FEDERAL 

BUILDINGS

Agencies Focus on 

Space Utilization As 

They Reduce Office 

and Warehouse 

Space

Report to Congressional Requesters

March 2018

GAO-18-304

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-304, a report to 

congressional requesters

March 2018

FEDERAL BUILDINGS

Agencies Focus on Space Utilization As They Reduce 

Office and Warehouse Space 

What GAO Found

Most of the 24 agencies with chief financial officers reported to the Office of 

Management and Budget (OMB) and the General Services Administration (GSA) 

that they planned to consolidate their office and warehouse space and allocate

fewer square feet per employee as the key ways to achieve their space reduction 

targets. For example, the Department of Agriculture reported it will consolidate 

staff from five component agencies in two office buildings. When complete, the 

space allocated per employee will average about 250 square feet down from a 

high of 420 square feet per employee. In taking these actions, the agencies most 

often identified the cost of space reduction projects as a challenge to achieving

their targets. Agencies cited costs such as for space renovations to 

accommodate more staff and required environmental clean-up before disposing 

of property as challenges to completing projects. Some agencies required to 

maintain offices across the country reported that their mission requirements limit 

their ability to reduce their space. 

In fiscal year 2016, 17 of the 24 agencies reported they reduced their space, but 

had varying success achieving their first-year targets. Of the 17 agencies, 9 

exceeded their target and reduced more space than planned, 7 missed their 

target (by anywhere between 2.8 and 96.7 percent), and 1 reduced space, 

despite a targeted increase. Agency officials said that it is not unusual for 

projects to shift to different years and that such shifts could lead to missing

targets one year and exceeding them the next. 

Majority of Agencies Reduced Space in Fiscal Year 2016

GSA has processes to manage the space vacated by agencies that is leased

through GSA. For example, starting in November 2016, GSA started tracking 

agencies’ space release requests centrally to help standardize the process and 

established an e-mail address to which agencies can submit requests. GSA 

relies on regional offices to manage real property in their regions and to identify 

tenants for vacant space or to remove unused space from the inventory. GSA’s

regional officials said regular monitoring and coordinating with agencies 

minimizes the likelihood GSA is caught off guard by a return of space. These 

processes also help them to plan ahead. GSA met its 2016 performance goal to 

have an annual vacant space rate of no more than 3.2 percent in its federally 

owned and leased buildings. However, given the recent implementation of the 

space reduction initiative, it is too early to determine the extent to which agencies 

will return space to GSA prior to the end of their leases and the effect on GSA’s

inventory. 

View GAO-18-304. For more information, 

contact Lori Rectanus at (202) 512-2834 or 

rectanusl@gao.gov.

Why GAO Did This Study

The federal government continues to 

work to reduce its real property

inventory and associated costs. GSA 

provides space for agencies in 

government-owned and commercially

leased buildings. In 2015, the OMB 

issued a memorandum requiring the 24 

agencies with chief financial officers to 

reduce their domestic office and

warehouse space. These agencies are 

required to set annual reduction targets 

for a 5-year time period and update 

their real property plans annually.

GAO was asked to review the 

implementation of this space reduction 

initiative. This report discusses: (1) the

approaches and any challenges the 24

agencies identified to achieving their 

reduction targets for all their domestic 

office and warehouse space; (2) the

extent these agencies reduced their 

space and met their fiscal year 2016 

targets; and (3) how GSA manages 

vacated space it had leased to these 

agencies.

GAO conducted a content analysis of 

the 24 agencies’ real property plans for 

fiscal years 2016 and 2017 and

analyzed agencies’ data as submitted 

to GSA on their targets and reductions 

for fiscal year 2016, the only year for 

which data were available. GAO 

selected five agencies as case studies 

based on several factors, including 

size of the agencies’ office and 

warehouse portfolio, agency reduction

targets, and fiscal year 2016 reported 

reductions. GAO reviewed relevant 

documentation and interviewed 

officials from GSA, OMB, and GAO’s 

case study agencies. GAO provided a 

draft of this product to GSA, OMB, and 

our case study agencies for comment. 

GAO incorporated technical 

comments, as appropriate.
Page i GAO-18-304 Federal Buildings

Letter 1

Background 3

Agency Plans Identified Similar Strategies to More Efficiently Use 

Space and Common Challenges 6

The Majority of Agencies Reported Space Reductions in Fiscal 

Year 2016 but Achieved Varied Success in Meeting Their 

Targets 15

GSA Has Processes to Track Space Release Requests and 

Manage Vacant Space 20

Agency Comments 23

Appendix I Objectives, Scope, and Methodology 24

Appendix II Agencies’ Reported Baselines, Targets, and Fiscal Year 2016 

Reductions 28

Appendix III GAO Contact and Staff Acknowledgments 30

Table

Table 1: Chief Financial Officers (CFO) Act Agencies’ Reported 

Office and Warehouse Baselines, Target Reductions, and 

Fiscal Year (FY) 2016 Reductions (in square feet) 28

Figures

Figure 1: U.S. Department of Housing and Urban Development 

(HUD) Headquarters Building’s Consolidation Efforts 

Include Reducing Cubicle Sizes to Increase Space 

Utilization 7

Figure 2: Chief Financial Officers (CFO) Act Agencies’ Reported 

Reduce the Footprint Progress and Target Attainment, 

Fiscal Year 2016 17

Figure 3: Chief Financial Officers (CFO) Act Agencies’ Reported 

Reduce the Footprint Targets and Space Reductions 

(percentage based on its 2015 baseline square footage), 

Fiscal Year (FY) 2016 18

Contents
Page ii GAO-18-304 Federal Buildings

Abbreviations

CFO Chief Financial Officer 

Commerce Department of Commerce 

Energy Department of Energy 

GSA General Services Administration

FY fiscal year 

HUD Department of Housing and Urban Development 

Interior Department of the Interior 

IRS Internal Revenue Service 

Labor Department of Labor 

National Strategy National Strategy for the Efficient Use of Real

 Property 

Plan 5-year Real Property Efficiency Plan

RTF Reduce the Footprint 

SSA Social Security Administration 

Treasury Department of the Treasury 

USDA Department of Agriculture 

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-18-304 Federal Buildings

441 G St. N.W.

Washington, DC 20548

March 8, 2018

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 Thomas R. Carper

United States Senate

The federal government is committed to reducing vacant and 

underutilized real property and its associated costs. Federal real property 

management has been on our High-Risk list since 2003, in part because 

we have found that the government maintains more property than it 

needs.1 In 2012, the Office of Management and Budget (OMB) directed 

the 24 Chief Financial Officers (CFO) Act agencies to “freeze” their 

footprint and maintain their civilian real estate inventory at or below their 

then-current levels.2 In 2015, OMB issued its Reduce the Footprint (RTF) 

policy requiring the CFO Act agencies to set annual targets for reducing 

their portfolio of domestic office and warehouse space.3 As the federal 

government’s principal landlord, the General Services Administration 

 1

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

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

2

The CFO Act established chief financial officers to oversee financial management 

activities at 23 agencies. Pub. L. No. 101-576, § 205, 104 Stat. 2838, 2842-43 (Nov. 15, 

1990). The list now includes 24 agencies, which are often referred to collectively as CFO 

Act agencies. See 31 U.S.C. § 901(b). For the purposes of this report, “agencies” refers to 

the 24 CFO Act agencies unless otherwise specified.

