FEDERAL REAL 

PROPERTY

Government-wide 

Building-Disposal 

Data Generally 

Reliable, but 

Opportunities for 

Further Improvements 

Exist

Report to Congressional Requesters

March 2017

GAO-17-321

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-321, a report to 

congressional requesters 

March 2017

FEDERAL REAL PROPERTY

Government-wide Building-Disposal Data Generally 

Reliable, but Opportunities for Further Improvements 

Exist

What GAO Found

GAO’s analysis showed that government-wide data were generally reliable for 

reporting on real property disposals for fiscal years 2014 and 2015.

• The General Services Administration’s (GSA) Federal Real Property Profile 

(FRPP) serves as the building inventory database for most of the largest 

federal agencies. FRPP’s data on real property disposals were generally

complete, reasonable, and internally consistent, based on GAO’s guidance 

for assessing data reliability. For example, the disposal date, disposal 

method, and buildings’ square footage data generally met these criteria.

• The Office of Management and Budget’s (OMB) reporting of FRPP disposal 

data for fiscal years 2014 and 2015 was also generally reliable. Based on 

analysis of FRPP data, GAO was able to replicate OMB’s reported numbers

on building disposals, despite minor inconsistencies. GAO identified three 

minor inconsistencies in its analysis and OMB’s reporting, all of which led to 

some over-reporting of building disposals. For example, the data showed 134

buildings as disposed of in multiple years. Given that these inconsistencies 

resulted in small differences in the number of buildings reported, GAO 

determined that the inconsistencies did not affect the overall reliability of 

government-wide reporting of disposal data.

OMB, GSA, and selected federal agencies have taken steps to improve 

government-wide real-property data and additional opportunities exist to make 

further improvements to data and reporting on disposed buildings. For example, 

OMB issued a government-wide memo requiring agencies to implement datavalidation and verification checks when submitting annual FRPP data. GSA 

issued guidance that should help agencies identify data anomalies. The three 

selected agencies have taken steps, such as updating their real-property 

databases and reporting guidance, to improve the reliability of their real property 

data. GSA has also taken steps to improve disposal data specifically. For 

example, GSA has addressed one of the inconsistencies GAO found, wherein 

agencies reported disposals with a disposal date from a previous reporting year. 

Regarding a second inconsistency that GAO identified wherein agencies can 

report the same building as disposed of multiple times, GSA officials responded

that they intend to address this issue by adding a data validation procedure to 

prevent this reporting error in the future. However, GSA did not give details on 

how it would accomplish this step especially in light of several other concurrent 

initiatives under way. Without such a control in place, disposals can be 

overstated and agencies might make decisions based on data that could be 

more accurate. A third inconsistency, wherein OMB used FRPP data differently 

in reporting fiscal year 2014 disposals than in fiscal year 2015, led to OMB’s

including 207 non-federally owned buildings in its reporting of domestic federal 

building reductions. OMB staff stated that they did not have a procedure in place 

to verify with GSA that the summary data used in fiscal year 2015 only included

federally owned buildings and were suitable for reporting on the progress of 

reducing the federal footprint. Thus, OMB did not precisely represent what it

intended to measure. As the Reduce the Footprint policy calls for OMB to 

continue to report annually on these data, it will be important to ensure that 

Congress and other stakeholders receive the most accurate data available. 

View GAO-17-321. For more information, 

contact David J. Wise at (202) 512-2834 or 

wised@gao.gov.

Why GAO Did This Study

Disposal of unneeded buildings—for 

example through demolition, sale, or

transfer to other federal agencies—has

the potential to save the government 

millions of dollars. To this end, OMB 

has developed policies to reduce

space in federal buildings and identify 

buildings for disposal. Recent progress 

notwithstanding, GAO’s body of work 

on real property has found limitations 

in the overall reliability of data in GSA’s 

government-wide database. OMB has 

reported on the status of federal real 

property disposals for fiscal years 2014 

and 2015. 

GAO was asked to examine the 

reliability of the data used to report 

disposals and any efforts to improve 

the data. This report assesses (1) the 

reliability and reporting of governmentwide disposal data for fiscal years 

2014 and 2015, and (2) steps OMB, 

GSA, and three selected agencies

have taken to improve disposal data.

GAO analyzed the most recent FRPP 

data, agency documents, and 

interviewed OMB, GSA, and agency 

officials. GAO selected the 

Departments of Agriculture, Energy, 

and the Interior based on the highest 

numbers of disposed buildings.

What GAO Recommends

GAO recommends (1) that GSA 

implement a data validation 

procedure to prevent reporting a

building as disposed of multiple 

times and (2) that OMB, in

coordination with GSA, establish a 

procedure to verify that its reports 

include data as intended. GSA and 

OMB agreed with GAO’s 

recommendations and identified 

steps to implement them.
Page i GAO-17-321 Federal Real Property

Letter 1

Background 4

Government-wide Data Were Generally Reliable for Reporting on 

Real Property Disposals in Fiscal Years 2014 and 2015 7

Federal Agencies Have Taken Steps to Improve Governmentwide Real Property Data and Additional Opportunities Exist to 

Improve Data and Reporting on Disposed Buildings 10

Conclusions 17

Recommendations for Executive Action 17

Agency Comments 18

Appendix I Buildings by Disposal Method, Fiscal Years 2014 and 2015 21

Appendix II Disposed Properties by Building Type in Fiscal Years 2014 and 2015 22

Appendix III Objectives, Scope, and Methodology 24

Appendix IV Comments from the General Services Administration 29

Appendix V GAO Contact and Staff Acknowledgments 30

Tables

Table 1: GAO’s Analysis of Office of Management and Budget’s 

(OMB) Reporting on Disposed Federal Buildings, Fiscal 

Years 2014 and 2015 9

Table 2: Domestic, Federally Owned Buildings by Disposal 

Method, Fiscal Years 2014 and FY2015 21

Table 3: Domestic, Federally Owned Disposals by Building Type, 

Fiscal Years 2014 and 2015 22

Contents
Page ii GAO-17-321 Federal Real Property

Figures

Figure 1: Examples of Vacant Federally Owned Buildings and 

Warehouses in Washington, D.C. 4

Figure 2: Federal Real Property Profile Validation and Verification 

Process 12

Abbreviations

CFO Chief Financial Officer 

FRPP Federal Real Property Profile

GSA General Services Administration

O&M operations and maintenance

OMB Office of Management and Budget

OPM Office of Personnel Management

V&V validation and verification

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

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

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

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

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-321 Federal Real Property

441 G St. N.W.

Washington, DC 20548

March 2, 2017

Congressional Requesters

The federal government is the largest real property owner in the United 

States with a vast and complex inventory costing billions of dollars 

annually to operate and maintain. As of September 30, 2015, this real 

estate portfolio included approximately 240,000 federally owned buildings 

that are under the custody and control of the 24 civilian and defense Chief 

Financial Officer (CFO) Act agencies in the United States and U.S. 

territories.1 In this time of fiscal constraint, the Administration and 

Congress have taken an interest in the disposal of unneeded buildings 

through demolition, sale, and transfer to other federal agencies that need 

them. Such disposals have the potential to save the government and 

taxpayers millions of dollars. In 2003, we added “Managing Federal Real 

Property” to our High Risk List, in part due to long-standing challenges 

federal agencies face in managing their real property, including disposal 

of excess and underutilized properties and collecting and reporting 

reliable real-property data.2 For example, in July 2014, we found that the 

data supporting office and warehouse space reductions in fiscal years 

2012 and 2013 were not reliable. Further, we testified in 2016 that the 

unreliable data could result in a potential overstatement of the progress 

made in reducing the federal government’s real property footprint.3 An 

official from the Office of Management and Budget (OMB) testified in 

June 2015 and in September 2016 on government-wide building 

 1

This number is based on data reported to the Federal Real Property Profile (FRPP) 

database by federal agencies subject to the CFO Act of 1990 as required by Executive 

Order 13327. CFO Act agencies are executive branch agencies identified in 31 U.S.C. § 

901(b). Fiscal year 2015 data are the most recent available. Agencies begin preparing 

their inventories for submission each October and submit them to FRPP each December 

based on their inventories at the end of the prior fiscal year. 

