that other

considerations might outweigh economic development incentives when 

companies decide where to locate. The studies explained that the critical 

factors in deciding were more likely to be the size and education of the 

labor force; local infrastructure such as telecommunication lines; 

transportation options, such as access to ports, roads, and rail; and access 

to consumer markets. However, the studies and consultants acknowledged

that the incentives state and local governments offered could influence a 

business’ decision when the business already had narrowed its choice to 

three or four locations. 

 16GAO-03-884T.

Page 13 GAO-07-1005 Restricting Federal Funds for Employer Relocation
We determined that 9 of the 17 large federal economic development 

programs that state and local governments can use as business incentives

contain statutory prohibitions against using funds to relocate businesses if 

the relocation would cause unemployment.17 Seven of the federal 

economic development programs with nonrelocation provisions were 

grant programs, and the remaining two were loan guarantee programs. 

The number of job losses and other requirements needed to trigger the 

nonrelocation provision varied by program. Nonrelocation provisions for 

the nine programs were enacted over a 40-year period. Recently, one 

program has sought but not obtained congressional removal of its 

nonrelocation provision. 

Based on our review of laws and regulations for the 17 large federal 

economic development programs that state and local governments can use 

as business incentives, we determined that nine contain statutory 

prohibitions against using program funds to relocate businesses.18 (See 

app. II for a more detailed description of each of these nine programs.) 

They are the two HUD CDBG programs (Entitlement and State programs); 

the WIA Adult, Dislocated Workers, and Youth programs; USDA and 

HUD’s respective EZ/EC programs (for designated rural and urban 

communities, respectively); USDA’s B&I program; and SBA’s 504 program. 

SBA voluntarily applies a nonrelocation provision to its 7(a) program.19

Nine Large Federal 

Economic 

Development 

Programs Have 

Nonrelocation 

Provisions, but 

Requirements Vary 

Nine Large Federal 

Economic Development 

Programs Contain 

Statutory Nonrelocation 

Provisions 

 17We identified 21 additional federal programs with statutory nonrelocation provisions. We 

did not focus on these programs because they did not meet our minimum funding criteria 

of $500 million annually or did not meet our definition of economic development. 

18See appendix I for a more detailed description of our methodology for identifying the 

large economic development programs with statutory prohibitions against using program 

funds for employer relocation. 

19SBA voluntarily applies a nonrelocation provision to its 7(a) loan program, which 

provides assistance to small businesses to purchase land and buildings. 7(a) loans also

assist small businesses with support operations, such as payroll and inventory. SBA’s

standard operating procedures prohibit the approval of a 7(a) loan if it finances a move that 

would cause serious unemployment in the present location. However, SBA’s procedures 

permit financing the relocation of an applicant’s business when the relocation will 

accomplish a sound business purpose, such as preventing the business from closing. The

remaining seven programs—HUD’s Renewal Communities, IRS’s New Market Tax Credit 

and two private activity bonds, USDA’s Community Facilities Loans and Grants, USDA’s 

Farm Ownership Loans and USDA’s Farm Operating Loans—do not contain statutory 

restrictions on using program funds to relocate businesses. 

Page 14 GAO-07-1005 Restricting Federal Funds for Employer Relocation
All nine programs that we identified with statutory restrictions on 

employer relocations use job loss in a relocating company’s original 

location as the primary criterion for applying a nonrelocation provision, 

but the job loss threshold varies by program. As shown in table 2, the 

statutory language for three programs—HUD and USDA’s EZ/EC program 

and USDA’s B&I program—do not specify a job loss threshold, but these 

agencies interpret the job loss threshold as one job lost. The three WIA 

programs specify a job loss threshold of one job lost. The remaining 

three—HUD’s CDBG Entitlement and State programs and SBA’s 504 

program—have higher job loss thresholds. In addition to job loss, these 

three programs specify other conditions for applying a nonrelocation 

provision, such as requiring that the relocations occur across 

geographically defined areas. 

Table 2: Job Loss and Other Statutory or Regulatory Requirements for Nine Large Federal Economic Development Programs 

with Nonrelocation Provisions

Agency Program Job loss threshold Other requirements 

Exemptions from application of 

nonrelocation provision 

HUD CDBG Entitlement and 

State 

More than 25 jobs • Relationship between 

job loss and size of 

labor market in

originating employer’s 

area 

• Relocation occurs 

across different labor 

market areas (as 

defined by BLS)

• New operations of a business

that are unrelated to existing

operations, even if business 

decides to reduce or eliminate 

existing operations. 

• Nonprofit entities 

• Indirect assistance that benefits 

multiple businesses 

• Loss of 25 or fewer jobs 

• Microenterprises 

• Purchase of business equipment, 

etc. if purchase does not result in 

relocation of sellers’ operations

HUD EZ (urban) 1 jobaNone None 

Labor WIA Adult, Dislocated 

Workers, and Youth 

programs 

1 job None None 

SBA Certified Development

Company 504 Loans 

• One third workforce 

reduction within a 

company, or 

• substantial increase in

unemployment in any area

of the country 

None • Relocation is key to the economic 

well-being of the applicant 

• Benefits to applicant and 

receiving community outweigh 

negative impact to original 

community. 

USDA EZ/EC (rural) 1 jobaNone None

Page 15 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Agency Program Job loss threshold Other requirements 

Exemptions from application of 

nonrelocation provision 

USDA B&I Guaranteed Loans 1 joba None • Business applying for $1 million

or less of assistance, or 

• Business applying would 

increase direct employment by

less than 50 employees

b

Source: GAO analysis.

Note: For CDBG programs, see 42 USC 5305(h); for EZ/EC programs, see 26 USC 1391; for WIA 

programs, see 29 USC 2931(d); for SBA program, see 15 USC 661; and for B&I program, see 7 USC

1932. 

a

Neither the statutes nor the regulations for these programs specify a job loss threshold. However, 

agency officials stated that the job loss threshold is one lost job for these programs. 

b

Based on language contained in statute, 7 U.S.C. 1932(d)(2). The regulations for the B&I program 

differ from the statute in that businesses are exempt from the nonrelocation provision if they are 

applying for less than $1 million in assistance “and” ( as opposed to “or”) the business would increase

direct employment by less than 50 jobs. 7 C.F.R. 1980.412(c); 7 C.F.R. 4279.114(b). Loans that are 

not exempt from the nonrelocation provision require U.S. Department of Labor involvement in 

reviewing certain information about these loans. USDA officials said that they are currently

implementing the B&I program based on the program’s regulations. Thus, USDA sends to Labor only

those loans that are for at least $1 million and would increase direct employment by more than 50 

jobs. According to USDA officials, USDA is seeking to have the statutory language changed to make 

it more consistent with regulatory language. The officials stated that when the B&I statute was 

originally enacted in 1972, loans of $1 million and above were rare. Currently, according to USDA, if 

the agency were to send to Labor for review loans based solely on the amount ($1 million and 

above), Labor would have to review most B&I loans. 

HUD regulations for the CDBG Entitlement and State programs make 

business relocations ineligible for funding if they involve certain job 

losses. Any relocation involving the loss of 500 or more jobs is prohibited. 

In contrast, relocations involving the loss of 25 or fewer jobs are exempt 

from the nonrelocation provision. For relocations involving between 25 

and 500 jobs, the nonrelocation provision applies if the number of jobs lost 

equals or exceeds one-tenth of one percent of the number of employed 

persons in the labor market experiencing the loss.20 The CDBG program’s 

statute does not specify a job loss threshold; it only requires that the 

agency prohibit funding for business relocations that are likely to result in

a significant loss of employment. According to a HUD official, HUD chose 

to exempt any relocation involving 25 or fewer jobs because losses of this 

magnitude likely would not significantly affect a labor market of any size.

By exempting these smaller businesses from the nonrelocation provision, 

this official said that the CDBG program retains some flexibility for 

entitlement and nonentitlement communities to provide funds to 

businesses to promote job growth. This official further noted that HUD 

 20See 24 C.F.R. § 570.210 (Entitlement program); 24 C.F.R. § 570.482(h) (State program). 