3

For the purposes of this report, “office and warehouse space” means domestic office and 

warehouse space unless otherwise specified.

Letter
Page 2 GAO-18-304 Federal Buildings

(GSA) plays a large role in providing space for agencies in both 

government-owned buildings that GSA leases to federal agencies and 

space GSA acquires in commercially-leased buildings for agencies.

You asked us to review the implementation of the RTF policy to 

determine to what extent its goals are being met. This report determines: 

(1) the approaches and any challenges CFO Act agencies have identified 

to achieving their RTF-reduction targets for all their domestic office and 

warehouse space; (2) the extent to which these agencies reduced their 

space and met their fiscal year 2016 RTF targets; and (3) how GSA 

manages vacated space that it had leased to these agencies.

To determine the approaches used and any challenges reported by 

agencies to achieving their RTF-reduction targets for all their domestic 

office and warehouse space, we conducted a content analysis of the 24 

CFO Act agencies’ 5-year Real Property Efficiency Plans (Plan) for fiscal 

years 2016 and 2017. Each Plan describes the agency’s overall strategic 

and tactical approach to managing its real property, provides a rationale 

for and justifies its optimum portfolio, and directs the identification and 

execution of real property disposals, efficiency improvements, and cost 

savings measures. The content analysis of the Plans helped us to 

understand the approaches agencies expected to use to reduce space, 

how space-reduction targets were set, and any challenges they 

experienced in reducing their space. We also selected five agencies as 

case studies to further understand their experiences in implementing the 

RTF policy. We selected the agencies using a variety of considerations 

such as diversity in the size of the agency’s domestic office and 

warehouse portfolio, agency reduction targets, the extent to which the 

agency met its fiscal year 2016 RTF targets, types of real property 

authorities the agency has,4 as well as suggestions from GSA and OMB 

related to agencies’ experiences. Based on these factors, our selected 

case study agencies included the: (1) Department of Commerce 

(Commerce); (2) Department of Energy (Energy); (3) Department of 

Housing and Urban Development (HUD); (4) Department of the Interior 

(Interior); and (5) Department of the Treasury (Treasury). While our case 

study agencies and their experiences reducing their space are not 

generalizable to all CFO Act agencies, they provide a range of examples 

of how a number of agencies are implementing the RTF policy.

 4

We looked at whether the agency has custody and control of any of its real property and 

whether it has authority, for example, to lease property directly from a third party and 

dispose of its real property. 
Page 3 GAO-18-304 Federal Buildings

To determine the extent to which agencies reduced their space and met 

their fiscal year 2016 RTF office and warehouse reduction targets, we 

analyzed the 24 CFO Act agencies’ data as submitted to GSA on their 

RTF targets and reported reductions. At the time of our review, fiscal year 

2016 was the first and only year of RTF data available as the policy was 

implemented in March 2015. We conducted a data reliability assessment 

of the RTF data by interviewing GSA officials and reviewing 

documentation, and concluded the data were reliable for our purposes. 

We also interviewed officials at GSA, OMB, and our five selected casestudy agencies to obtain supporting documentation and to improve our 

understanding of how agencies set their RTF targets, agencies’ progress 

toward those targets, and the approaches used and challenges faced in 

meeting those targets. We also visited three office buildings occupied by 

our case study agencies in the Washington, D.C., area with ongoing or 

recently completed RTF projects. We selected the buildings based on 

recommendations from officials at our case study agencies.

To determine how GSA manages vacated federally owned and 

commercially leased space that it had leased to agencies, we reviewed 

federal requirements and GSA policies and vacancy data.5 We conducted 

a data reliability assessment of GSA’s vacancy and cost avoidance data 

by interviewing GSA officials and reviewing documentation, and 

concluded the data were reliable for our purposes. We also interviewed 

GSA headquarters and regional officials and obtained documentation on 

how GSA manages space returned by agencies. For more information on 

our scope and methodology, see appendix I.

We conducted this performance audit from April 2017 to March 2018 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.

The federal government owns and leases hundreds of thousands of 

buildings across the country that cost billions of dollars annually to 

 5

This includes space in federally-owned buildings under GSA’s custody and control, and 

commercial space GSA leases on behalf of tenant agencies. 

Background
Page 4 GAO-18-304 Federal Buildings

operate and maintain. In recent years, the federal government has taken 

steps to improve the management of federal real property and address 

long-standing issues by undertaking several government-wide initiatives 

and issuing memorandums to the CFO Act agencies. Within the executive 

branch, OMB and GSA provide leadership in managing federal real 

property. As the chief management office for the executive branch, OMB 

oversees how federal agencies devise, implement, manage, and evaluate 

programs and policies. OMB provides direction to federal agencies by, 

among other things, issuing policies and memorandums on real property 

management.

In 2012, OMB issued a memorandum that required agencies to move 

aggressively to dispose of excess properties held by the federal 

government and more efficiently use real estate assets. This 

memorandum initially laid out the requirement to “freeze the footprint.”6 In 

2013, OMB issued a memorandum clarifying the Freeze the Footprint

policy.7 This memorandum required agencies going forward to maintain 

no more than their fiscal year 2012 total square footage of domestic office 

and warehouse space. The policy required agencies to specifically 

identify existing properties to be disposed of to offset any new property 

acquisitions.

In March 2015, OMB transitioned from freezing the federal government’s 

real property footprint to reducing it. Specifically, OMB issued the National 

Strategy for the Efficient Use of Real Property (National Strategy) to 

provide a framework to guide agencies’ real property management, 

increase efficient real property use, control costs, and reduce federal real 

property.8 The National Strategy outlined three key steps to improve real 

property management: (1) freeze growth in the inventory; (2) measure 

performance and use data to identify opportunities to improve the 

efficiency of the real property portfolio; and (3) reduce the size of the 

inventory by consolidating, co-locating, and disposing of properties.