2

GAO, High-Risk Series: Progress on Many High-Risk Areas, While Substantial Efforts 

Needed on Others, GAO-17-317 (Washington D.C.: Feb. 15, 2017).

3

GAO, Federal Real Property: Efforts Made, but Challenges Remain in Reducing 

Unneeded Facilities, GAO-16-869T (Washington, D.C.: Sept. 23, 2016). 

Letter
Page 2 GAO-17-321 Federal Real Property

disposals.4 The Reduce the Footprint policy calls for OMB to continue to 

provide annual updates on federal real property disposals.5 In 2012, we

found that a lack of reliable data makes it difficult to accurately measure 

the amount of excess and unneeded property.6 The General Services 

Administration (GSA) has taken some important steps to improve the 

capacity of the Federal Real Property Profile (FRPP) to allow agencies to 

better record data; however, questions remain about the accuracy of data 

collected and reported.

You asked us to examine the reliability of the data used to report 

disposals and any efforts to improve these data. This report assesses (1) 

the reliability of government-wide data and reporting on domestic, 

federally owned buildings’ disposal data in fiscal years 2014 and 2015 

and (2) steps OMB, GSA, and selected CFO Act agencies have taken to 

improve disposal data.

To assess the reliability of government-wide reporting on domestic, 

federally owned buildings’ disposal data reported in fiscal year 2014 and 

fiscal year 2015, we examined the disposal date, disposal method, 

square footage, and annual operations and maintenance (O&M) data 

fields within the FRPP database to determine whether the data were 

complete, within reasonable ranges, and internally consistent (e.g., 

federally owned buildings reported as disposed would not be listed as 

disposed of through “lease termination”). We limited our scope to fiscal 

years 2014 and 2015 to be consistent with the source data used in the 

recent OMB testimonies. We compared our findings to data reliability 

standards contained in Standards for Internal Control in the Federal 

Government7 and our guidance for assessing the reliability of computer 

 4

David Mader, Controller of the Office of Management and Budget, testimony before 

Senate Committee on Homeland Security and Governmental Affairs, 114th Cong., 1st sess. 

(June 16, 2015) and David Mader, Controller of the Office of Management and Budget, 

testimony before the House Committee on Oversight and Government Reform, 

Subcommittee on Transportation and Public Assets, 114th Cong., 2nd sess. (Sept. 23, 

2016).

5

OMB, Implementation of OMB Memorandum M-12-12 Section 3: Reduce the Footprint, 

Management Procedures Memorandum No. 2015-01 (Washington, D.C.: Mar. 25, 2015)

6

GAO, Federal Real Property: National Strategy and Better Data Needed to Improve 

Management of Excess and Underutilized Property, GAO-12-645 (Washington, D.C.: June 

20, 2012)

7

GAO, Internal Control: Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). 
Page 3 GAO-17-321 Federal Real Property

processed data, as discussed later in the report.8 We limited our review to 

selected disposal-related data fields, and as such, our results are not 

generalizable to all FRPP data fields. To assess the reliability of OMB’s 

reporting of domestic building disposals, we examined information 

sources and methods GSA used to calculate the number of disposed 

buildings, reductions in square footage, and savings in O&M for fiscal 

years 2014 and 2015 and replicated the data OMB reported.9 We then 

applied internal control standards to determine whether OMB 

appropriately reflected the FRPP data in its June 2015 and September 

2016 testimonies.

To assess steps OMB, GSA, and selected CFO Act agencies have taken 

to improve the reliability of reported FRPP data since the fiscal year 

2014’s reporting cycle, we interviewed OMB and GSA officials as well as 

real property officials at a non-generalizable selection of three civilian 

agencies—the United States Department of Agriculture (Agriculture), the 

Department of Energy (Energy), and the Department of the Interior 

(Interior)—with the highest numbers of disposed buildings during the 

evaluation period. We reviewed guidance and documentation from the 

selected agencies to understand their methods for collecting, reporting, 

and validating real-property building disposals. Further, we reviewed 

OMB and GSA guidance and documentation to determine recent steps 

they have taken to improve FRPP data reliability. We also examined the 

methods agencies used to dispose of their buildings and the types of 

buildings agencies disposed of in fiscal year 2014 and fiscal year 2015 

(see apps. I and II, respectively, for these analyses). Further information 

on our scope and methodology can be found in app. III. 

We conducted this performance audit from April 2016 to March 2017 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 8

GAO, Assessing the Reliability of Computer-Processed Data, GAO-09-680G 

(Washington, D.C.: July 2009).

9

For the purposes of this report, we limited our review to buildings located in the United 

States and U.S. territories. GSA’s guidance for real-property inventory reporting defines a 

building as “a constructed asset that is enclosed with walls and a roof that provides space 

for agencies to perform activities or store materials as well as provides space for people to 

work in.”
Page 4 GAO-17-321 Federal Real Property

The federal government owns and leases hundreds of thousands of 

buildings and permanent structures across the country that cost billions of 

dollars annually to operate and maintain. Federally owned buildings range 

from multi-story buildings located in urban centers to remotely located 

storage facilities in national parks or national forests. Federally owned 

buildings are used for offices, warehouses, schools, hospitals, housing, 

data centers, and laboratories, among others uses. Our prior work has 

found that when these types of buildings remain vacant, they may be 

good candidates for disposal or re-use for another agency (see fig. 1).

Figure 1: Examples of Vacant Federally Owned Buildings and Warehouses in Washington, D.C.

Note: Buildings pictured from left to right: The Cotton Annex, held by the General Services

Administration (GSA), a vacant GSA warehouse, and a vacant building on the St. Elizabeth’s 

Campus, held by GSA and planned for development as part of the Department of Homeland 

Security’s headquarters consolidation.

Within the executive branch, OMB and GSA provide leadership in 

managing federal real property.

• As the chief management office for the executive branch, OMB is 

responsible for overseeing how federal agencies devise, implement, 

manage, and evaluate programs and policies.

• OMB develops and provides direction, such as issuing policies and 

memorandums, to federal agencies on real property management 

matters.

• OMB reports the progress of agencies’ efforts in freezing and 

reducing the federal real property footprint.

Background
Page 5 GAO-17-321 Federal Real Property

• GSA acquires, manages, and disposes of federally owned real 

property for which it has custody and control. The Federal Property 

and Administrative Services Act of 1949, as amended, provides GSA 

the authority to dispose of property for most federal entities and 

mandates the process for doing so.