Page 16 GAO-07-1005 Restricting Federal Funds for Employer Relocation
also determined that relocations involving 500 or more jobs would be 

significant for labor markets of any size. 

SBA’s 504 program, which guarantees the portion of a business loan that 

nonprofit certified development companies make to businesses, features 

potentially higher job loss thresholds.21 For example, SBA regulations 

would require that applications for loans be denied if the relocation would 

result in the business’s reducing its workforce by at least one-third, or 

serious unemployment would result in the original business location or 

any area of the country. SBA regulations allow for the waiver of these job 

loss limits if the relocations would be key to the economic well-being of 

the business or if the benefits to the applicant and the receiving

community would outweigh the negative impact to the community from 

which the applicant would move. 

As noted previously, three of the programs specify conditions in addition 

to job loss for applying the nonrelocation provision, such as relocations 

occurring across defined geographic areas and funding thresholds. For 

example, HUD’s CDBG regulations for both the Entitlement and State 

programs prohibit funding for a business that relocates to a different labor 

market area.22 USDA’s B&I program, through which USDA guarantees up 

to 80 percent of a loan that an approved third-party lender makes to 

businesses, statutorily prohibits program funds from supporting business 

relocations in cases in which USDA assistance exceeds $1 million. Our 

review of congressional reports indicates that this minimum funding 

threshold is intended to expedite the processing of small business 

applications, based on the reasoning that the relocation of small 

businesses would pose no threat to the labor force or other businesses in 

the original location. 

 21Certified development companies are private, nonprofit corporations established to 

promote economic development within a community. 13 C.F.R. § 120.822 requires each 

certified development company to have at least 25 members representing the following 

groups: (1) government organizations responsible for economic development; (2) financial 

institutions that provide commercial long-term fixed-asset financing; (3) community 

organizations dedicated to economic development; and (4) businesses. 

22According to BLS, a labor market area is an economically integrated area within which

individuals can readily change jobs without moving. According to HUD officials, HUD’s 

regulatory approach reflects the statutory nonrelocation provision for the CDBG program, 

which specifies that a “relocation is likely to result in a significant loss of employment in 

the market area from which the relocation occurs.” 

Page 17 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Congressional approval of the nonrelocation provisions for the nine large 

programs was spread over a 40-year period (1958 to 1998). Table 3 shows 

the date on which the nine programs became subject to nonrelocation 

provisions. 

Table 3: Timeline Showing Congressional Approval of Nonrelocation Provisions for 

Nine Large Federal Programs 

Yeara

Agency Program

1958b SBA Certified Development Company 504 Loan program 

1972 USDA B&I Guaranteed Loan program 

1993 USDA / HUD EZ/EC (2 programs) 

1998cLabor WIA Adult, Dislocated Workers, and Youth (3 programs) 

1998 HUD CDBG Entitlement and State (2 programs) 

Source: GAO analysis.

a

Years listed are those in which the legislation was enacted, not necessarily the years in which the 

provisions took effect. 

b

The 504 loan program was enacted in 1986 as part of the Small Business Investment Act of 1958, as

amended. The nonrelocation provision was established under the original 1958 act. It applied to the 

predecessors of the current 504 loan program and to the 504 program itself. 

c

Labor’s WIA was enacted in 1998, but the act’s nonrelocation provisions are based on the Job 

Training Partnership Act, which was enacted in 1982. 

One of the federal agencies has sought but not obtained removal of a 

nonrelocation provision from its program. USDA officials said that since 

2001 the agency has sought congressional support for the removal of the 

nonrelocation provision for the B&I program, citing administrative burden

and other problems involved with ensuring compliance. A USDA official 

explained that while Labor has the statutory responsibility to analyze labor 

market information related to B&I applications—to help ensure that 

funding will not result in the transfer of any employment or business 

activity—Labor does not receive separate funding to support analysis of 

this information. According to USDA, the agency has sent between 6 and 

18 B&I applications to Labor for review in the past few years. Labor 

Page 18 GAO-07-1005 Restricting Federal Funds for Employer Relocation
confirmed that it does not receive separate funding to support its analysis, 

but said the agency reviews all of the applications Labor provides.23

Federal agencies administering the nine programs with nonrelocation 

provisions used various procedures to help ensure that program recipients

complied with overall program goals and requirements, but the extent to

which these procedures specifically addressed nonrelocation provisions 

was limited. The Guide to Opportunities for Improving Grant 

Accountability states that organizations awarding grants need effective 

internal control systems to provide adequate assurance that funds are 

properly used and achieve intended results.24 The two loan guarantee 

programs—USDA’s B&I and SBA’s 504 programs—relied on screening 

mechanisms (written review guidance and eligibility checklists or thirdparty verification of data) to help ensure compliance with nonrelocation 

provisions. In contrast, officials who administer grant programs we 

reviewed noted inherent limitations in using screening mechanisms for 

grant programs, given that program recipients (states and local 

governments) do not always know at the time of application which 

businesses later will apply for and obtain assistance through the program. 

Because of the inherent limitations of screening, the agencies 

administering grant programs primarily relied on monitoring recipients 

and subrecipients to help identify instances of potential noncompliance. 

However, only one of the grant programs we reviewed had developed 

monitoring guidance specifically tailored to the nonrelocation provision. 

Without structured guidance and procedures in place, agencies have 

limited assurance that recipients and subrecipients are complying with 

Extent to Which 

Federal Agencies Had 

Established and 

Implemented 

Procedures to Help 

Ensure Compliance 

with Nonrelocation 

Provisions Was 

Limited 

 23We identified another agency—EDA for its Public Works and Facilities Program—that did 

obtain congressional removal of a nonrelocation provision. According to EDA officials, the 

Secretary of Commerce requested the removal because the agency had detected only one 

violation more than 30 years ago when the provision was effective and because EDA did 

not receive separate funding to monitor compliance with the provision. Senate and House

reports do not specifically address the rationale for removing this provision, but note that 

the legislative changes were being made to reflect different economic conditions and a new 

emphasis on innovation, productivity, and entrepreneurship. Despite the statutory removal 

of the provision, program officials told us they do not support the use of program funds to

relocate jobs among communities. 

24A guide compiled by members of the Domestic Working Group (a collection of federal, 

state, and local audit organizations tasked by the Comptroller General of the United States)

working on a Grant Accountability Project. They were tasked with offering suggestions for 

improving grant accountability. See Domestic Working Group, Guide to Opportunities for 

Improving Grant Accountability (Washington, D.C.: October 2005). 

Page 19 GAO-07-1005 Restricting Federal Funds for Employer Relocation
statutory and regulatory requirements and spending funds on allowable 

activities. 

Agencies Had Eligibility 

Screening Procedures, but 

Focus on Nonrelocation 

Provision Was Limited 

As stated in the Guide to Opportunities for Improving Grant 

Accountability, organizations that award and receive grants need effective 

internal control systems to help ensure that grants are awarded to eligible

entities for intended purposes and in accordance with applicable laws and

regulations. As shown in table 4, each of the four federal agencies we 

reviewed had screening procedures covering applicants’ eligibility to 

receive funds. The agencies used at least one of the following mechanisms: 

written application or plan review guidance, eligibility checklists, selfcertification forms, third-party verification of data, or business statements 

of compliance. However, only four of the nine programs—including both 

loan guarantee programs—used screening mechanisms that specifically 

addressed a relevant nonrelocation provision. 

Table 4: Federal Agency Mechanisms to Screen for Compliance with Nonrelocation Provisions

Written application or plan

review guidance Self-certification form 

Agency Program

Specific to

nonrelocation 

provision 

Not specific 

to 

nonrelocation 

provision 

Eligibility 

checklist that 

specifically 

addressed

nonrelocation

Specific to

nonrelocation 

provision 

Not specific 

to 

nonrelocation 

provision 

Third-party 

verification of

applicant 

data specific 

to 

nonrelocation

Business 

statements 

of 

compliance

EZ (urban) 9 9

CDBG 

(Entitlement) 

9 9 9

HUD 

CDBG 

(State) 

9 9 9

WIA Adult 9 9 9

WIA 

Dislocated 

Workers 

9 9 9

Labor 

WIA Youth 9 9 9

EZ/EC 

(rural) 

USDA 9 9

B&I Loans 9 9 9

SBA 504 9 9

Source: GAO analysis.