 6

OMB, M-12-12 Memorandum to the Heads of Executive Departments and Agencies

(Washington, D.C.: May 11, 2012).

7

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

Management Procedures Memorandum No. 2013-02 (Washington, D.C.: Mar. 14, 2013). 

8

OMB, 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). 
Page 5 GAO-18-304 Federal Buildings

OMB also issued the RTF policy which clarified existing policy to dispose 

of excess properties and promote more efficient use of real property 

assets. The RTF policy requires agencies to: (1) submit annual Real 

Property Efficiency Plans (Plan)9 to GSA and OMB; (2) issue a policy that 

specifies a design standard for maximum useable square feet by 

workstation for use in domestic office space; (3) set and specify in their 

Plans annual reduction targets for their domestic office and warehouse 

space for a 5-year period; (4) set and specify in their Plans annual 

reduction targets for domestic owned building properties reported in the 

Federal Real Property Profile; and (5) continue to not increase the square 

footage of their domestic inventory of office and warehouse space.10

Additionally, agencies must identify in their Plans potential projects 

related to office and warehouse consolidation, co-location, disposal, as 

well as construction and acquisition efforts. OMB is responsible for 

reporting the progress of agencies’ efforts in reducing the amount of 

federal real property space under the RTF policy.

GSA has two key leadership responsibilities related to real property 

management. First, GSA’s Public Buildings Service functions as the 

federal government’s principal landlord. In this role, GSA acquires, 

manages, and disposes of federally owned real property for which it has 

custody and control on behalf of federal agencies that occupy the 

space.11 Additionally, GSA leases commercial buildings on behalf of 

agencies and manages the lease agreements.12 In these situations, GSA 

executes an occupancy agreement with a customer agency for each 

space assignment that is similar to a sublease between GSA and the 

agency. The occupancy agreement outlines both the financial specifics of 

the agreement and the responsibilities of GSA and the customer agency. 

There are certain unique advantages for customer agencies when GSA 

 9

Agencies are required to submit a draft 5-year Plan 90 days after the Federal Real 

Property Profile data submission, with the final Plan submitted 60 days after an agency’s 

annual strategic review meeting with OMB, for each fiscal year. The Federal Real Property 

Profile is a real property inventory database maintained by GSA that contains information 

on federal real property government-wide.

10OMB, Implementation of OMB Memorandum M-12-12 Section 3: Reduce the Footprint, 

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

11GSA also disposes of real property under the custody and control of landholding 

agencies which do not have independent disposal authority.

12Included in federal agencies’ monthly rent is a monthly fee to GSA for its services 

related to leased space; tenants pay 5 or 7 percent of their lease value in a fee to GSA 

based on the level of flexibility the agency has in canceling the agreement.
Page 6 GAO-18-304 Federal Buildings

leases on their behalf. For example, GSA is able to enter into longer-term 

leases, and agencies can release space back to GSA with 4 months’

written notice if certain conditions are met, relieving the agencies of the 

cost for the returned space. Second, GSA’s Office of Government-wide 

Policy is responsible for, among other things, identifying, evaluating, and 

promoting best practices to improve the efficiency of management 

processes. In this policy role, GSA provides guidance for federal agencies 

and publishes performance measures. It also maintains the Federal Real 

Property Profile, a real property inventory database that contains 

information on federal real property government-wide.

Based on our review of agencies’ 2016 and 2017 Plans, we found that all 

24 CFO Act agencies described strategies for reducing office and 

warehouse space. As previously mentioned, these annual Plans must 

include all potential projects related to office and warehouse 

consolidation, co-location, disposal, as well as construction and 

acquisition efforts. The agencies’ Plans cited consolidation, co-location, 

and disposal as the primary means to reduce their office and warehouse 

space, activities mentioned in the National Strategy. Agencies also cited 

other methods, such as utilizing telework and decreasing the space they 

allocate per person to achieve space reductions.

The space reduction strategies included most often in the Plans we 

reviewed include the following.

• Consolidation: All 24 agencies reported planned or ongoing efforts to 

reduce their space by consolidating their offices or operations. For 

example, we spoke with officials at HUD, which is in the process of 

consolidating staff from four offices in the National Capital Region into 

its 1.12-million square foot headquarters building in Washington, D.C. 

HUD started by remodeling one floor to create a more open floor plan 

Agency Plans 

Identified Similar 

Strategies to More 

Efficiently Use Space 

and Common 

Challenges

Agencies Identified Space 

Consolidation, Colocation, or Property 

Disposal as Ways to 

Achieve Space 

Reductions
Page 7 GAO-18-304 Federal Buildings

and intends to apply this design throughout the building. As part of the 

consolidation project, HUD has reduced the size of some office 

cubicles from 64 square feet to 56 square feet. (See fig. 1.) HUD 

leases its space through GSA and estimates that it will be able to 

return about 175,000 square feet of unneeded space back to GSA 

once all four offices are closed. At that point, GSA would then bear 

the cost of the space and work to lease it to another agency or 

otherwise dispose of it. Once the project is completed, HUD estimated 

that its headquarters building will accommodate about 500 more 

personnel (for a total of 3,200) and reduce its annual lease payments 

by about $11 million.

Figure 1: U.S. Department of Housing and Urban Development (HUD) Headquarters Building’s Consolidation Efforts Include 

Reducing Cubicle Sizes to Increase Space Utilization

Fifteen of the 24 agencies identified consolidation opportunities 

outside of their headquarters buildings. For example, the Department 

of Agriculture (USDA) discussed a consolidation project involving five 

component agencies in Albuquerque, New Mexico, in its fiscal year 

2017 Plan. According to USDA officials, four component agencies 

occupying nearly 44,500 square feet in one building were to be 

consolidated into about 34,000 square feet of space in another 

building already occupied by a different USDA agency. In the prior 
Page 8 GAO-18-304 Federal Buildings

location, the multiple components spaces’ square footage per person 

averaged 327, but the proposed consolidation would bring the 

utilization rate down to 255 square feet per person. USDA estimated 

that the consolidation project would result in about $238,000 in annual 

rent cost savings for the four components. Additionally, to enable this 

consolidation project, the component agency already occupying the 

building consolidated and vacated about 20,000 square feet, a move 

that resulted in an annual rental savings of about $500,000. In its 

fiscal year 2017 Plan, Interior’s Bureau of Reclamation anticipated 

eliminating 87,000 square feet of office space by consolidating 

operations from two buildings in Denver, Colorado. Interior estimated 

that the consolidation will result in a 40 percent reduction in its overall 

utilization rate to 165 square feet per person and an annual cost 

savings of about $2.1 million.