• GSA’s Office of Government-wide Policy is responsible for identifying, 

evaluating, and promoting best practices to improve the efficiency of 

management processes. In this policy role, GSA also provides 

guidance for federal entities and publishes performance measures.

Established in 2004 in response to requirements in Executive Order 

13327, FRPP is a single comprehensive database that contains 

information on federal real property worldwide, including disposal 

information, and is maintained by GSA.10 The 24 CFO Act agencies are 

required to report their real property data on an annual basis.11

Government decision makers—including Congress, OMB, and 

agencies—can use FRPP data to understand the nature, use, and extent 

of the federal real-property inventory. In its June 2015 and September 

2016 testimonies to Congress on agencies’ progress in implementing 

OMB’s Freeze the Footprint initiative, OMB used FRPP data to report on 

domestic, federally owned building disposals.

Since 2012, OMB has undertaken several initiatives and issued guidance 

to federal agencies to improve the management of federal real property 

and address long-standing issues. In March 2015, OMB introduced the 

National Strategy for Efficient Use of Real Property to improve federal 

utilization of the real property portfolio. The National Strategy adopts a 

policy framework intended to improve the cost effectiveness and 

efficiency of the federal real-property portfolio: it aims to freeze federal 

real-property growth and identifies policy actions to measure the cost and 

utilization of real property assets and reduces the size of the federal real 

 10Executive Order Number 13327 established the Federal Real Property council (FRPC) 

and required the FRPC to work with GSA to establish and maintain a single, 

comprehensive database describing the nature, use, and extent of federal real property 

under the control and custody of the executive branch agencies. FRPC created the FRPP 

to meet this requirement. Exec. Order No. 13327, Federal Real Property Asset 

Management, 69 Fed. Reg. 5997 (Feb. 6, 2004). 

11In addition to the CFO Act agencies, some agencies voluntarily report to FRPP. This 

reporting may not be as consistent since these agencies are not required to report. For 

example, the United States Postal Service has significant real-property holdings, but is not 

a CFO Act agency; therefore, it is not required to submit, and has not recently submitted, 

real property data to the FRPP. 
Page 6 GAO-17-321 Federal Real Property

property portfolio. In March 2015, OMB also issued the “Reduce the 

Footprint” policy, which directed CFO Act agencies to establish targets for 

the reduction of office and warehouse space and for the disposal of 

federally owned buildings beginning in fiscal year 2016. Further, in 

December 2016, real-property reform legislation was enacted that could 

address some of the long-standing issues pertaining to excess and 

underutilized property. For example, the Federal Asset Sales and 

Transfer Act of 2016 established a commission to identify opportunities 

for the federal government to reduce its inventory of civilian real property 

and reduce its costs.12 In addition, the Federal Property Management 

Reform Act of 2016 codified the Federal Real Property Council to ensure 

efficient and effective real-property management while reducing costs to 

the federal government. The act requires executive branch agencies to 

annually submit to the Federal Real Property Council a report on all 

excess and underutilized real property that is in the inventory of each 

executive agency, among other things.

13

Our body of work on federal real property over the past 10 years has 

found that FRPP data quality is limited and could be improved. We 

previously reported that FRPP data can provide reliable background 

information on the real property portfolio and that data agencies submit 

match the data contained in the FRPP database.14 GSA employs a 

number of data reliability measures within FRPP to help agencies report 

reliable real-property data—for example, FRPP can flag some errors such 

as numbers that are outside of a reasonable range (e.g., a negative 

number for the operating costs), improperly formatted data, and blank 

data elements. However, we previously found certain data within FRPP, 

such as annual O&M costs, may be unreliable because agencies do not 

report this data accurately and consistently even though federal realproperty reporting guidance requires them to certify the data’s accuracy.15

In March 2016, we reported on limitations in the usefulness of FRPP data 

due to inconsistencies in collecting and reporting data across agencies, 

and a lack of transparency into the limitations of the data. We 

recommended that GSA, along with OMB and federal agencies, assess, 

analyze, and identify any limitations in how agencies collect and report 

 12Pub. L. No. 114-287, 130 Stat. 1463 (Dec. 16, 2016).

13Pub. L. No. 114-318, 130 Stat. 1608 (Dec. 16, 2016).

14GAO-16-275 and GAO-12-645. 

15GAO-16-275.
Page 7 GAO-17-321 Federal Real Property

FRPP data.16 GSA partially concurred with this recommendation and is 

currently working to implement it, as described later in this report. 

Our analysis of FRPP found that disposal data were generally reliable for 

domestic, federally owned buildings (hereafter referred to as “buildings”) 

for fiscal years 2014 and 2015. While reliable data must be reasonably 

complete and accurate and meet the intended purposes, this finding does 

not mean the data are error-free.17 Errors are considered acceptable 

when they are not substantial enough to cause a reasonable person, 

aware of the errors, to doubt a finding, conclusion, or recommendation 

based on the data. For example, as described below, we found a few 

instances of buildings with square footage outside reasonable ranges; 

however, we determined these errors did not have a substantial effect on 

the overall reported disposal data. For the purposes of this report, we 

determined that the different elements of disposal data in the FRPP 

database (e.g., disposal date, disposal method, square feet, and annual 

O&M costs) were generally complete, within reasonable ranges, and 

internally consistent. Specifically, for fiscal years 2014 and 2015, we 

found the following pertaining to the completeness, reasonableness, and 

internal consistency of the data, based on our data reliability guidance:

• Completeness of the data: All of the buildings reported as disposed of 

included values for the disposal date, square feet, and annual O&M 

cost data fields. Similarly, all of the buildings disposed of by sale had 

a corresponding sale value reported.

• Reasonableness of the data ranges: Nearly all of the data fields we 

reviewed were within reasonable ranges. For instance, using a square 

footage value of under 1 as a proxy for a likely error, we found 6 of 

approximately 7,500 total disposed buildings in fiscal year 2014 to 

have a reported square footage value of less than 1.18 In fiscal year 

2015, we found 2 of nearly 4,800 buildings with reported square 

footage values of less than 1. In addition, we did not find any O&M 

data fields below zero. Of approximately 7,500 buildings reported 

disposed of in fiscal year 2014, 134 had disposal dates outside of 

 16GAO-16-275. 

17GAO-09-680G.

18FRPP guidance states that numeric values for square feet must be greater than zero. 

Government-wide 

Data Were Generally 

Reliable for Reporting 

on Real Property 

Disposals in Fiscal 

Years 2014 and 2015
Page 8 GAO-17-321 Federal Real Property

fiscal year 2014, and all of the buildings reported in fiscal year 2015 

had dates that fell within the fiscal year.

• Internal consistency: Nearly all of the owned buildings’ disposal 

records in our review included methods of disposal consistent with 

common categories (e.g., sold, transferred, conveyed, or demolished) 

and all of the leased buildings disposed of during the review period 

were disposed of in ways consistent with leasing (e.g., lease 

termination, lease expiration, other). However, we found a large 

proportion of building disposals—nearly 50 percent—disposed of by 

“other” means in fiscal year 2014. Selected agencies explained to us 

that no other disposal categories applied to those properties in that 

year and our analysis mostly concurred in these cases (see app. I for 

more details on this analysis).