Page 20 GAO-07-1005 Restricting Federal Funds for Employer Relocation
All four agencies had procedures for reviewing applications or plans to 

help ensure that applicants were eligible to receive funds under the 

program. 

Review of Applications or 

Plans 

• The two loan guarantee programs—USDA for its B&I program and SBA for 

its 504 program—had formal written guidance that specifically addressed 

the screening of applicants for compliance with the nonrelocation 

provision. USDA’s formal written guidance listed the nonrelocation 

provision as one of the ineligible purposes of a B&I loan guarantee.25 SBA 

also incorporated specific references to its nonrelocation provision into its 

standard operating procedures, which are addressed to SBA personnel and 

lending partners who review and approve 504 loans. SBA also required its 

504 lending partners to complete an eligibility checklist for each loan

guarantee applicant. One of the items on the eligibility checklist seeks to 

determine whether 504 loan proceeds will be used to “relocate any 

operations of a small business, which will cause a net reduction of onethird or more in the workforce of the relocating small business or a 

substantial increase in unemployment in any area of the country.” In 

reviewing the supporting documentation for 10 approved loans, we found 

that certified development companies were using the eligibility checklist 

SBA had developed to screen 504 loan applicants for these loans.26

• Each of the seven grant programs had formal written guidance covering 

the review of required plans but with the exception of USDA’s EZ/EC 

program, the guidance did not specifically address the nonrelocation 

provisions for each program. Under the CDBG programs, recipients 

(entitlement communities and states) must submit an action plan to HUD 

each year that broadly identifies the activities that they will undertake to 

meet the objectives of previously submitted consolidated plans.27 Labor 

requires states to submit strategic plans for WIA describing how a state 

intends to use WIA funds. Both agencies use written checklists as 

guidance to determine whether the submitted plans are complete and both 

agencies’ guidance includes an item to determine whether applicants have

assured their compliance with applicable laws and regulations. HUD 

 25USDA RD Instruction 4279-B, section 4279.114(b). 

26Under the 504 program, certified development companies underwrite up to 40 percent of 

project financing. Thus, they are involved in screening 504 program applicants and

monitoring their use of loan proceeds. 

27CDBG recipients submit a consolidated plan at least once every 3 to 5 years that 

addresses the housing, homeless, and community development needs in the recipient’s

jurisdiction. 

Page 21 GAO-07-1005 Restricting Federal Funds for Employer Relocation
officials noted that its written guidance on review of action plans does not 

require analysis of the nonrelocation provision, in part because CDBG 

recipients generally do not know which businesses will apply for CDBG 

funding at the time the plans are developed and submitted to HUD. HUD 

officials explained that most CDBG recipients engaged in economic 

development activities have an “open window” approach, in that 

assistance is available to businesses on an “as needed” basis during the 

program year. 

• For the EZ/EC programs, USDA had formal written guidance for reviewing 

required application plans that referred to the program’s nonrelocation 

provision, while HUD’s written guidance did not specifically address the 

provision. Under the EZ/EC program, communities seeking EZ or EC 

designation submit (1) a strategic plan outlining the community’s vision 

for revitalizing its distressed area; (2) a tax incentive utilization plan 

specifying how the community plans to use the tax benefits available 

under the program; and (3) an implementation plan providing detailed

information on the activities and projects the community is undertaking to 

implement its strategic plan. HUD officials said that while the agency does

not currently have review guidance specific to the nonrelocation 

provision, the agency has been revising a review manual to incorporate 

language specific to the provision and has been taking other steps, such as 

communicating directly with EZs regarding compliance and providing 

training to staff, to raise awareness of the provision and the need to 

comply with it. USDA officials said that EZ/EC review staff were told to 

reject any application for EZ/EC designation in which an applicant’s 

strategic plan included evidence that the community intended to lure 

businesses from other communities. The officials said that review staff 

eliminated several applications for potential program designation because 

intent to relocate jobs was evident in the submitted plans. However, we 

were not able to verify this statement because USDA officials said that the

strategic plans eliminated from contention were discarded and are no 

longer available for review. 

Some officials, particularly those who administer grant programs, noted 

the limitations of reviewing applications and plans to identify instances of 

potential noncompliance with a nonrelocation provision. As noted above, 

HUD CDBG officials said that action plans for its Entitlement program 

were unlikely to identify specific businesses receiving funds because the 

communities do not always know which businesses would apply for 

assistance when they submitted the action plans. Similarly, the officials 

noted that action plans for the State CDBG program do not contain a list 

of proposed activities, but rather a description of the methods used to 

distribute funds to local governments. HUD officials noted that under the 

Page 22 GAO-07-1005 Restricting Federal Funds for Employer Relocation
CDBG State program, individual states implement a method of distributing 

funds that may or may not include economic development activities and 

that in most cases the states evaluate applications from local governments 

to determine which activities to fund. 

As part of the application review process, USDA’s EZ/EC and B&I 

programs require applicants to sign self-certification forms that included a 

specific reference to the nonrelocation provision for each program. For 

example, USDA’s application for the EZ/EC program contained a form in 

which an applicant self-certifies that “no action will be taken to relocate 

any business establishment to the nominated area.” According to USDA 

EZ/EC officials, this required certification sends a clear message to the 

EZ/EC community that relocation is not permitted under the program. 

Similarly, USDA’s B&I program requires loan applicants applying for loans 

of more than $1 million that will increase employment by more than 50 

employees to self-certify that “it is not the intention of the applicant or any 

related company to relocate any present operation as a result of the 

proposed project.”28

Other agencies, such as HUD for both its CDBG and EZ programs and 

Labor for its WIA programs, require more general statements of 

compliance. For example, HUD’s application for Round II of the EZ 

program contained a form in which an applicant self-certified that “the 

nominating entities shall comply with state, local, and federal

requirements, and have agreed in writing to carry out the Strategic Plan if

designated.” Similarly, HUD’s CDBG program requires applicants to selfcertify their compliance with “applicable laws,” which HUD officials said 

includes the Housing and Community Development Act of 1974, as 

amended, which contains the nonrelocation provision. According to the 

officials, HUD saw no need or statutory basis to add a special certification 

for the nonrelocation provision, particularly since not all states or 

entitlement communities use CDBG funding for economic development 

purposes. Labor’s statement of compliance, included in WIA state strategic

plans, requires the governor of each state to assure that WIA funds “will be

spent in accordance with the Workforce Investment Act and the WagnerPeyser Act and their regulations, written Department of Labor guidance 

implementing these laws, and all other applicable federal and state laws 

and regulations.” Labor officials noted that this general statement of 

Requirements for SelfCertification of Compliance 

 28USDA only requires an applicant to make this self-certification if the applicant or related 

company has a business facility at another location. 

Page 23 GAO-07-1005 Restricting Federal Funds for Employer Relocation
compliance covers compliance with the nonrelocation provision. During 

our review of 30 USDA EZ/EC, HUD EZ, and Labor WIA approved grant

applications (10 applications for each program), we found that recipients

had completed the required self-certifications for each of the applications

we reviewed. 

As part of the pre-approval process for the B&I program, USDA turns over 

information that certain loan applicants provide to Labor for independent,

third-party verification. For guaranteed loans in excess of $1 million that 

will increase employment by more than 50 jobs, USDA will send an 

applicant’s certification of nonrelocation and the market and capacity

information form to Labor for clearance. In-turn, Labor sends the form to 

state-level workforce agencies, where the business’ competitors are 

located, for analysis and direct solicitation of the competitor’s comments. 

According to USDA officials, Labor must complete this third-party 

verification before USDA can approve a B&I loan guarantee request. Our 

review of loan documentation for 10 approved B&I loan applications 

indicated that both USDA and Labor carried out these procedures for the 

applications we reviewed. As discussed earlier in this report, USDA 

officials have been asking Congress to remove the nonrelocation provision 

from the B&I program, citing an administrative burden and costs incurred 

in helping to ensure compliance. 