• Co-location: Thirteen of the 24 agencies’ Plans stated that they are 

exploring or implementing co-location projects to reduce space by 

merging staff from different components or agencies into another 

agency’s space. For example, the Social Security Administration 

(SSA) recently initiated a co-location pilot program with the Internal 

Revenue Service (IRS) within Treasury to combine SSA field offices 

with IRS Taxpayer Assistance Centers. Co-location of operations can 

reduce the overall space required by allowing agencies to share 

common space such as waiting rooms, an action that can reduce rent 

and operating costs for the co-located agencies. Since the inception 

of the 1-year program in January 2017, four IRS offices are 

participating and have moved into SSA field offices. According to 

SSA, IRS and SSA staff have adjusted to sharing space and the IRS 

presence in SSA space has not affected SSA wait times or created 

security or parking issues. According to an IRS official, IRS 

employees continue all normal operations from their co-located offices 

with SSA, including meeting with taxpayers in-person. The official also 

noted that IRS has extended the terms of its agreement with SSA for 

an additional year. However, SSA noted that the agencies are still 

working through customer access issues that could determine 

whether it would be possible to expand the pilot program and pursue 

additional co-location opportunities. In another example, according to 

Interior officials, the U.S. Geological Survey is co-locating staff from 

Menlo Park, California, to a National Aeronautics and Space 

Administration facility in the nearby city of Mountain View, California. 

About 40 percent of the staff will move early in fiscal year 2019, and 

the U.S. Geological Survey expects the remaining staff to be colocated by the end of 2021. Interior officials estimate that the co-
Page 9 GAO-18-304 Federal Buildings

location will result in an overall reduction of 165,000 square feet 

(about 50 percent of its space) and expects to save about $12 to $14 

million in annual rent costs.

To help agencies identify potential co-location opportunities and work 

with other agencies to meet their space requirements, GSA developed 

and provided agencies access to its Asset Consolidation Tool in fiscal 

year 2015. This database tool provides agencies with information 

about federal spaces in their area, including the buildings’ vacancy 

and utilization rates.

• Disposal of unneeded space: Thirteen of the 24 agencies reported 

that they plan to reduce their real property footprint by disposing of 

unneeded space, including selling or demolishing federal buildings or 

terminating leases, among other actions.13 For example, IRS has five 

tax submission-processing centers that receive all mailed income-tax 

returns and have warehouses that store the physical tax records. 

Each of these five processing centers, which include both office and 

warehouse spaces in multiple buildings, is approximately 500,000 

square feet. According to IRS officials, 87 percent of all 2016 

individual income-tax returns were filed electronically. As a result, the 

IRS plans to dispose of three of the five centers by 2024 to align with 

its reduced need for income-tax return processing and storage space.

GSA has the statutory authority to dispose of property for all federal 

agencies and generally does so on their behalf.

14 In addition, some 

federal agencies, such as Energy, or departmental components have 

statutory authority to dispose of buildings and other types of property 

and are not required to notify or use the services of GSA to complete 

the disposal.15

• Better utilization of existing space: In their Plans, agencies also 

reported using tactical tools, such as incorporating space utilization 

rates into their capital-planning process, to identify opportunities to 

 13A disposal is the sale, demolition, lease termination, federal transfer, conveyance to 

another public entity for public benefit uses, such as homelessness assistance or 

education, and sale, or any other action that results in the removal of the asset from the 

inventory of the agency.

1440 U.S.C. § 542. 

15GAO, Federal Building Management: Building Disposal Authorities Provide Varying 

Degrees of Flexibility and Opportunities for Use, GAO-17-123 (Washington, D.C.: Dec. 8, 

2016). 
Page 10 GAO-18-304 Federal Buildings

reduce space. For example, 22 of the 24 agencies reported 

incorporating office space design standards and agency utilization 

rates into their processes to identify space reduction opportunities. 

Agencies set their own space design standards and space utilization 

rates, which may vary based on agency mission requirements across 

their components. The RTF policy requires agencies to establish a 

design standard for the maximum workstation size, which should, at a 

minimum, be applied to all space renovations and new acquisitions. In 

addition, GSA has a recommended office space-utilization rate range 

of 150 to 200 square feet per person.

Officials from our case study agencies noted several practices they 

said were helpful to identify opportunities to better utilize and 

ultimately reduce their space. For example, Commerce officials 

described developing a process for identifying and prioritizing space 

reduction opportunities using a two-factor matrix. Through this 

process, Commerce plans to target office space with a large number 

of employees and poor utilization rates (compared to its 170 square 

foot utilization rate). According to Commerce officials, these situations 

may offer the most opportunity for space reductions and achieving 

significant rent and operating cost savings, particularly in high-cost 

real estate markets. Using this process, Commerce identified the 

potential for reducing as much as 1.6-million square feet (16 percent) 

of its total office space within 52 high priority facilities. According to 

IRS, retirements, hiring freezes, budget reductions, and increased 

telework have resulted in excess space throughout its portfolio. In 

fiscal year 2016, IRS started using a Strategic Facility Plan model to 

help identify space reduction projects. IRS’s objectives include 

consolidating multiple offices within a metropolitan area, closing 

outlying buildings, and leveraging telework, mobility, and its attrition 

rates. This model utilizes a template form to provide a consistent 

decision-making framework for assessing various options, articulating 

the rationale for selecting the preferred option, and documenting 

decisions and concurrence. According to IRS officials, this model has 

helped IRS to reduce a lot of its space.

In 2014, GSA developed and provided agencies with access to the 

Real Property Management Tool, which can aid agencies that want to

more effectively utilize their space. The database tool provides 

agencies with the capability to comprehensively view their real 

property portfolio by consolidating data from the assets that agencies

directly manage with the assets that GSA manages on their behalf. As 

such, regardless of whether an agency initiated the action or GSA did 
Page 11 GAO-18-304 Federal Buildings

so on its behalf, the tool gives an agency the ability to see all of its

data, such as on expiring leases, in one place. The tool enables 

agencies to create individualized analytic reports allowing them to 

analyze the data in various ways.

• Teleworking and hoteling: Fifteen of the 24 agencies also described 

alternate workplace arrangements enabled by information technology, 

such as telework and hoteling, to help reduce office space. Telework 

is a work flexibility arrangement under which an employee performs 

their work responsibilities at an approved alternative worksite (e.g., 

home). Executive agencies are required to establish policies that 

authorize eligible employees to telework, determine the eligibility of all 

employees to participate in telework, and notify all employees of their 

eligibility.16 Federal law also requires that agencies consider whether 

space needs can be met using alternative workspace arrangements 

when deciding whether to acquire new space.17 As such, some 

agencies are eliminating designated offices for staff who primarily 

telework, a step that can improve space utilization. In a hoteling 

arrangement, employees use non-dedicated, non-permanent 

workspaces assigned for use by reservation and on an as needed 

basis. For example, the Office of Personnel Management 

implemented a workspace sharing initiative at one of its program 

offices. Staff who are not physically present in the office 4 or more 

days per week are required to share cubicles and offices. The Office 

of Personnel Management estimated that the initiative resulted in a 47 

percent office space reduction for the program office.