OMB’s reporting of FRPP data was also generally reliable. To gauge the 

progress on the Freeze the Footprint initiative, OMB used FRPP data to 

report on the overall progress of the disposal of federal real property. 

OMB reported the number of disposed buildings along with the 

associated square footage and annual O&M costs for fiscal years 2014 

and 2015 in its June 2015 and September 2016 testimonies to Congress. 

Beginning in fiscal year 2017, the Reduce the Footprint initiative calls for 

OMB to report annually on progress agencies make toward meeting 

annual disposal targets. Using FRPP data, we were able to replicate 

OMB’s reported data, despite minor inconsistencies in reporting. We 

found slightly lower numbers for the number of buildings, square feet, and 

annual O&M costs for both fiscal years 2014 and 2015, ranging from 2 to 

10 percent lower (see table 1). We traced the differences in our analysis 

and the data OMB reported and we identified three minor inconsistencies, 

all of which led to some over-reporting of building disposals; we discuss 

this over-reporting in more detail later in this report.

• First, OMB reported FRPP data that contained buildings with a 

disposal date from another reporting year.

• Second, OMB reported FRPP data that contained buildings disposed 

of in multiple reporting years (i.e., counting a building more than 

once).

• Third, in fiscal year 2015, OMB reported FRPP data that contained 

buildings other than those owned by the federal government.

Given that these inconsistencies resulted in minor differences in the 

number of building disposals, we determined that they did not affect the 

overall reliability of the government-wide disposal data.
Page 9 GAO-17-321 Federal Real Property

Table 1: GAO’s Analysis of Office of Management and Budget’s (OMB) Reporting on Disposed Federal Buildings, Fiscal Years 

2014 and 2015

Fiscal year 2014 Fiscal year 2015

FY 2014 

Number of 

buildings

Square Feet 

(in millions)

Annual O&M 

Costs (in millions)

FY 2015 

Number of 

buildings

Square feet 

(in millions)

Annual O&M 

costs (in 

millions)

Disposed buildings 

reported by OMB 

7,358 47.1 17.2 4,898 24.8 46.1

(-) Buildings with disposal 

date from another 

reporting year

134 1.2 1.3 0 0 0

(-) Buildings reported 

disposed in multiple 

reporting years

11 0.1 0.5 121 0.6 0.7

(-) Buildings other than 

federally owned

0 0 0 207 0.9 0.3

Disposed buildings 

(FRPP data)

7,213 45.8 15.4 4,570 23.3 45.1

Percentage difference, 

FRPP data compared to 

OMB reporting

-2% -3% -10% -7% -6% -2%

Source: GAO analysis of fiscal years 2014 and 2015 FRPP data and OMB’s reporting. | GAO-17-321
Page 10 GAO-17-321 Federal Real Property

Our work found that the federal government has demonstrated continued 

commitment to improving the management of federal real property by 

executing a number of reform efforts, many of which should improve 

federal real property data, as described below. For example, in addition to 

OMB’s National Strategy, which calls for data quality improvements and 

identifies actions to reduce the size of the federal real-property portfolio,19

OMB also issued a government-wide memo in January 2016 requiring all 

CFO Act agencies to begin implementing standard data validation and 

verification checks when submitting their annual FRPP data to GSA 

beginning in fiscal year 2017.20 GSA also has taken steps intended to 

improve real property data. These combined efforts should improve 

government-wide data on building disposals.

• In response to the January 2016 OMB memo, GSA issued its Federal 

Real Property Data Validation and Verification Guidance in May 2016. 

The data validation and verification (V&V) guidance establishes a third 

step—called anomaly resolution—in the V&V process (see fig.2). In 

anomaly resolution, agencies investigate whether the underlying data 

flagged as anomalies are accurate or inaccurate and take action to 

 19OMB, National Strategy for the Efficient Use of Real Property 2015–2020: Reducing the 

Federal Portfolio through Improved Space Utilization, Consolidation, and Disposal 

(Washington, D.C.: Mar. 25, 2015). 

20OMB, Improving Federal Real Property Data Quality—Required Data Validation and 

Verification Procedures (Washington, D.C.: Jan. 28, 2016). 

Federal Agencies 

Have Taken Steps to 

Improve Governmentwide Real Property 

Data and Additional 

Opportunities Exist to 

Improve Data and 

Reporting on 

Disposed Buildings

OMB, GSA, and Selected 

Agencies Have Taken 

Steps to Improve 

Reliability of Governmentwide Real Property Data 

That Should Also Help 

Improve Disposal Data 
Page 11 GAO-17-321 Federal Real Property

address them. For example, if the FRPP V&V process flags as an 

anomaly an agency’s office building as 2 square feet in size, the 

agency is required to investigate whether the underlying data is either 

correct or incorrect.21 The agency’s CFO must then certify and 

support that all identified anomalies are validated or corrected before 

the next reporting cycle (October 15 of each year). Implementation of 

the new V&V guidance and the anomaly resolution process began 

with the December 2016 data submissions and should help to 

improve the reliability of future data that agencies submit to FRPP.22

• In August 2016, GSA issued a detailed user guide for V&V tools 

described in the May 2016 V&V guidance. GSA completed training 

sessions and demonstrations with agency staff to further familiarize 

them with the system in September 2016.

 21Reported anomalies are not necessarily incorrect. While an anomaly may have an 

underlying data-quality problem, it may also have a legitimate explanation. 

22December 2016 will serve as the baseline for anomaly resolution and measure of data 

accuracy starting in October 2017. On October 15 of every year, agencies are required to 

resolve 100 percent of the anomalies identified in their automated anomaly reports from 

the prior reporting year. 
Page 12 GAO-17-321 Federal Real Property

Figure 2: Federal Real Property Profile Validation and Verification Process

• GSA is also working to help agencies report operating costs more 

uniformly in response to our March 2016 recommendation to improve 

the quality of data entered into FRPP.23 We have consistently found 

that agencies report operating costs differently. For example, not all 

agencies directly calculate O&M costs because some agencies do not 

maintain data on costs for each specific building. For example, the 

Coast Guard estimates O&M costs to be equal to 3 percent of the 

estimated replacement value of the building. We also reported that 

some agencies estimate operating costs for some buildings based on 

their size and other attributes relative to a larger asset within the same 

geographic footprint or facility.24 Similarly, during this review, we 

found that two of the three selected agencies did not directly calculate 

O&M costs before reporting them in FRPP. Specifically, we found that 

Energy tracks maintenance costs at the asset level.

25 Energy also

assigns most of its operating costs across its owned buildings for a 

 23GAO-16-275.

24GAO-16-275.

25Maintenance costs refer to asset level costs for predictive and preventive maintenance, 

surveillance and maintenance, repairs, and renovations accrued.
Page 13 GAO-17-321 Federal Real Property

particular site based on hours of operations and gross square feet.26

Interior officials told us that the agency does not track or assign O&M 

costs at the individual building level (e.g., fueling station or security 

station), because the work is typically completed for the entire, multibuilding site (e.g., a research campus).27 Further, according to Interior 

officials, splitting out the costs by individual buildings would not be 

useful in managing the site and would place unnecessary burden on 

real property managers. For example, they told us that local realproperty managers do not track mowing costs for each of the 

restrooms and security stations at a site—such as at Glacier National 

Park. Rather, Interior’s real property system tracks costs for the entire 

site depending on factors such as the size of the buildings.