Regulations for HUD’s Entitlement and State CDBG programs and Labor’s 

three WIA programs require grant recipients (such as a state or local 

government) to obtain a signed written statement of compliance with the

nonrelocation provision from businesses before providing direct 

assistance to them. For example, under the CDBG programs, there is a 

two-step process. First, businesses receiving CDBG assistance must 

submit a written statement to the recipient (entitlement community or 

state), subrecipient, community-based development organization, or 

nonprofit providing the assistance whether the activity will result in the 

relocation of jobs from one labor market area to another. Second, if the 

assistance will not result in the relocation of jobs covered by the statutory 

prohibition, the business must provide a certification that it has no plans 

to relocate jobs (in a manner that would violate the nonrelocation 

provision). However, these statements are not included in a recipient’s 

application for funding (action plan), and thus HUD does not review them 

during the action plan review process. HUD officials noted that it would 

not be possible for an entitlement community to provide these statements 

to HUD with an action plan because, as previously noted, most entitlement 

communities do not know at that time which businesses will apply for 

CDBG assistance. Similar to HUD, Labor’s regulations for WIA require that

Pre-Approval Third-Party 

Verification

Requirements for Written 

Statements of Compliance from 

Businesses 

Page 24 GAO-07-1005 Restricting Federal Funds for Employer Relocation
local workforce investment boards conduct a pre-award review of 

businesses seeking job training funds, which includes obtaining a written 

certification from the business indicating whether WIA assistance is being 

sought in connection with past or impending job losses at other facilities. 

Our review of 10 approved WIA grants indicated that businesses had 

completed the required statements of compliance for each of those grants. 

With respect to HUD’s CDBG program, we did find one case in which a 

HUD CDBG entitlement community recipient we contacted told us that its 

subrecipient (a nonprofit development corporation) was not obtaining the 

required written statements of compliance. An official from the 

entitlement community said that neither the entitlement community nor 

the subrecipient had developed formal procedures to help ensure 

compliance with the regulatory requirement. In addition, neither HUD nor 

Labor require that recipients provide copies of completed written 

statements to HUD or Labor, although a HUD official noted that the 

written statements would be available to on-site reviewers during 

monitoring visits. HUD officials also said that HUD is revising a monitoring 

handbook to include a question addressing the business’ written 

statements of compliance. We discuss agency monitoring procedures and 

guidance in greater detail in the next section. 

The Guide to Opportunities for Improving Grant Accountability states 

that once grants are awarded, agencies need to ensure that grant funds are 

used for intended purposes and in accordance with applicable laws and 

regulations. The guide also states that it is critical to identify, prioritize, 

and manage potential at-risk subrecipients to ensure that grant goals are 

reached and resources are properly used. Due to inherent limitations in 

using the screening process to help ensure compliance with nonrelocation

provisions, other procedures, such as monitoring activities, become key

controls. Having established, written procedures in place helps to ensure 

that agencies achieve their monitoring objectives and that staff are 

consistently implementing monitoring procedures. 

Officials at some of the agencies we reviewed told us that they rely on 

complaints as a mechanism to monitor compliance with the employer 

nonrelocation provision. A HUD official said that an employer relocation 

that resulted in significant job loss and involved the use of federal funds 

likely would result in the affected community or state raising a complaint 

to the federal agency or to their congressional representatives. HUD, 

Labor, SBA, and USDA officials all reported receiving few if any of these 

complaints, in some cases over the course of many years. For this reason, 

While Monitoring Is a Key 

Control for Helping to 

Ensure Compliance with 

Nonrelocation Provisions, 

Only One Grant Program 

Had Written Guidance 

Specific to the Provision 

Page 25 GAO-07-1005 Restricting Federal Funds for Employer Relocation
some officials did not consider the risk of noncompliance to pose a 

significant risk to the programs. However, this complaint-based approach

is reactive and does not necessarily provide reasonable assurance of 

compliance. Standards for Internal Control in the Federal Government

states that an agency’s monitoring activities should be performed 

continually and be ingrained in agency operations.29 As shown in table 5, 

the four agencies administering programs with nonrelocation provisions 

used various other mechanisms, including on-site review, to monitor fund

recipients. All of the agencies had formal written guidance covering the

monitoring of program participants. However, only one program—HUD 

for its EZ program—had a monitoring procedure that specifically 

addressed the nonrelocation provision. 

Table 5: Status of Federal Agency Mechanisms for Monitoring Compliance with Nonrelocation Provisions, as of July 2007 

Agency Program

On-site monitoring of 

recipients 

Written monitoring 

guidance

Written monitoring 

guiduance specific to

nonrelocation 

provision 

Specific monitoring

guidance has been

used in a monitoring

review

HUD EZ (urban) 9 9 9 9

CDBG (Entitlement) 9 9 Draft

CDBG (State) 9 9 Draft 

Labor WIA Adult 9 9 Draft 

WIA Dislocated

Workers 

9 9 Draft 

WIA Youth 9 9 Draft 

USDA EZ/EC (rural) 9

B&I Loan Guarantee N/Aa

9

SBA 504 Loan Guarantee N/Aa

9

Source: GAO analysis.

a

Given program structure and legal requirements, USDA and SBA procedures are implemented upfront, on a pre-approval rather than a post-approval basis. 

To effectively leverage limited staff resources, HUD and Labor told us that 

their respective agencies conduct on-site monitoring reviews in

accordance with risk-based procedures intended to focus monitoring 

 29GAO’s Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999) provides an overall framework for establishing and

maintaining internal control, identifying and addressing major performance and

management challenges, and identifying and addressing areas at the greatest risk of fraud,

waste, and mismanagement. 

Page 26 GAO-07-1005 Restricting Federal Funds for Employer Relocation
resources on areas requiring the most attention.30 For example, HUD’s 

procedures for the EZ program specify factors for reviewers to consider 

when determining the scope of a review. These factors include funding 

amount, outstanding complaints related to noncompliance with a legal 

requirement, and unresolved monitoring or assessment issues. Similarly, 

for the CDBG program, reviewers consider factors such as the complexity 

of a state or entitlement community’s activities and use of subrecipients to

carry out funded activities. According to HUD CDBG officials, on-site 

monitoring is the most effective way to identify potential violations of the 

nonrelocation provision for the CDBG program. Labor also conducts onsite monitoring of states and a sample of local workforce investment 

agencies. As part of Labor’s risk-based procedures, reviewers may 

consider factors such as the number of federal grants a state administers, 

a history of disallowed costs or administrative findings in previous 

reviews, and percentage of grant funds subcontracted. 

USDA’s monitoring for the EZ/EC program involves two staff members—

one in a state office and the other in the national office—reviewing 

requests for drawdown that EZ/ECs make several times during the year. 

Drawdown requests include a specification of how an EZ or EC will use its 

funds. Prior to disbursing requested funds, USDA staff members review 

the request to ensure that the funds will be used to carry out the 

community’s strategic plan (which includes a certification form that 

specifically refers to the nonrelocation provision and which USDA reviews 

at the time of initial application). In addition to reviewing drawdown 

requests, USDA staff in both the state and national offices review 

mandatory annual reports describing a community’s progress in 

implementing its strategic plan. According to USDA officials, the review of 

annual reports also includes a review of any updates to the strategic plan 

to ensure that no relocation support has crept into the plan since the initial 

review. A USDA official added that USDA staff have made on-site 

monitoring visits to all of the rural EZ/ECs. 

Officials of SBA’s 504 and USDA’s B&I program told us that they do not 

monitor for compliance with the nonrelocation provision because, unlike 

federal grant programs, in loan guarantee programs, a federal agency can 

determine which specific businesses will receive assistance and for what 

 30HUD CDBG program officials noted that HUD also can perform off-site monitoring of 

recipients if necessary. This off-site monitoring involves a remote review of files and 

documents in a HUD office. 