As part of their fiscal year 2016 and 2017 Plans, the 24 CFO Act 

agencies also described the major challenges they anticipated facing in 

their efforts to meet their space reduction targets. The agencies most 

frequently cited the following challenges:

• Space reduction costs: Twenty of 24 agencies stated that the costs of 

space reduction projects pose a challenge. Agencies are generally 

responsible for the up-front costs associated with relocations and 

tenant improvements, such as acquiring new furniture and renovating 

existing areas to reduce space or to accommodate more personnel in 

 165 U.S.C. § 6502(a).

1740 U.S.C. § 587(c)(2).

Cost and Mission 

Considerations Were Cited 

as Leading Challenges to 

Reducing Space
Page 12 GAO-18-304 Federal Buildings

a smaller area.18 For example, the Department of Labor (Labor) 

reported in its fiscal year 2017 Plan that it did not have sufficient 

funding to implement a space reduction project that would have 

reduced commercially leased office space by 4,000 square feet. 

Similarly, the Department of Veterans Affairs’ fiscal year 2017 Plan 

noted that assuming a limited budget, large scale consolidations 

would be difficult to achieve.

Some agencies have used or report that they intend to use funding 

from GSA’s Consolidation Activities program to help fund their space 

reduction projects.19 According to GSA, from fiscal years 2014 to 

2017, GSA’s Consolidation Activities program funded projects that will 

eliminate 1.4-million rentable square feet from the GSA inventory and 

reduce agencies’ annual rent payments by $54 million. According to 

the IRS, GSA’s Consolidation funds have helped the agency reduce 

about 500,000 square feet of space. IRS officials noted that these 

funds helped the agency implement larger and more expensive space 

reduction projects than it would have been able to do otherwise. 

However, according to officials from several agencies, to use this 

program, agencies must also contribute funds to the projects. HUD 

officials stated that they considered applying for project funding 

through GSA but did not do so because HUD did not have sufficient 

funds for the agency’s share of project costs.

Three of the 24 agencies specifically noted that the cost to clean up 

environmentally contaminated buildings is a challenge to disposing of 

excess office and warehouse space. Agencies are required to 

consider the environmental impact of property disposals.20 We have 

previously found that assessments and remediation of contaminated 

properties can be expensive and complicate the disposal process.21

Also, agencies are responsible for supervising decontamination of 

excess and surplus real property that has been contaminated with 

 18GSA, Public Buildings Service, Pricing Desk Guide, 4th Edition (Washington, D.C.: Oct. 

3, 2011). Tenant improvements are the finishes and fixtures that typically take space from 

the shell condition to a finished, usable condition.

19GSA’s Consolidation program helps fund projects that enable agencies to relocate to 

federally owned space with the goal of more efficiently meeting their mission needs and 

results in improved space utilization and cost savings.

2042 U.S.C. § 4332.

21GAO, DOE Facilities: Better Prioritization and Life Cycle Cost Analysis Would Improve 

Disposition Planning, GAO-15-272 (Washington, D.C.: Mar. 19, 2015).
Page 13 GAO-18-304 Federal Buildings

hazardous materials of any sort. In its fiscal year 2017 Plan, Energy 

estimated that over 60 percent of its excess buildings require 

extensive decontamination prior to disposal. Overall, Energy projected 

that its total liability for environmental clean-up could cost more than 

$280 billion.

• Mission delivery: Thirteen of the 24 agencies reported that mission 

delivery requirements can also affect their ability to reduce space. 

Agency missions may require office locations in certain areas or 

require additional space to accommodate activities such as customer 

interactions. These requirements may preclude disposals or limit 

opportunities to reduce space. For example, in its fiscal year 2017 

Plan, SSA stated that its efforts to reduce space are affected by its 

mission, which requires offices widely dispersed throughout the 

country to administer and support its benefit programs, among other 

things. SSA has about 1,500 office spaces nationwide, most of which 

require space to accommodate the public. SSA had an overall office 

space utilization rate of 301 square feet per person, which exceeded 

GSA’s recommended office space utilization rate range of 150 to 200 

square feet per person. USDA’s fiscal year 2017 Plan stated that its 

missions require office space in rural areas to, among other things, 

provide program assistance and leadership on food, agriculture, 

natural resources, rural development, nutrition, and related issues. In 

its fiscal year 2017 Plan, USDA also observed that the real estate 

market in rural areas is less competitive than in urban areas because 

there are fewer rental options, a situation that can also drive up rent 

costs. As such, USDA noted that these factors may contribute to 

difficulties identifying disposal opportunities and finding alternate 

spaces that could allow for more effective space utilization.

• Employee organization concerns: Ten of the 24 agencies reported 

that considering employee organizations’ concerns and addressing 

collective bargaining requirements when reconfiguring space can add 

time and affect the extent of their space reductions. For example, in 

its fiscal year 2017 Plan, SSA noted that the agency must meet with 

three employee unions when revising office space policies or design 

standards and collaborating with these organizations adds to the 

project’s implementation timeline. In July 2017, we reported that SSA 

officials met with employee union groups about the impact of potential 

changes to its space configuration or usage. Officials said that while 

the interactions with the union groups were positive—including 

gaining input on issues such as ergonomics, the security of field 

offices, and overall implementation—at times, these negotiations 

caused delays to individual projects and complicated reduction efforts 
Page 14 GAO-18-304 Federal Buildings

by requiring union buy-in.22 In addition, Labor reported in its fiscal 

year 2017 Plan that its collective bargaining agreement and agency 

mission requirements for offices and work stations do not always 

enable it to take advantage of the previously discussed GSA 

Consolidation Funding program as well as GSA’s Total Workplace 

Furniture & Information Technology program.23 For example, the Total 

Workplace Furniture & Information Technology program requires that 

cubicles and offices must not exceed a specified square footage. 

However, according to Labor officials, Labor’s Departmental Space 

Management Regulation requires a certain utilization rate per person 

which may make it challenging to also stay within the program’s 

square footage requirements.