• GSA continues to respond to our March 2016 recommendation to 

improve FRPP data quality by deploying an in-depth survey in June 

2016 to better understand the methods CFO Act agencies used to 

collect and prepare data for submission to the FRPP.28 This survey 

focused on the following data elements: operating costs, lease costs, 

repair needs, replacement value, status, and utilization. GSA selected 

these data elements based both on recommendations from federal 

agencies within the Federal Real Property Council and also on the 

findings of our prior reports. In November 2016, GSA completed its 

initial analysis of the FRPP data survey’s results, and officials stated 

that their next step would be to form an inter-agency working group—

comprised of GSA, OMB, and executive branch agencies that 

contribute data to the FRPP—in 2017 to discuss each of the data 

elements and devise an action plan to address the findings of the 

survey. The working group is intended to review the survey results in 

more detail and reach consensus on: 1) changes to the definitions 

and requirements for these data elements in the FRPP data 

dictionary; 2) limitations on the use of the data for cross-agency 

analysis; and 3) best practices and methodologies for reporting these 

data elements. In response to the survey, GSA issued a memo in 

December 2016 to senior real-property officers of the Federal Real 

 26This process is only performed when the operating cost cannot be tracked at the asset 

level. Energy does not allocate natural-gas, central-heat, and central-cooling costs for 

trailers. 

27FRPP is maintained at the asset level for land, buildings, and structures. Some 

disposals include multiple assets in a transaction. For example, a disposal may include 

multiple buildings and the land on which they were built. In that scenario, each land parcel, 

building, and structure is recorded separately as a disposed asset.

28GAO-16-275.
Page 14 GAO-17-321 Federal Real Property

Property Council that included revised definitions for repair needs, 

replacement value, and annual O&M costs to improve the consistency 

and quality of FRPP data within and among agencies. This memo 

also requires CFO Act agencies to implement the revised definitions 

no later than the December 2018 FRPP reporting cycle.

Officials from the three agencies we selected also told us that they have 

taken steps—including updating their real property databases and 

reporting guidance—to improve the reliability of their overall real-property 

data. 

• Agriculture: Agriculture officials told us they modified their realproperty management system in 2016 to align with GSA’s V&V 

requirements to address data anomalies. In August 2016, Agriculture 

also revised its real-property user guide, which describes the required 

data elements for FRPP reporting. In September 2016, Agriculture 

officials told us that they plan to hire contractors to further review the 

department’s data reliability for fiscal year 2017. 

• Energy: In May 2016, Energy added GSA’s V&V requirements to its 

existing V&V procedures. Energy officials told us they updated their

real-property management system to identify a number of common 

anomalies. Although Energy generates anomaly reports at the 

headquarters level before submitting data to FRPP, the real property 

system update allows users to implement anomaly checks through a 

new anomaly-reporting tool, which identifies issues with real property 

data. For example, the anomaly-reporting tool flags outliers, such as 

when the disposition year is a past fiscal year.

• Interior: According to officials, Interior plans to work with the bureaus 

to implement the V&V procedures. In November 2016, Interior 

updated its internal FRPP guidance to incorporate GSA’s new data 

V&V steps. Interior expects the bureaus to implement the new V&V 

procedures for the fiscal year 2016 real-property data it submits and 

address any anomalies in accordance with the guidance.
Page 15 GAO-17-321 Federal Real Property

In addition to improving government-wide real property data, GSA has 

also taken steps to improve disposal data specifically. As described 

above, we found disposal data and reporting to be generally reliable, with 

three minor inconsistencies, one of which GSA has addressed. 

Specifically, we found that GSA has addressed the issue wherein 

agencies reported buildings with a disposal date from another reporting 

year. For example, our analysis showed that approximately 2 percent of 

buildings reported as disposed of in fiscal year 2014 were actually 

disposed of in other years dating back to fiscal year 2001. These 

buildings comprised 1.2-million square feet and included annual O&M 

costs of $1.3 million of those reported in fiscal year 2014 (see table 1). 

Since OMB’s June 2015 testimony, GSA added a data validation 

procedure that prevents agencies from reporting buildings disposed of in 

other years. This new procedure seems to have addressed the issue, as 

we did not find any cases in the fiscal year 2015 data of buildings 

disposed of in other years. In this respect, GSA has improved the 

accuracy of the FRPP database.

Regarding the second inconsistency we identified wherein agencies can 

report the same building disposed of multiple times, GSA intends to 

address this issue. We found 132 buildings that were reported as 

disposed of in fiscal years 2014 and 2015 that had already been reported 

as disposed of in a previous reporting cycle. For the 2015 reporting year, 

121 buildings reported as disposed of (see table 1) were also reported in 

other fiscal years from 2011 through 2014. Our data reliability guidance 

suggests that controls to the data entry process should be in place to 

prevent duplicate reporting.29 When we asked about the cases in which 

buildings were reported as disposed of multiple times, GSA officials told 

us that currently, FRPP does not have a data validation procedure that

prevents agencies from reporting disposals in multiple reporting cycles.

An official also told us that the agencies’ own data V&V procedures may

not identify cases in which agency staff report buildings as disposed of

multiple times. In response, in December 2016, GSA officials asked

agencies to review their current-year submissions to ensure that disposed 

buildings reported this cycle had not been reported as disposed of

previously. GSA officials told us that they intend to add a data validation 

procedure to prevent agencies from reporting buildings as disposed of

multiple times. Finally, GSA officials said that they intend to conduct a 

comprehensive review of all FRPP data-validation procedures. However,

29GAO-09-680G. 

GSA and OMB Have 

Opportunities to Further 

Improve the Reliability and 

Reporting of Disposal 

Data by Addressing Minor 

Inconsistencies 
Page 16 GAO-17-321 Federal Real Property

they did not provide details on how they would accomplish specific plans 

related to addressing the data validation procedure in light of several 

other concurrent initiatives under way. As noted above, GSA has several 

ongoing efforts to improve FRPP data reliability. Ensuring that a data 

validation procedure is put in place is important because without this 

control, building disposals can be overstated. As such, agencies might 

make real property management decisions based on data that could be 

more reliable.

We also found that OMB could further improve the reliability of its 

reporting of federal real-property disposal data. OMB used FRPP data 

differently in reporting fiscal year 2014 disposals than it used in reporting 

fiscal year 2015 disposals; the result was less accurate reporting that 

included some state-owned buildings and leased buildings. For fiscal year 

2014, OMB requested information on domestic, federally owned buildings 

disposed of in that year. In response, GSA conducted an analysis that 

only included domestic, federally owned buildings. Our analysis of fiscal 

year 2014 showed that OMB’s reporting was accurate in this respect (see 

table 1). For fiscal year 2015, OMB used summarized real property data 

from GSA’s FRPP website with slight modifications, excluding buildings 

that were disposed of through transfer to other federal agencies, lease 

expiration, and lease termination. However, this modified summary data 

did not exclude 207 non-federally owned buildings reported among the 

disposed buildings for fiscal year 2015 (see table 1).30 The data reported 

would have been more reliable without the inclusion of these non-federal 

buildings.

OMB staff stated this happened because they did not have a procedure in 

place to verify with GSA, as they noted they should have, that the 

summary data they used in fiscal year 2015 were suitable for the 

purposes of reporting on the progress of reducing the federal footprint. 