Page 27 GAO-07-1005 Restricting Federal Funds for Employer Relocation
purpose (relocation, equipment purchase, etc.) before an agency 

guarantees a loan. SBA officials explained that SBA and certified 

development companies (CDC) approve a project for 504 financing before

construction begins, but SBA does not disburse loan funds or issue a 

debenture guarantee until after the project is completed.31 According to 

SBA officials, CDC staff review the completed project before closing on a 

loan, at which time loan funds are disbursed and a debenture guarantee 

issued. Similarly, USDA officials told us that their field staff verify uses for 

loan proceeds when they review a loan closing package, specifically the 

settlement statement, before guaranteeing a loan. USDA officials 

explained that once a loan is fully disbursed, subsequent monitoring of the 

use of loan proceeds for compliance focuses on other issues, such as the 

number of jobs created, rather than compliance with the nonrelocation 

provision, because the loan proceeds already have been used for their 

intended purposes. The emphasis on screening rather monitoring seemed 

appropriate for the two loan guarantee programs since the federal 

agencies know which specific businesses are requesting funds and the 

purposes for which the funds will be used. 

HUD’s EZ program was the only program we reviewed that had written 

monitoring guidance specific to the nonrelocation provision at the time of

our review. As of July 2007, HUD had used this monitoring guidance in 

four on-site reviews. HUD’s guide for the review of Round II EZ strategic 

plan compliance calls for review staff to determine whether there is “any 

evidence to indicate that the EZ is complying with the prohibition against

assisting a business to relocate.” The guide did not provide specific 

procedures or steps that staff should follow to make the assessment of 

compliance, but rather referred to the program’s implementing regulation

for the nonrelocation provision. HUD officials said that under current 

procedures, on-site reviewers rely on receiving complaints of 

noncompliance or on information obtained by asking open-ended 

questions about compliance to determine whether communities are 

complying. For the four reviews in which HUD had used the guidance at 

the time of our review, the narrative supporting the reviewer’s assessment 

of compliance indicated that approved implementation plans, discussions 

with EZ staff regarding standard operating procedures, and a review of 

loan file documents were among the bases on which HUD reviewers 

determined that EZs were complying with the program’s nonrelocation 

provision. HUD officials said that for additional on-site reviews planned 

 31A debenture is a certificate acknowledging a debt. 

Page 28 GAO-07-1005 Restricting Federal Funds for Employer Relocation
for fiscal year 2007, the agency is considering reviewing implementation 

plans to specifically check for compliance with the nonrelocation 

provision. HUD officials said that they would focus on plans involving 

sites with potential for commercial development to determine whether 

HUD-approved activities or projects involving marketing or promotional 

efforts encouraged relocations to an EZ. 

HUD and Labor officials told us that their agencies were developing 

monitoring guidance specific to the nonrelocation provision for the CDBG 

and WIA programs, respectively, but that such guidance is in draft form.32

As of July 2007, HUD and Labor had not finalized this guidance or used it 

in a monitoring review. HUD officials said that HUD expects to finalize the 

monitoring guidance tailored to the nonrelocation provision by December 

31, 2007. The officials explained that HUD was developing monitoring 

guidance for inclusion in a forthcoming revision to a monitoring handbook 

that HUD uses for all of its major Office of Community Planning and 

Development grant programs, including the CDBG and EZ programs. HUD 

undertook the revisions because the current version of the handbook was 

issued prior to the promulgation of the CDBG program’s nonrelocation 

provision in December 2005. HUD CDBG officials stated that including a 

question on compliance with the nonrelocation provision is intended to 

ensure that compliance reviews by HUD staff in this area would be 

consistent. Labor officials explained that their monitoring handbook for 

employment and training grant programs, including WIA programs, is 

generic and limited to examining core activities found in all of Labor’s 

employment and training programs. In contrast, Labor’s formula grant 

supplement to the monitoring handbook, currently under development and 

in draft form, will provide a more detailed examination of statutes, rules, 

and regulations specific to the formula-based programs once finalized. 

Labor officials said that the formula grant supplement has been tested in 

field offices and will address the nonrelocation provision. The officials 

said that they expect to publish the formula grant supplement in the latter 

half of calendar year 2007. 

State and local governments use incentives, including funds from federal 

economic development programs, to attract business investment and Conclusions 

 32According to HUD officials, the monitoring guidance for the CDBG program, once 

finalized, will include a check for business statements of compliance, required under the 

CDBG program’s nonrelocation provision. As noted previously, businesses are to complete

these statements as a condition of receiving CDBG funds. 

Page 29 GAO-07-1005 Restricting Federal Funds for Employer Relocation
create jobs in their communities. Although it is difficult to determine the 

extent to which state and local governments use federal funds as business 

incentives, 9 of 17 large federal economic development programs contain 

statutory restrictions against using program funds to relocate jobs if the 

use of such funds creates unemployment. Thus, for these nine federal 

programs, the agencies charged with their administration are responsible 

for helping to ensure that program funds are used for intended purposes 

and in accordance with applicable laws and regulations, including 

compliance with nonrelocation provisions. 

Each of the four agencies that administer the programs with nonrelocation 

provisions used screening and monitoring mechanisms to help ensure that

fund recipients were eligible to participate in the programs, meeting 

program goals, and complying with legal requirements. The two agencies 

administering the loan guarantee programs we reviewed—SBA for the 504 

program and USDA for the B&I program—relied primarily upon screening 

mechanisms to help ensure that applicants would not use loan proceeds to 

relocate businesses and jobs. For these two programs, screening 

mechanisms may be sufficient since the agencies can determine which 

specific businesses will receive assistance and how the loan proceeds will 

be used. In such cases, a screening process can determine if loan funds 

will be used to support a business relocation. In contrast, officials from the 

other programs we reviewed, particularly those that administer grant 

programs, noted limitations in using screening mechanisms for such 

programs. For example, with grant programs, fund recipients (e.g., states 

and local communities) do not always know which businesses will apply 

for or receive funding at the time the recipient submits an initial plan or 

application for funding. 

Acknowledging the limitations of screening for helping to ensure 

compliance with nonrelocation provisions, agency officials regarded onsite monitoring as the most effective way to detect an instance of potential

noncompliance in their grant programs. However, officials also noted that 

they targeted their limited monitoring resources on recipients that posed 

the greatest risk. Furthermore, they maintained that noncompliance with

nonrelocation provisions did not present a significant risk to the programs 

they administered because they received few or no complaints over the 

years and regarded complaints as a barometer for undertaking monitoring 

activities. 

We recognize that there are costs associated with monitoring program 

recipients for compliance with nonrelocation provisions. Nevertheless, a 

reactive approach in which agencies assume there are no problems 

Page 30 GAO-07-1005 Restricting Federal Funds for Employer Relocation
because outside parties do not report them, by itself, is an insufficient 

means to help ensure that problems do not exist and federal internal 

control standards state that monitoring should be performed continually 

and be ingrained in agency operations. Further, USDA EZ/EC program 

officials said that they have rejected applications for zone designation 

because intent to relocate jobs was evident in the applications, providing 

evidence that applicants do sometimes seek to use program funds to lure 

businesses away from one community to another. 

Given the relatively large size of some federal grant programs and their 

complicated funding structure (including the number of recipients and 

subrecipients involved in the process), it is important that agencies 

develop and use cost-effective approaches to identify, prioritize, and 

manage potential at-risk recipients. Specific monitoring guidance and 

procedures would provide staff impetus and direction in their monitoring

roles and help ensure consistent monitoring efforts across locations. 

Moreover, written guidance would provide recipients and subrecipients 

with specific information on the types of business support activities 

allowed under each program. For example, we learned that there are HUD 

CDBG subrecipients who may be unaware of the requirement that 

businesses receiving assistance under the program must provide written 

statements of compliance with the nonrelocation provision. Absent such 

guidance and related controls, agencies have limited assurance that 

recipients and subrecipients—which include state and local governments 

as well as individual business—are meeting statutory and regulatory 

responsibilities that restrict the use of program funds to support employer 

relocations.

To provide greater assurance that grant recipients and subrecipients of 

federal economic development programs are complying with statutory 

restrictions against the use of program funds to support employer 

relocations, we recommend that the Secretaries of Labor (for the WIA 

Adult, Dislocated Workers, and Youth programs); Agriculture (for the 

EZ/EC program); and Housing and Urban Development (for the CDBG 

Entitlement and State programs) direct their respective offices to develop

(or finalize the development of) and implement formal and structured 

approaches for federal reviewers to follow when monitoring for 

compliance with nonrelocation provisions. 