• Workload growth: Eight of the 24 agencies noted that increases in 

their workload limited their ability to achieve overall agency space 

reductions. For example, according to the Department of Justice’s 

fiscal year 2017 Plan, the agency anticipated having to provide 

additional court rooms to support an increased volume of immigration 

cases and accommodate the additional immigration judges needed to 

handle that volume.24 The Department of Justice estimated that the 

space needed to accommodate the new judges and additional public 

areas could add about 155,000 square feet to its portfolio. Also, 

according to the Department of Health and Human Services’ fiscal 

years 2016 and 2017 Plans, the Office of Medicare Hearings and 

Appeals experienced a 30 percent growth in cases and expected 1.2-

million new cases annually after 2017. The Department of Health and 

Human Services projected that the growth in cases and additional 

staff needed to process the cases required additional field offices, 

which would increase its total office space square footage.

 22GAO, Social Security Administration: Improvements Needed in Facilities Planning and 

Service Delivery Evaluation, GAO-17-597 (Washington, D.C.: July 25, 2017).

23GSA’s Total Workplace Furniture & Information Technology program allows agencies to 

lease furniture over a 5-year term and lease information technology over a 3-year term. 

The program is part of the agency’s overall Total Workplace initiative, which provides 

resources and expertise to encourage federal agencies to reduce their office space, foster 

collaboration, better manage information technology spending, and increase efficiency.

24According to the Department of Justice’s 2017 Plan, the Executive Office of Immigration 

Review conducted immigration court hearings in 59 immigration courts nationwide.
Page 15 GAO-18-304 Federal Buildings

As previously mentioned, agencies are required to set annual square foot 

reduction targets for domestic office and warehouse space in their annual 

Plans. According to an OMB official, to help ensure the targets are 

realistic, agencies are also required to identify the specific projects that 

will help them to achieve their space reduction targets. According to GSA 

and OMB officials, agencies submit their Plans, including their reduction 

targets, and their Plans are reviewed by both GSA and OMB. But each 

individual agency ultimately establishes its targets based on what it 

determines to be cost-effective and feasible. Through its Real Property 

Efficiency Plan template, GSA provides guidance to agencies on what is 

expected in their annual submissions. Each agency is required to 

document its internal controls, such as the process for identifying and 

prioritizing reductions to office and warehouse space and disposal of 

properties based on return on investment and mission requirements. The 

identified internal controls should help ensure that an agency’s proposed 

space reduction projects reflect an efficient use of space and are cost 

effective. A review of our five case study agencies illustrated some of the 

different approaches agencies used to determine their reduction targets. 

For example, several agencies’ targets were based on the total estimated 

feasible reductions identified by each agency component. In contrast, one 

agency centrally established a reduction target percentage and then 

asked its components to develop projects to meet that target. According 

to case-study agency officials, the agencies considered many factors, 

including their missions, priorities, component needs, and available 

budgets, when determining their targets.

We found that the number and magnitude of the space reduction projects 

agencies identified in their fiscal year 2017 Plans varied greatly and were 

generally proportional to the size of the agency’s real property portfolio. 

The number of projects identified in agency Plans ranged from as few as 

3 projects (the minimum required in the Plans) to nearly 400 projects. The 

estimated space reductions per project across agencies ranged from 

about 1,400 to over 94,000 square feet. For example, the Department of 

Veterans Affairs has a relatively large office and warehouse portfolio of 

over 28-million square feet. As part of its fiscal year 2017 Plan, the 

agency reported 320 planned or ongoing projects with an average space 

reduction of about 1,800 square feet per project. Conversely, the Office of 

Personnel Management has a relatively small office space portfolio of 

about 1-million square feet; its fiscal year 2017 Plan identified 4 ongoing 

or potential projects with an average space reduction of about 6,000 

square feet.

The Majority of 

Agencies Reported 

Space Reductions in 

Fiscal Year 2016 but 

Achieved Varied 

Success in Meeting 

Their Targets
Page 16 GAO-18-304 Federal Buildings

In fiscal year 2016—the first and only year RTF data were available at the 

time of our review—the majority (71 percent or 17 of the 24 agencies) 

reported they achieved reductions in their office and warehouse space 

even though the agencies had varying success in achieving the individual 

targets they set for themselves.25 For example, as shown in figure 2, of 

the 17 agencies that reduced space, 9 exceeded their targets (i.e., 

reduced more space than planned); 7 reduced space but missed their 

target (by anywhere between 2.8 and 96.7 percent); and 1 agency 

expected to increase in square footage, but reduced space.26

 25We report the combined reduction figures for agencies’ domestic office space and 

warehouse space, unless otherwise indicated. Agencies with fewer than 200 domestic 

warehouses are not required to set reduction targets and as such, 11 of the 24 agencies 

were exempt. For all the CFO Act agencies, the majority of agencies’ combined office and 

warehouse square footage is comprised of office space.

26Two of the 24 CFO Act agencies did not have a space reduction target, but rather 

projected they would increase in size; three agencies’ target was to maintain the same 

baseline square footage; and the National Science Foundation was not required to set a 

target. As reported by the National Science Foundation, GSA and OMB agreed that the 

National Science Foundation would not be required to establish an RTF reduction target 

until one year after its move, slated for late fiscal year 2017, to its new Alexandria, 

Virginia, space.
Page 17 GAO-18-304 Federal Buildings

Figure 2: Chief Financial Officers (CFO) Act Agencies’ Reported Reduce the Footprint Progress and Target Attainment, Fiscal 

Year 2016

Whether an agency met its target is not the only indicator of an agency’s 

success in reducing space. For example, although some agencies missed 

their targets, they reduced their office and warehouse space by a larger 

percentage than some agencies that exceeded their targets. Also, the fact 

that some agencies missed their targets can in part be attributed to 

setting more aggressive targets than other agencies. Agencies’ fiscal year 

2016 targets ranged from a 0.8 percent increase to an 8.4 percent 

decrease in office and warehouse space. Of the 9 agencies that 

exceeded their reduction targets, 4 more than tripled their target. As 

mentioned, agency targets are set by the agency and are a reflection of 

their unique situation including mission needs and priorities and therefore 

cannot be generalized across agencies. For example, Energy exceeded 

its fiscal year 2016 reduction target and reduced 292,140 square feet of 

space (0.8 percent of its total square footage). However, the 

Environmental Protection Agency missed its target, which was the second 

most aggressive target across all the agencies at 7.2 percent of its total 

square footage; but the agency reduced 174,003 square feet (3.24 
Page 18 GAO-18-304 Federal Buildings

percent of its total square footage). Of the three agencies with the most 

aggressive target reductions—those that ranged between 6.7 and 8.4 

percent of their total square footage—only one met its target. Figure 3 

shows the extent to which each of the CFO Act agencies met its fiscal 

year 2016 targets. See appendix II for more detailed information on each 

agencies’ square footage of space, reduction targets and fiscal year 2016 

reductions.