Federal standards for internal control state that agencies should have 

procedures in place to help ensure actions are taken to address risks 

such as the risk of reporting inaccurate information.31 Thus, by not having 

a procedure in place to verify that the data OMB used were suitable for its 

purposes, OMB included 207 non-federally owned buildings that it should 

 30These 207 non-federally owned buildings do not represent inconsistencies in the FRPP 

disposal data themselves, but are due to OMB counting disposals of state-owned 

buildings and leased buildings. 

31GAO/AIMD-00-21.3.1
Page 17 GAO-17-321 Federal Real Property

not have, and therefore its reporting of fiscal year 2015 disposals did not 

precisely represent what it intended to measure. As the Reduce the 

Footprint initiative calls for OMB to report annually on these data, it will be 

important to ensure that Congress and other stakeholders receive the 

most accurate data available.

OMB and GSA face a complex task in reporting on and managing data 

agencies submit given the diversity of their real property inventories, 

which range from multistory buildings in urban centers to small, remotely 

located storage facilities in national forests. Reliable data, including 

building-disposal data, are critical to accurately gauge the federal 

government’s progress in disposing of unneeded and excess federal real 

property. OMB, GSA, and selected agencies have taken steps to address 

data reliability and reporting challenges. The combined initiatives (1) of 

OMB’s requirement for CFO Act agencies to implement standard datavalidation and verification checks beginning in fiscal year 2017, (2) of 

GSA’s updated guidance and the expanded capacity of the FRPP to allow 

agencies to enter more complete disposal data, and (3) of selected 

agencies’ development of new processes should lead to improved data 

reliability. As these steps are relatively recent and have not been fully 

implemented, it is too soon to assess progress and the effect, if any, on 

federal real property data in general, and disposal data in particular. 

Additional opportunities exist for OMB and GSA to address insufficient 

controls which resulted in over-counting of domestic, federally owned 

disposed buildings in fiscal years 2014 and 2015. Although we found that 

the government-wide real property data were generally reliable, continued 

improvements in data reliability could lead to more effective real-property 

management decision making.

We are making two recommendations, one to the Administrator of GSA 

and one to the Director of OMB.

To improve the reliability of FRPP disposal data, we recommend that the 

Administrator of GSA implement a data validation procedure to prevent 

reporting the same building disposal multiple times.

To improve the accuracy of reporting on progress in reducing the 

inventory of federal buildings, we recommend that the Director of OMB, in 

coordination with the GSA Administrator, establish a procedure to verify 

that the OMB’s reports include the intended data, such as, reporting 

Conclusions

Recommendations for 

Executive Action
Page 18 GAO-17-321 Federal Real Property

individual buildings only once and reporting only federally owned 

buildings.

We provided a draft of this report to OMB, GSA, and the Departments of 

Agriculture, Energy, and the Interior for review and comment. OMB 

provided oral comments and concurred with our recommendation to 

establish a procedure to verify that OMB’s reports include the intended 

data, such as, reporting individual buildings only once and reporting only 

federally owned buildings. OMB stated that it plans to implement 

procedures to ensure that subsequent data calls to GSA for FRPP data 

include the intended data. OMB also provided technical comments, which 

we incorporated where appropriate. We shared a written summary of the 

oral comments with the principal OMB staff who agreed that the 

information was accurate. GSA concurred with our recommendation to

implement a data validation procedure to prevent reporting the same 

building’s disposal multiple times and provided actions and time frames 

for completion. GSA stated that it will create a new business rule in FRPP 

that will prevent agencies from reporting disposed buildings multiple 

times. This validation will be incorporated in fiscal year 2017 and will be 

active for the fiscal year 2017 reporting cycle and beyond. GSA’s official 

written response is reprinted in appendix IV. The Departments of 

Agriculture and Energy provided technical comments, which we 

incorporated where appropriate. Interior did not have any comments on 

the draft report.

We are sending copies of this report to the appropriate congressional 

committees, the Director of OMB, the Administrator of GSA, and the 

Secretaries of the U.S. Department of Agriculture, the Department of 

Energy, and the Department of the Interior. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov.

Agency Comments 
Page 19 GAO-17-321 Federal Real Property

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

contact me at (202) 512-2834 or wised@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

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

appendix V.

David J. Wise

Director, Physical Infrastructure
Page 20 GAO-17-321 Federal Real Property

List of Requesters

The Honorable Ron Johnson

Chairman

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable James Lankford

Chairman

The Honorable Heidi Heitkamp

Ranking Member

Subcommittee on Regulatory Affairs and Federal Management

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Rob Portman

Chairman

The Honorable Thomas R. Carper

Ranking Member

Permanent Subcommittee on Investigations

Committee on Homeland Security and Governmental Affairs

United States Senate
Appendix I: Buildings by Disposal Method, 

Fiscal Years 2014 and 2015

Page 21 GAO-17-321 Federal Real Property

In fiscal year 2014, Chief Financial Officer (CFO) Act agencies reported 

that they disposed of nearly 50 percent of their domestic, federally owned 

buildings through “other” means (see table 2).

Table 2: Domestic, Federally Owned Buildings by Disposal Method, Fiscal Years 2014 and FY2015

Disposal method 2014 number of 

buildings

2014 percentage of 

buildings

2015 number of 

buildings

2015 percentage of 

buildings

Demolition 2,535 35.09 2,292 48.86

Loss due to Deterioration (New for 2015) N/A N/A 3 0.06

Loss due to Disaster (New for 2015) N/A N/A 14 0.30

Public Benefit Conveyancea 830 11.49 1,254 26.73

Reversion to Prior Owner (New for 2015) N/A N/A 13 0.28

Sale 252 3.49 162 3.45

Otherb 3,607 49.93 953 20.32

Total 7,224 100.00 4,691 100.00

Source: GAO analysis of fiscal years 2014 and 2015 FRPP data. | GAO-17-321

a

Public benefit conveyance refers to buildings that are conveyed to a non-federal entity for public 

benefit. For example, agencies may convey buildings to, among other things, benefit homeless 

assistance programs, health or educational use, or wildlife conservation.

b

The “other” category includes methods of disposal not otherwise categorized.

Because disposals by “other” means composed such a large percentage 

of the total in fiscal year 2014, we asked officials at three selected civilian 

agencies with some of the highest numbers of building disposals in that 

year—the U.S. Department of Agriculture (Agriculture), Department of 

Energy (Energy), and the Department of the Interior (Interior)—to 

describe the disposals through “other” means. The officials explained 

that, in most cases, they categorized these disposals as “other” because 

existing categories did not apply. Some of these buildings reported as 

disposed of by “other” means include portable trailers transferred from 

real property to personal property prior to disposal, and buildings 

transferred to state universities and Native American tribes.1 In fiscal year 

2015, the Federal Real Property Profile (FRPP) included 7 new disposal 

methods—such as loss due to deterioration or natural disaster—so that 

agencies could use these categories instead of the “other” category. 

 1

Real property includes land together with the improvements, fixtures or structures, 

including trailers that are located on the land. Trailers can be disposed of as personal 

property when the underlying land is not part of the disposal. 41 C.F.R. § 102-71.20.