Recommendations for 

Executive Action 

Page 31 GAO-07-1005 Restricting Federal Funds for Employer Relocation
We provided a draft of this report to the Secretaries of the Departments of 

Labor, Agriculture, Housing and Urban Development, and Commerce; the 

Acting Commissioner of the Internal Revenue Service; and the 

Administrator of the Small Business Administration. We received written 

comments from Labor that are summarized below and are reprinted in 

appendix III. USDA’s Acting Assistant Deputy Administrator for 

Cooperative Programs provided oral comments on August 8, 2007, which 

are summarized below. 

Agency Comments 

and Our Evaluation 

In its written comments, Labor stated that the department concurred with 

our recommendation that it develop and implement formal and structured 

approaches for federal reviewers to follow when monitoring compliance 

with nonrelocation provisions. In addition, Labor stated that it agreed that 

such guidance and approaches will assist states in monitoring local 

subrecipient compliance with these provisions. Labor stated that to 

support efforts to monitor and ensure compliance with nonrelocation 

provisions, it is implementing two complementary strategies. First, Labor 

is developing a formal policy guidance letter that clarifies allowable and 

unallowable uses of WIA funds for economic-development-related 

activities and that will specifically address prohibitions related to the 

nonrelocation provision. Second, Labor said that its Core Monitoring 

Guide and draft Formula Grant Supplement to the guide provide federal 

reviewers with tools for monitoring compliance with the nonrelocation 

provision. Labor said the draft Formula Grant Supplement includes 

indicators of compliance along with each governor’s responsibility to 

determine which costs are allowable or unallowable under WIA, including 

prohibitions against using WIA Title I funds to encourage business 

relocation and related restrictions. Labor stated that its regional office 

reviewers have extensively tested the draft Formula Grant Supplement

since the fall of 2006, and the supplement will enter the formal clearance 

process shortly. Labor said that when completed in final form, which the 

department expects to occur by December 31, 2007, the supplement will 

provide federal reviewers, as well as state review staff, with a valuable 

resource for assessing recipients’ compliance with the nonrelocation 

provision under the WIA Adult, Dislocated Worker, and Youth programs. 

In oral comments, USDA’s Acting Assistant Deputy Administrator for 

Cooperative Programs stated that USDA concurred with the report’s 

recommendation. The Acting Assistant Deputy Administrator also 

provided us with documentation showing that USDA is taking initial steps 

to implement the recommendation. 

Page 32 GAO-07-1005 Restricting Federal Funds for Employer Relocation
We also received technical comments from Labor, USDA, HUD, IRS, and 

SBA that were incorporated into the report as appropriate. Commerce did 

not provide comments on the draft report. 

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 30 days from the 

date of the report. At that time, we will provide copies of this report to the 

Ranking Member, Subcommittee on Interstate Commerce, Trade, and 

Tourism, Senate Committee on Commerce, Science, and Transportation, 

and interested congressional committees. We will also provide copies of 

this report to Secretaries of Labor, Agriculture, Housing and Urban 

Development, and Commerce; the Acting Commissioner of the Internal 

Revenue Service; and the Administrator of the Small Business 

Administration. We will provide copies to others upon request. In addition, 

this report will be available at no charge on our home page at 

http://www.gao.gov. 

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

contact me at (202) 512-8678 or shearw@gao.gov. Contact points for our 

Office of Congressional Relations and Public Affairs may be found on the 

last page of this report. GAO staff who made key contributions to this 

report are listed in appendix IV. 

Sincerely yours, 

William B. Shear 

Director, Financial Markets and 

 Community Investment 

Page 33 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To identify large federal economic development programs, we conducted

a search of the Catalog of Federal Domestic Assistance (CFDA) database 

(using key word searches of “jobs” and “economic development”) and 

focused on those programs that can be used to provide assistance to 

businesses and that CFDA reported as having obligations of at least $500 

million for fiscal year 2006. In a prior report, we found inconsistencies in 

how agencies reported budget data for CFDA, resulting in potential overreporting of data.1

 However, for purposes of this report, because we are 

using CFDA to identify large federal economic development programs, the 

risk is acceptably low of CFDA not covering large programs we would 

have otherwise selected. We, therefore, consider CFDA to be a sufficiently 

reliable source of data for use in this report. Because CFDA does not 

include tax expenditure programs, we searched the Congressional 

Research Service’s (CRS) Tax Expenditure Compendium (using key word 

searches of “community development” and “private activity bonds”) for 

economic development tax expenditure programs that support businesses 

for which CRS reported as having estimated tax revenue losses of at least

$500 million in fiscal year 2006. We also confirmed these budget figures 

with agency officials. We excluded programs that are only available under 

specific circumstances or are not available nationwide, such as regional 

economic development programs or those that are only available under 

disaster assistance designations. 

In addition to these database searches, we reviewed each of the 50 states’ 

economic development Web sites to identify the federal programs that 

states marketed as incentives or financial assistance for businesses. While 

this search did not provide us with a comprehensive list of federal 

programs used as business incentives, it provided us with additional 

information on how the programs we identified through CFDA and the 

CRS compendium might be used as incentives. 

To identify large federal programs currently or formerly subject to 

restrictions against use for relocating jobs among U.S. communities, we 

reviewed laws and regulations. Our review included the use of electronic

databases. We identified relevant nonrelocation provisions for four federal 

agencies—the Departments of Housing and Urban Development (HUD), 

Agriculture (USDA), Labor, and the Small Business Administration 

(SBA)—and a former provision for one federal agency—the Department of 

 1

GAO, Rural Economic Development: More Assurance is Needed that Grant Funding 

Information is Accurately Reported, GAO-06-294 (Washington, D.C.: Feb. 24, 2006), 32. 

Page 34 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix I: Scope and Methodology 

Commerce’s Economic Development Administration (EDA). To assess the 

completeness of our search results, we interviewed representatives of 

select federal agencies as well as representatives of economic 

development trade associations and policy groups. To identify

congressional purpose in adopting or rescinding restrictions, we reviewed 

implementing laws and their legislative histories, including congressional 

reports and the Congressional Record. 

To assess federal agency procedures to help ensure compliance with 

nonrelocation provisions, we requested, obtained, and analyzed the 

following information from HUD, Labor, USDA, and SBA 

• policies and procedures designed to ensure compliance with

nonrelocation provisions; 

• data on the number of complaints received regarding the provisions; 

• data on the number of violations identified; and

• information about any enforcement actions taken, as well as the status of 

those actions. 

We also conducted a limited test of agency procedures by reviewing a 

small and random, but not generalizable sample of case file documentation 

for each of the programs (generally 10 files for each program). These 

documents included the mechanisms agencies have developed to screen 

for compliance with nonrelocation provisions, including 

• an eligibility checklist (SBA’s 504 program); 

• self-certification forms (USDA and HUD’s Empowerment Zone/Enterprise 

Community program); 

• business statements of compliance as a condition of receiving assistance 

(Labor’s Adult, Dislocated Workers, and Youth programs under the 

Workforce Investment Act); and 

• third-party verification of data that applicants self report (USDA’s 

Business and Industry Guaranteed Loan program). 

Further, we reviewed monitoring guidance and exhibits for each program 

having such guidance; completed monitoring reports; publications on 

effective internal control and grant management practices; and recently

Page 35 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix I: Scope and Methodology 

issued reports we completed on the programs.2 To supplement our 

document reviews and testing procedures, we conducted interviews with 

officials at each agency.

The scope of our work in this area was focused mainly on whether the 

agencies had screening and monitoring procedures. We did not test the 

effectiveness of the implementation of these procedures. Furthermore, we 

did not conduct an overall evaluation of the programs, evaluate how well 

the programs served their intended purposes, or evaluate how 

nonrelocation provisions affect the relative success of the programs in 

achieving their intended purposes. We also did not address the impact 

these programs had on development efforts by state and local

governments. 

We conducted our work from October 2006 through August 2007 in 

Washington, D.C., and San Francisco and Fresno, California, in

accordance with generally accepted government auditing standards. 