Figure 3: Chief Financial Officers (CFO) Act Agencies’ Reported Reduce the Footprint Targets and Space Reductions 

(percentage based on its 2015 baseline square footage), Fiscal Year (FY) 2016

Note: Square feet reductions are represented as positive numbers and increases are represented by 

negative numbers. The National Science Foundation is not included because it was not required to 

establish reduction targets in fiscal year 2016.

Officials from our case study agencies cited a number of factors that 

influenced whether or not they met their fiscal year 2016 targets, and may 

also affect their target achievement in subsequent years. Of our five case 
Page 19 GAO-18-304 Federal Buildings

study agencies, three exceeded their fiscal year 2016 reduction target 

and two missed their target.

• Timing and funding: Officials from two case study agencies cited 

timing as a factor, noting that there is fluidity to the project’s planning, 

implementation, and disposal process that may not always be within 

an agency’s control. As a result, space reductions anticipated in one 

fiscal year may not be realized until a subsequent fiscal year; 

conversely, some space reduction opportunities may present 

themselves unexpectedly. For example, according to officials at HUD, 

which missed its fiscal year 2016 reduction target, some projects take 

longer than anticipated to start or complete. HUD officials said that 

their fiscal year 2016 target may have been too ambitious and 

planned projects were delayed because they were unable to secure 

sufficient funding. As such, the officials said the agency must carefully 

select which projects to move forward with in a given fiscal year, but 

expected to move forward with their delayed, planned projects in the 

next fiscal year. Energy on the other hand, exceeded its fiscal year 

2016 reduction target. Energy officials said that they tend to be 

conservative in listing potential RTF projects in their Plans. They 

noted that it takes a long time to dispose of a building and the timing 

was dependent on the building’s level of contamination, location, size, 

agency budget, and other factors. As a result, even though the 

agency may have planned to dispose of a building in a given fiscal 

year, there were numerous reasons why the project may get delayed.

Further, RTF is a long-term effort and should not be judged based on 

agencies’ progress in their first year. According to an OMB official, it is 

understood that there may be circumstances in a given year that may 

hinder agencies from reaching their RTF targets, such as budget 

constraints or the timing of leases; however, the expectation is that 

agencies will continue to work toward accomplishing their target in the 

next year. Accordingly, under RTF, agencies set annual space 

reduction targets for a 5-year period. Officials from our case study 

agencies emphasized that the 5-year targets are not static, but rather 

are subject to annual updates. The RTF policy also acknowledged 

that changes to mission requirements and the availability of budgetary 

resources may require modifications to an agency’s targets, 

particularly in each of the subsequent years. Lastly, given that the 

RTF policy is still relatively recent, an OMB official noted that 

agencies are still in the process of learning how to set appropriate 

targets.
Page 20 GAO-18-304 Federal Buildings

• Previous space reductions: Officials from three of our case study 

agencies noted that prior space reductions made during the Freeze 

the Footprint policy limited their ability to reduce space more 

aggressively. Though the thrust of Freeze the Footprint was to 

maintain the fiscal year 2012 size of an agency’s portfolio, agencies 

started to look more strategically for opportunities to dispose of 

excess space in their portfolios. The majority of agencies (18 of 24) 

have been decreasing the square footage of their domestic office and 

warehouse space since the Freeze the Footprint policy was 

implemented in 2013. OMB reported that under Freeze the Footprint, 

agencies achieved a 24.7-million square foot reduction between fiscal 

years 2012 and 2015. Officials from the IRS, which accounts for 70 

percent of Treasury’s real property inventory, noted it has released 

2.7-million square feet (approximately 10 percent) in the past 5 years, 

bringing its total square footage down to 25.3 million. According to 

officials from three of our case study agencies, a certain amount of 

space is required to effectively fulfill their missions. As such, the 

closer agencies get to attaining their optimum footprint, their ability to 

achieve further space reductions may be limited.

In November 2016, GSA put into effect a new standard operating 

procedure to, among other things, standardize and streamline the 

process of receiving, reviewing, and documenting agencies’ space 

release actions. As previously mentioned, GSA’s occupancy agreements 

for space it leases on behalf of its customer agencies generally allow the 

agencies to release space back to GSA with as little as 4 months’ notice, 

if certain conditions are met.27 This can enable agencies to reduce their 

space and related rent costs relatively quickly without penalty.28 As a 

result of this new process, GSA established a centralized e-mail for 

agencies to submit their space release requests. The e-mail is maintained 

at GSA headquarters before it is forwarded to the respective GSA region. 

 27According to GSA officials and GSA’s Pricing Desk Guide (4th Ed.), a customer agency 

has the right to release space to GSA with 4 months’ written notice, if GSA regional 

officials determine the following requirements are met: (1) there is no longer a need for the 

space; (2) the space is in a marketable block; (3) the space is not designated as noncancelable in the occupancy agreement; and (4) the release date is at least 16 months 

into the occupancy term.

28If the requirements are met, then the only penalty is that the customer agency must pay 

the unpaid balance of the cost of tenant improvements as well as the remaining amount of 

any concession (free rent for example) applicable to the remaining lease term. This 

release of space provision applies to space GSA provides to agencies in federally owned 

assets and commercial leased assets.

GSA Has Processes 

to Track Space 

Release Requests 

and Manage Vacant 

Space
Page 21 GAO-18-304 Federal Buildings

GSA also developed a centralized space release tracking spreadsheet to 

help ensure that all GSA regions were (1) notifying the customer agency 

of GSA’s determination on whether the space release request was within 

GSA’s policy, and (2) processing the space release and ceasing rent 

billings in a timely manner. According to GSA headquarters officials, this 

new process was implemented to rectify past concerns that space release 

requests were not centrally tracked, GSA regions may not have been 

making consistent determinations, and some requests either were missed 

or were not processed within the appropriate time frames.

GSA officials noted that GSA similarly manages all vacant space in 

federally owned property under its custody and control and in commercial 

space it leases, and the agency seeks to utilize the space as quickly as 

possible. GSA has 11 regional offices throughout the country that 

generally conduct the day-to-day real property management activities for 

its customer agencies. These responsibilities include acquiring, 

managing, and disposing of real property, as well as executing, renewing, 

and terminating leases on behalf of its customer agencies in exchange for 

a monthly fee for GSA’s services. GSA headquarters officials told us that 

GSA regional offices track all the occupancy agreements and proactively 

work with customer agencies to help manage their space needs well 

before the agreements expire to understand ongoing space requirements. 