Appendix I: Buildings by Disposal Method, 

Fiscal Years 2014 and 2015
Appendix II: Disposed Properties by Building

Type in Fiscal Years 2014 and 2015

Page 22 GAO-17-321 Federal Real Property

In our analysis of fiscal year 2014 and fiscal year 2015 building disposals, 

we found that family housing1 represented the largest category of 

disposed buildings and that half of the buildings disposed of in fiscal year 

2015 were less than 1,710 square feet (see table 3).

Table 3: Domestic, Federally Owned Disposals by Building Type, Fiscal Years 2014 and 2015

 1

Buildings are categorized based on their predominant use.

Appendix II: Disposed Properties by Building 

Type in Fiscal Years 2014 and 2015

Building type Definition Fiscal year 

2014 number 

of buildings 

Fiscal year 2015 

number of 

buildings

All other Buildings that cannot be classified elsewhere. 946 707

Child care center Stand-alone facility that provides child care services. The 

center cannot be part of a larger building.

0 3

Comfort station/restrooms Asset with toilet and lavatory facilities for public use. May 

include showering facilities.

123 122

Communications systems Buildings used for telephone and telegraph systems, data 

transmission, satellite communications, and/or associated 

with radio towers or other communications facilities.

69 100

Data centers An asset that stores and/or manages server, network, and 

computer or telecommunications equipment.

3 1

Dormitories/barracks Buildings primarily used as dwellings for housing individuals 

(without families/dependents).

186 126

Facility security Stand-alone building used primarily to house security 

personnel that inspect persons, baggage, vehicles, or goods 

entering a campus, facility, or installation. This building is 

stand-alone, not part of another building, and dedicated to 

housing security staff only.

0 91

Family housing Buildings primarily used as dwellings for families/dependents. 

Includes apartment houses, single houses, row houses, 

public housing, military personnel housing, federal employee 

housing, and housing for institutional personnel.

3,411 1652

Hospital Buildings used primarily for furnishing in-patient diagnosis 

and treatment under physician supervision and having 24-

hour-a-dayregistered graduate nursing services. This 

category also includes medical laboratories used for routine 

testing. This category excludes buildings used directly in 

basic or applied medical research.

6 6

Industrial Buildings specifically designed and primarily used for 

production or manufacturing, such as the production or 

manufacture of ammunition, aircraft, ships, vehicles, 

electronic equipment, fish production, chemicals, aluminum, 

and magnesium. Included are buildings that house utility 

plants or utility system components such as pump stations or 

valves.

518 302
Appendix II: Disposed Properties by Building 

Type in Fiscal Years 2014 and 2015

Page 23 GAO-17-321 Federal Real Property

Source: GAO analysis of FRPP data. | GAO-17-321

a

The Department of the Navy disposed of these post office buildings. USPS building disposals are not 

included in table.

Laboratories Buildings used directly in basic or applied research in the 

sciences (including medicine) and in engineering, such as 

medical laboratories; meteorological research laboratories; 

and buildings used in designing, developing, and testing of 

prototypes and processes for chemistry and physics. This 

category excludes medical or industrial laboratories used for 

routine testing.

153 83

Museum Buildings used for the housing and/or display of tangible 

objects or collections for the purpose of displaying said 

objects or collections for public view and benefit on a regular 

basis.

7 13

Navigation and traffic aids Includes buildings that house aircraft or ship navigation and 

traffic aids, such as beacon lights, antenna systems, ground 

control approach systems, and obstruction lighting.

191 215

Office Buildings primarily used for office space or military 

headquarters.

366 348

Other institutional uses Buildings used for institutional purposes other than schools, 

hospitals, and prisons, such as libraries, and chapels. This 

category also includes food preparation and dining facilities, 

buildings housing entertainment and recreational activities, 

and visitor’s centers.

332 215

Outpatient healthcare facility Buildings used primarily for outpatient diagnosis, treatment, 

and therapy. Includes medical, dental, mental health, and 

substance abuse treatment facilities

2 3

Post Officea Buildings or portions of buildings used as a Post Office. 0 2

Prisons and detention centers 4 8

School Buildings used primarily for formally organized instruction, 

such as schools for dependent children of federal employees, 

Indian schools, and military training buildings including 

specialized training facilities.

179 144

Service Buildings used for service activities, such as maintenance 

and repair shops, dry cleaning plants, post exchange stores, 

airport hangars, and buildings primarily used for vehicle 

maintenance and repair.

508 390

Warehouses Buildings used for storage, such as ammunition storage, 

covered sheds, and buildings primarily used for storage of 

vehicles or materials. Also included are underground or earth 

covered ammunition storage bunkers and magazines. This 

category excludes water reservoirs and storage tanks which 

are storage structures.

220 160

Grand Total 7,224 4,691

Median Square Footage 2,514 1,708
Appendix III: Objectives, Scope, and 

Methodology

Page 24 GAO-17-321 Federal Real Property

Our objectives were to assess (1) the reliability of government-wide data 

and reporting on domestic, federally owned buildings’ disposal data in 

fiscal years 2014 and 2015 and (2) steps the Office of Management and 

Budget (OMB), GSA, and selected CFO Act agencies have taken to 

improve disposal data. We found the data to be sufficiently reliable for our 

purposes. Because this review was limited to disposal-related data fields 

in the FRPP, our results are not generalizable to other FRPP data fields.

Reliability and reporting of government-wide disposal data: To assess the 

reliability of government-wide data and reporting on domestic, federally 

owned buildings’ disposal data in fiscal years 2014 and 2015 we (1) 

examined information sources and methods OMB used to report on the 

number of buildings disposed of, square feet reduced, and O&M costs 

avoided for fiscal years 2014 and 2015; (2) analyzed data from GSA’s 

FRPP; (3) replicated the figures OMB used in its June 2015 and 

September 2016 testimonies; and (4) reviewed the data underlying 

OMB’s reported disposals to assess the extent that these data accurately 

reflected the building disposals that were intended to be reported. In 

addition, we interviewed officials from a non-generalizable selection of 

three CFO Act agencies—the Departments of Agriculture, Energy, and 

the Interior—to determine how they assess the reliability of their disposal 

data.1 We sorted fiscal year 2014 FRPP data to determine the civilian 

departments with the highest numbers of disposed buildings and the 

highest O&M costs avoided. We selected these three agencies for review 

based on the fact they were among the top four in at least two of these 

categories. Because we used a judgmental selection methodology, our 

findings are not generalizable to all federal agencies. We also analyzed 

fiscal years 2014 and 2015 FRPP data to learn more about the disposal 

methods used and the types of buildings disposed. 

Before analyzing the FRPP disposal data, we met with GSA officials and 

OMB staff to better understand how they analyzed and reported the 

FRPP data for the period. They told us that OMB relied on GSA analysis 

of FRPP data that included all federally owned buildings in the United 

States and territories reported as disposed of by CFO Act agencies. We 

also obtained FRPP datasets consisting of all civilian and defense 

buildings (358,495 and 351,781 in fiscal years 2014 and 2015, 

respectively), and using the “Real Property Unique Identifier” variable in 

 1

The CFO Act agencies are executive branch agencies identified in 31 U.S.C. § 901(b).