 2

For example, GAO, Workforce Investment Act: Labor and States Have Taken Actions to 

Improve Data Quality, but Additional Steps Are Needed, GAO-06-82 (Washington, D.C.:

Nov. 14, 2005); Community Development Block Grants: Program Offers Recipients 

Flexibility but Oversight Can Be Improved, GAO-06-732 (Washington, D.C.: July 28, 2006); 

and Empowerment Zone and Enterprise Community Program: Improvements Occurred

in Communities, but the Effect of the Program Is Unclear, GAO-06-727 (Washington, D.C.: 

Sept. 22, 2006). 

Page 36 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix II: De

Federal E

with No

scription of the Nine Large

conomic Development Programs 

nrelocation Provisions

Page 37 GAO-07-1005

Appendix II: Description of the Nine Large 

Federal Economic Development Programs 

with Nonrelocation Provisions 

The following is a description of the nine large federal economic 

development programs that we identified as having statutory restrictions 

against using program funds to relocate businesses and jobs. Seven are 

grant programs in which a federal agency provides funds to recipients 

(generally a state or local government) that, in turn, may provide funds to 

a subrecipient (such as a nonprofit entity or for-profit business) to 

facilitate economic development activities. They are 

• the Department of Housing and Urban Development’s (HUD) Community 

Development Block Grant (CDBG) Entitlement and State programs; 

• HUD and U.S. Department of Agriculture’s (USDA) Empowerment 

Zone/Enterprise Community (EZ/EC) programs (urban and rural 

respectively); and 

• the Department of Labor’s (Labor) three Workforce Investment Act (WIA) 

programs—Adult, Dislocated Workers, and Youth. 

The two remaining programs—USDA’s Business and Industry (B&I) 

program and SBA’s 504 program—are loan guarantee programs in which 

federal agencies guarantee loans that third-party lenders and nonprofit 

development corporations make. 

HUD’s CDBG program provides communities with grants for activities that 

will benefit low- and moderate-income people, prevent or eliminate slums 

or blight, or meet urgent community development needs. The Entitlement 

program provides grants to qualifying local governments. The State 

program provides states with grants for distribution to the smaller, 

nonentitlement communities. Both programs fund a wide range of 

activities—including those that support housing, public improvements, 

public services, and economic development—which involve the use of 

funds to assist, recruit, and retain individual businesses. According to the 

Catalog of Federal Domestic Assistance (CFDA), fiscal year 2006 

estimated budget authority for the CDBG Entitlement program was $2.6 

billion and $1.1 billion for the State program. 

HUD’s Office of Community Planning and Development (CPD) administers 

the CDBG program. A headquarters office sets program policy while 43

HUD field offices monitor recipients. HUD distributes funds to entitlement 

HUD CDBG 

Entitlement and State 

Programs 

Restricting Federal Funds for Employer Relocation
Appendix II: Description of the Nine Large

Federal Economic Development Programs 

with Nonrelocation Provisions

communities and states based on the higher yield of two formulas.1 See 

figure 1 for an overview of the funding process for economic development 

projects involving businesses. Entitlement communities may carry out 

activities under CDBG directly, or they may award funds to subrecipients, 

which include, as HUD defines them for the purposes of the CDBG 

program, governmental agencies such as housing authorities as well as 

private nonprofit and a limited number of private for-profit entities. Under 

HUD regulations, subrecipients must enter into a signed, written 

agreement with entitlement communities regarding compliance with laws 

and regulations. States distribute their funds to nonentitlement 

communities for activities such as business financing. The distribution 

mechanisms vary by state; some states set aside a certain percentage of 

funds for economic development while others do not take into account the 

category of activity. Neither HUD nor the states distribute funds directly to 

citizens or private organizations. Moreover, HUD does not select the 

business entities that receive CDBG assistance; recipients and 

subrecipients make these decisions.

 1

The Entitlement and State programs each have their own set of formulas that take into

account population, poverty, overcrowding, growth lag, and age of housing. The two

formulas are similar. 

Page 38 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix II: Description of the Nine Large

Federal Economic Development Programs 

with Nonrelocation Provisions

Figure 1: Overview of CDBG Funding Streams for Economic Development Projects 

Involving Businesses 

Businesses receive assistance through the CDBG program either from a 

recipient (such as an entitlement community) or from subrecipients (such 

as designated public agencies or nonprofit development corporations). For 

example, once an entitlement community or a state receives its allocation, 

businesses may apply for economic development funding, assuming that 

the recipient has elected to operate an economic development program. 

This assistance may take the form of loans, grants, technical assistance, or

infrastructure improvements. This approach assumes that the recipient’s 

consolidated and action plans include and authorize these types of 

economic development activities. 

For a related GAO product on the CDBG program, see Community 

Development Block Grants: Program Offers Recipients Flexibility but 

Oversight Can Be Improved. GAO-06-732. Washington, D.C.: July 28, 2006. 

HUD CPD Office

(CDBG appropriation)

Allocation by formula

Entitlement Communities

(qualifying metropolitan areas)

Subrecipient

Businesses Businesses

Nonentitlement

communities

States

(distribution to local

areas varies by state)

Allocation by formula

Assistance in the form of grants, loans, or other

assistance, such as infrastructure improvements

Source: GAO analysis of prior reports and HUD information.

(can be public 

agency, nonprofits, 

or limited number 

of for-profit entities)

Page 39 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix II: Description of the Nine Large

Federal Economic Development Programs 

with Nonrelocation Provisions

HUD and USDA’s EZ/EC program targets federal grants and provides tax 

relief to distressed communities in urban and rural areas, respectively, to 

help those communities overcome economic and social problems. EZs and 

ECs can use grant funds for a range of activities identified in strategic 

plans, which are developed in conjunction with community stakeholders. 

Strategic plans outline the urban or rural community’s vision for 

revitalizing its distressed areas and the activities and projects planned to

accomplish this task. These activities can include education, infrastructure 

development, workforce development, and assistance to for-profit 

businesses. According to CRS’s Tax Compendium, estimated revenue

losses for USDA’s and HUD’s EZ/EC program were $1 billion combined for 

fiscal year 2006.2

Congress authorized three rounds of EZ designations and two rounds of 

EC designations. HUD and USDA have primary oversight over the 

program, which involves reviewing strategic plans, designating 

communities as EZs or ECs, and evaluating the progress EZs and ECs 

make in implementing their strategic plans. However, two other agencies, 

the U.S. Department of Health and Human Services (HHS) and the Internal

Revenue Service (IRS), also have had responsibility for administering the 

program. For the first round of the program which began in 1993, HHS had 

fiscal oversight over the program, in which HHS issued grants to states, 

which served as pass-through entities that in turn distributed funds to 

individual EZs and ECs. For the second round of the program, which 

began in 1998, Congress appropriated grant funds through USDA and 

HUD, but not through HHS. For the third round, which began in 2001, 

Congress appropriated grant funds for rural EZs but not for urban EZs. In 

addition to grants, businesses that locate in an EZ or EC can claim tax 

benefits, such as the Work Opportunity Tax Credit, which IRS administers. 

Tax benefits have been available in all three rounds of the EZ/EC program, 

but not the EC program. 

As shown in figure 2, businesses can receive funds directly from the 

designated EZ/EC cities or from nonprofit corporations the city 

establishes to administer the program. For example, EZs/ECs issue 

requests for proposals and review applications for EZ/EC funding, 

including those that businesses submit. The EZs/ECs that a corporation 

HUD and USDA

EZ/EC Programs 

 2

CRS’s Tax Compendium lists one combined estimated revenue-loss figure for the EZ tax 

incentive program (both HUD and USDA), District of Columbia tax incentive program, and

Indian Reservation tax incentive program. 

Page 40 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix II: Description of the Nine Large

Federal Economic Development Programs 

with Nonrelocation Provisions

oversees generally have a board of directors consisting of community 

members who review and have final approval for funded activities (with 

input from advisory committees). Businesses then receive funding in the 

form of grants, loans, and other assistance. Businesses eligible for federal,

state, and local tax benefits claim these benefits directly on tax filing 

forms. 