Appendix III: Objectives, Scope, and 

Methodology
Appendix III: Objectives, Scope, and 

Methodology

Page 25 GAO-17-321 Federal Real Property

FRPP as our unit of analysis, we performed the following steps to get to 

the base number of buildings, square feet, and annual O&M costs for our 

analyses. These steps yielded 7,213 domestic, federally owned buildings 

in fiscal year 2014 and 4,570 in fiscal year 2015.

• We excluded all non-building asset records in FRPP such as land and 

non-building structures such as antennae or navigational aids. This 

exclusion left us with all civilian and defense building records.

• We then removed all building records with a value in the “status 

indicator” field other than “disposed,” leaving us with disposed of 

building records.

• We then removed all records of buildings disposed of that had a value 

in the “country name” field other than the following, which left us with 

domestic, disposed building records:

• United States

• Guam

• Northern Marianas Islands

• Puerto Rico

• U.S. Minor Outlying Islands

• Virgin Islands

• We then removed records for buildings that had values in the “legal 

interest indicator” field other than “owned.” This step left us with 

domestic, federally owned disposed-buildings’ records.

• We then removed records where the “reporting agency name” field 

was not a CFO Act agency.

• We then removed the buildings with disposal dates prior to or after the 

fiscal year being reported. For instance, for the fiscal year 2014 data 

set, we only included buildings with disposal dates ranging from 

October 1, 2013 through September 30, 2014.

• We then compared these remaining buildings against previous 

inventories and removed any buildings that had been previously 

reported as disposed.

To assess the reliability of the domestic, federally owned disposed 

buildings’ data, we examined the disposal date, disposal method, square 

feet, and annual O&M fields within the FRPP database to identify the 

frequency of missing data, data anomalies, year-to-year inconsistencies, 

and relational errors. Specifically, we conducted the following electronic 
Appendix III: Objectives, Scope, and 

Methodology

Page 26 GAO-17-321 Federal Real Property

tests on the FRPP disposal data that OMB used to calculate the number 

of buildings disposed, square footage reductions, and savings in O&M 

and assessed the data to determine if they were within reasonable 

ranges, were internally consistent (e.g., owned buildings that were 

reported as disposed would not be disposed through “lease termination”), 

and appeared complete:

• Missing values in the “disposition method,” “disposal date,” “square 

feet,” and “annual operating cost” data fields. We found zero cases of 

missing values in the aforementioned data fields.

• Data field values beyond what we considered reasonable:

• “Square feet” less than 1. We found 6 buildings in the fiscal year 

2014 data and 2 buildings in the fiscal year 2015 data with less 

than 1 square foot.

• “Annual operating and maintenance costs” less than zero. We 

found zero cases of buildings with annual O&M costs less than 

zero.

• “Disposed date” outside of the fiscal year corresponding to the 

report year (i.e., for reporting year 2014, disposal dates should fall 

within fiscal year 2014). We found 134 buildings in the fiscal year 

2014 data with disposal dates prior to fiscal year 2014. All 

reported disposed buildings in the fiscal year 2015 data had a 

disposal date within fiscal year 2015.

• Relational errors:

• If the method of disposal is sale, then a disposal value is also 

supposed to be reported. We tested to identify instances where 

this was not the case. All buildings reported as disposed of by sale 

included a disposal value.

• If the ownership status of the building is leased, then the disposal 

method should be “lease expiration,” “lease termination,” or 

“other.” We tested the data to identify instances where this was 

not the case. All leased buildings in our fiscal year 2014 and 2015 

datasets were reported disposed of by either “lease expiration,”

“lease termination,” or “other.”

• If the ownership status of the building is owned, then the disposal 

method should not be lease expiration or lease termination. We 

tested to identify instances where this was not the case. None of 

the owned buildings in our fiscal year 2014 and 2015 datasets 

were reported disposed of by either “lease expiration” or “lease 

termination.”
Appendix III: Objectives, Scope, and 

Methodology

Page 27 GAO-17-321 Federal Real Property

• Longitudinal errors:

• If a building was reported as disposed of in a reporting year, the 

building should not appear in FRPP in subsequent reporting 

years. We tested to identify instances where this was not the case 

with the fiscal year 2011 through 2015 data available to us. We 

found 132 buildings reported as disposed of in the 2014 and 2015 

reporting years (11 buildings and 121 buildings, respectively) that 

had already been reported as disposed of in previous years. With 

more years of data, we may have found additional cases.

In our analysis of the disposal methods used in fiscal year 2014 and 

2015, we found 3,607 buildings in fiscal year 2014 that were disposed of 

by “other” means or disposed of in a way that could not be categorized 

(see app. I). We reviewed these disposals at three selected agencies 

(Agriculture, Energy, and Interior) to understand how some of these 

buildings were disposed. To avoid putting an administrative burden on the 

agencies, we sent our selected agencies short lists of “other” building 

disposals that were greater than 549 square feet and asked them to 

provide a more detailed description of the disposal method. In addition to 

analyzing these more detailed descriptions of “other” disposals, we 

interviewed officials at these agencies to better understand their internal 

processes for collecting and reporting disposal data.

To further verify disposal information, we attempted to reconcile disposed 

buildings reported in the real property databases with those reported in 

the agencies’ financial accounting systems at the three agencies we 

reviewed. Internal Control Standards require appropriate documentation 

of transactions in a manner that allows documentation to be readily 

available for examination.2 The ability to reconcile an agency’s real 

property and accounting databases would provide confidence as to the 

reliability of the data. We found that, for various reasons, the agencies 

were unable to easily reconcile individual disposed buildings in their real 

property databases with their financial accounting systems. We did not 

request the agencies to perform further analysis, and therefore, this is not 

included in our report.

To assess the reliability of the disposal figures OMB reported based on 

fiscal year 2014 and 2015 data, we first replicated the data OMB used in 

its reporting and then compared them against the figures we arrived at 

based on the criteria GSA officials and OMB staff provided to us

 2

GAO/AIMD-00-21.3.1.
Appendix III: Objectives, Scope, and 

Methodology

Page 28 GAO-17-321 Federal Real Property

(as discussed above). Where we identified differences between our 

analyses and OMB’s reporting of GSA data, we provided the differences 

to both GSA and OMB for comment to ensure that our analysis was 

correct. OMB and GSA officials concurred with the differences we found. 

Steps taken to improve disposal data: To describe steps GSA, selected 

CFO Act agencies, and OMB have taken to improve disposal data, we 

reviewed GSA and OMB guidance related to improving the quality of 

government-wide real property data; we interviewed GSA officials and 

OMB staff to identify any steps taken to improve the quality of disposal 

data; we interviewed officials at Agriculture, Energy, and Interior to 

understand what actions, if any, they have taken to improve their realproperty data quality since the fiscal year 2014 reporting cycle, and we 

reviewed agency documents supporting recent efforts to improve the 

collection, reporting, and validation of building-disposal data.
Appendix IV: Comments from the General 

Services Administration

Page 29 GAO-17-321 Federal Real Property

Appendix IV: Comments from the General 

Services Administration
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 30 GAO-17-321 Federal Real Property

David J. Wise, (202) 512-2834 or wised@gao.gov

In addition to the contact named above, Amelia Shachoy (Assistant 

Director), Tina Paek (Analyst-in-Charge), Russell Burnett, Justin Fisher, 

Hannah Laufe, Steve Rabinowitz, Malika Rice, Minette Richardson, Amy 

Rosewarne, and Dawn Simpson made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100807)
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