Figure 2: Overview of EZ/EC Funding Streams for Economic Development Projects 

Involving Businesses 

For related GAO products on the EZ/EC program, see 

HUD / USDA / HHS IRS State tax agency

City that has been

designated as an EZ or a EC

Administering

nonprofit corporation 

Business

Receives assistance in the form of grants, loans, and tax incentives

Source: GAO analysis of prior reports, and HUD and USDA information.

• Empowerment Zone and Enterprise Community Program: 

Improvements Occurred in Communities, but the Effect of the Program 

Is Unclear. GAO-06-727. (Washington, D.C.: Sept. 22, 2006), and 

• Community Development: Federal Revitalization Programs Being 

Implemented, but Data on the Use of Tax Benefits Are Limited. GAO-04-

306. (Washington, D.C.: March 5, 2004). 

Page 41 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix II: Description of the Nine Large

Federal Economic Development Programs 

with Nonrelocation Provisions

The WIA Adult and Dislocated Workers programs provide a variety of 

services to individuals, including help with job searches, skills assessment, 

and occupational training. The Adult and Dislocated Workers programs 

provide similar services, but differ in their eligibility requirements.3

 The 

Youth program is designed to prepare high school students for 

employment or postsecondary education. All three programs require that 

states and local areas use a one-stop center approach, which consolidates

16 categories of programs under four agencies (Labor, Education, HHS, 

and HUD) to provide services for several employment and training 

programs. In addition to employee services, state and local workforce 

investment boards may use WIA funds from the three programs to provide 

services to employers, including helping employers identify and recruit job 

candidates.4

 States and local boards can also offer various job training 

programs, such as classroom-based, on-the-job, or customized training to

meet employer needs.5

 According to CFDA, fiscal year 2006 estimated 

obligations for the WIA Adult, Dislocated Workers, and Youth programs 

were $857 million, $1.181 billion, and $926 million, respectively. 

Labor oversees all three WIA programs, but states and local boards have 

flexibility over how they use WIA funds. WIA specifies a different funding 

source for each of the Act’s main clients—youth, adults, and dislocated 

workers. Labor distributes WIA funds to states and states distribute funds 

to local areas based on specific formulas that account for unemployment 

(see fig. 3 below for an overview of the three WIA program funding 

streams). Labor allots 100 percent of the adult and youth funds and 80 

percent of the dislocated worker funds to states (the Secretary of Labor 

sets aside 20 percent of the dislocated worker funds primarily for national 

emergency grants, but these funds can be used for other job training 

purposes).6

 The states can then set aside up to 15 percent of the funds as 

discretionary funds to support state employment activities. (For the 

dislocated worker program, the state can set aside no more than 25 

percent of the funds for rapid response activities, such as notifying 

Labor WIA Adult, 

Dislocated Workers, 

and Youth Programs 

 3

The Adult program serves all adults over the age of 18, while the Dislocated Workers

program targets adults who have been laid off from a job or are displaced homemakers. 

4

Each of approximately 600 local workforce areas throughout the country has a local 

workforce investment board that administers WIA activities within that area. 

5

For customized job training, an employer must pay at least 50 percent of the training costs. 

6

This money also can be used for demonstrations and technical assistance, but at least 85 

percent of the 20 percent set-aside must be used for national emergency grants. 

Page 42 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix II: Description of the Nine Large

Federal Economic Development Programs 

with Nonrelocation Provisions

workers on how to access unemployment and one-stop center benefits in 

the event of mass layoffs.) 

Figure 3: Overview of WIA Adult, Dislocated Workers, and Youth Funding Streams

The remainder of the funds are distributed to local areas based on a 

formula. Local workforce investment boards, in turn, may provide services 

to businesses. Businesses are generally connected to these services 

through one-stop career centers. 

For related GAO products on the Workforce Investment Act, see 

Federal WIA funds

Source: GAO analysis.

Youth

Dislocated workers

(National emergency grants,

demonstrations, and

technical assistance)

100% distributed

to states by formula

80% distributed

to states by

formula; 20% for

Secretary of

Labor’s reserve

Businesses

can access

WIA-funded 

services, 

including 

job training

S services tatewide

activities

Substate

funds

(distributed

to local areas

by formula)

Adults

85% 85% 60%

State rapid

response

25%

15% 15% 15%

• Workforce Investment Act: Labor and States Have Taken Actions to 

Improve Data Quality, but Additional Steps Are Needed. GAO-06-82. 

Washington, D.C.: November 14, 2005; 

• Workforce Investment Act: Substantial Funds Are Used for Training, but 

Little is Known Nationally About Training Outcomes. GAO-05-650. 

Washington, D.C.: June 29, 2005; and

• Workforce Investment Act: Exemplary One-Stops Devised Strategies to 

Strengthen Services, but Challenges Remain for Reauthorization. GAO03-884T. Washington, D.C.: June 18, 2003. 

Page 43 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix II: Description of the Nine Large

Federal Economic Development Programs 

with Nonrelocation Provisions

SBA’s 504 loan program provides businesses with long-term, fixed-rate 

financing for major fixed assets, such as land, buildings, and machinery 

and equipment. To qualify for an SBA loan guarantee, a project must meet 

job creation or other community development goals, such as increasing 

the number of minority-owned businesses in an area. For the job creation

requirement, a business must generally create or maintain one job for 

every $50,000 in SBA assistance. 

While SBA administers the 504 loan guarantee program, it relies on 

development companies to originate 504 loans. SBA participates in the 504

loan program by guaranteeing loans that certified development companies 

(CDC) make. CDCs generally are private nonprofit corporations 

established to contribute to the economic development of their 

communities. For a typical 504 loan project, the borrower (a business) 

must cover at least 10 percent of a project’s costs, a private third-party 

lender provides at least 50 percent of project costs, and a CDC provides up 

to 40 percent of project costs. SBA guarantees 100 percent of the CDC’s 

portion of the loan. According to SBA, in fiscal year 2006, the agency

provided 504 program guarantees totaling $5.7 billion. 

USDA’s B&I program seeks to improve the economic and environmental 

climate in rural communities by providing guarantees on loans private 

lenders make to borrowers that meet certain economic development 

criteria, such as creating employment or encouraging the development and 

construction of renewable energy systems. The program finances business 

and industry acquisition, construction, conversion, expansion, and repair 

in rural areas. Loan proceeds can be used to finance the purchase and 

development of land, supplies and materials, and start-up costs for rural 

businesses. 

USDA administers the B&I program through field offices located in each of 

the states. A borrower first secures a loan from a USDA-approved private 

third-party lender. The borrower then applies to USDA for a B&I loan 

guarantee. USDA will evaluate the application and make a determination 

on whether the borrower is eligible and the proposed loan is for an eligible

purpose, there is reasonable assurance of repayment ability, there is 

sufficient collateral and equity, and the proposed loan complies with all 

applicable statutes and regulations. USDA will notify the lender in writing 

if it is unable to guarantee a loan. USDA also works with the lender to 

negotiate the percentage of guarantees, but USDA can guarantee up to 80 

percent of loans for $5 million or less, 70 percent of loans between $5 and 

$10 million, and 60 percent of loans exceeding $10 million. According to 

SBA 504 Loan 

Program 

USDA B&I Program 

Page 44 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix II: Description of the Nine Large

Federal Economic Development Programs 

with Nonrelocation Provisions

USDA, in fiscal year 2006, the B&I program guaranteed 350 loans with a 

face-value of $766.3 million. 

Page 45 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix III: Comments from the Department Appendix III: Comments from the of Labor 

Department of Labor 

 Page 46 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix III: Comments from the Department 

of Labor 

 Page 47 GAO-07-1005 Restricting Federal Funds for Employer Relocation
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 48 GAO-07-1005

Appendix IV: GAO Contact and Staff 

Acknowledgments 

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

In addition to the above contact, Harry Medina, Assistant Director; 

Meghana Acharya; Dianne Blank; Bonnie Derby; Ronald Ito; Terence Lam; 

John McGrail; Carl Ramirez; Barbara Roesmann; Paul Schmidt; Michael 

Springer; and Kathryn Supinski made key contributions to this report. 

Restricting Federal Funds for Employer Relocation

GAO Contact 

Staff 

Acknowledgments 

(250315) 
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