For example, according to GSA headquarters officials, this process 

includes working with agencies at a strategic level and helping them think 

about how they can accomplish their space needs and meet their targets 

4 to 5 years in advance. GSA headquarters and regional officials noted 

that the advance planning helps the GSA regional officials integrate 

agencies’ potential space needs into the work they are already doing in 

the region as GSA manages the regional inventory as a whole, including 

managing the amount of vacant space. GSA regional officials told us that 

they work closely with the agencies in their space consolidation and 

reduction efforts to minimize the likelihood that GSA would be caught off 

guard by a release of space. This work enables GSA to develop options 

for either filling vacant space based on the known needs in the region or 

developing an alternative plan to effectively utilize the unneeded space.

One of GSA’s strategic objectives is to improve the federal utilization of 

space in order to lower the government’s operational costs. To assess 

progress, GSA has an agency-wide vacant space performance goal of 

3.2 percent for its federally-owned and leased inventory (with a 5 percent 
Page 22 GAO-18-304 Federal Buildings

goal for federally owned and 1.5 percent goal for leased space).29 Based 

on GSA data, the agency has steadily lowered its percentage of vacant 

space under its custody and control from 3.8 percent in fiscal year 2013 

to 3 percent in fiscal year 2016, exceeding its performance goal of 3.2 

percent for the first time in 4 years.30 The vacant space performance 

goal’s data help GSA evaluate its real property assets and plan for and 

make investment decisions while meeting its customer’s needs. 

According to GSA officials, the lower vacant space percentage is a 

reflection of the agency’s continued focus on working with its customer 

agencies to: (1) move into federally owned space, when possible; (2) 

decrease the size of commercially leased space to reduce agency rental 

costs and overall government reliance on leased space; and (3) dispose 

of unneeded federally owned assets. However, GSA officials noted that a 

certain level of vacant space is necessary to meet the space needs of 

new customers and customers with changing space requirements.

According to GSA officials, GSA also tracks and reports annual cost 

avoidance data for all office and warehouse space reductions. These data 

include space covered under RTF in federally owned buildings under 

GSA’s custody and control and commercial space that GSA leases. Cost 

avoidance is defined as the results of an action taken in the immediate 

timeframe that will decrease future costs. The government-wide cost 

avoidance for fiscal year 2016 was $104 million based upon a net 10.7 

million square foot reduction to all office and warehouse space. Of the 

government-wide figure, according to GSA, the total cost avoidance 

associated with office and warehouse space reductions in federallyowned space under GSA’s custody and control and commercial space 

GSA leased in fiscal year 2016 was over $75.8 million and 3.1 million 

square feet. In its cost avoidance calculation, GSA accounts for space 

returned to it by customer agencies only if there is a net square footage 

reduction in GSA’s total square footage across all the space that it 

manages.

Similarly, the space returned to GSA does not reduce the federal 

government’s overall office and warehouse square footage unless GSA 

disposes of it. However, space that is returned to GSA is reflected as a 

 29This performance indicator reports GSA’s total unoccupied assignable square feet as a 

percentage of total assignable square feet in its owned and leased inventory. Space 

undergoing on-time, prospectus level renovation is excluded.

30GSA, Fiscal Year 2016 Annual Performance Report—Fiscal Year 2018 Annual 

Performance Plan.
Page 23 GAO-18-304 Federal Buildings

square footage reduction for the customer agency and contributes toward 

that agency’s RTF target reduction. According to GSA regional officials, 

agencies’ requests to return space prior to the end of their occupancy 

agreements appear to have increased since the implementation of the 

RTF policy. Thus far, GSA has processes to manage agencies’ space 

release requests and keep its vacant space to a minimum. However, it is 

too early to determine how the recent increase in space release requests, 

in combination with agencies’ continued focus on occupying a smaller 

footprint and reducing their square footage, will affect: (1) the size of 

GSA’s inventory of vacant space in the long term, (2) GSA’s regional 

office workload to manage the requests, and (3) the cost savings for the 

federal government.

We provided a draft of this report to GSA, OMB, Commerce, Energy, 

HUD, Interior, and Treasury for review and comment. We received 

technical comments from Energy, which we incorporated, where 

appropriate. GSA, OMB, Commerce, HUD, Interior, and Treasury did not 

have comments on our draft report. 

We are sending copies of this report to the appropriate congressional 

committees; the Administrator of GSA; the Director of the OMB; the 

Secretaries of the Departments of Commerce, Energy, HUD, the Interior, 

and the Treasury; and other interested parties. In addition, the report will 

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

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

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

our Offices 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 III.

Lori Rectanus

Director, Physical Infrastructure Issues

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 24 GAO-18-304 Federal Buildings

Our objectives were to determine: (1) the approaches and any challenges 

the 24 Chief Financial Officers (CFO) Act agencies1 identified to 

achieving their Reduce the Footprint (RTF) reduction targets for all their 

domestic office and warehouse space; (2) the extent to which these 

agencies reduced space and met their fiscal year 2016 RTF targets; and 

(3) how the General Services Administration (GSA) manages vacated 

space that it had leased to these agencies.

To obtain background information for all three objectives, we reviewed 

relevant literature, including laws governing federal real-property 

management and agencies’ efforts to reduce their real property portfolios 

and Office of Management and Budget’s (OMB) and GSA’s

memorandums and guidance governing the RTF policy. We also 

reviewed prior GAO and GSA inspector general reports describing 

agencies’ real-property management and efforts to more efficiently 

manage their real property portfolios.

To determine the approaches used and any challenges faced by the CFO 

Act agencies in achieving their RTF reduction targets for all their domestic 

office and warehouse space, we conducted a content analysis of the 

agencies’ 5-year Real Property Efficiency Plans (Plans) for fiscal years 

2016 and 2017. These Plans were obtained directly from each of the 

agencies. Each Plan describes an agency’s overall strategic and tactical 

approach in managing its real property, provides a rationale for and 

justifies its optimum portfolio, and directs the identification and execution 

of real property disposals, efficiency improvements, general usage, and 

cost-savings measures. The content analysis of the Plans helped us to 

understand the approaches agencies used to reduce space, how spacereduction targets were set, and any challenges they experienced in 

reducing their space. To identify agencies’ approaches to achieving their 

RTF targets, we reviewed all agencies’ Plans to determine the most 

frequently mentioned approaches agencies reported using or planned to 

 1

The 24 CFO Act agencies include the Departments of Agriculture, Commerce, Defense, 

Education, Energy, Health and Human Services, Homeland Security, Housing and Urban 

Development, the Interior, Justice, Labor, State, Transportation, the Treasury, and 

Veterans Affairs; the Environmental Protection Agency; GSA; the National Aeronautics 

and Space Administration; the National Science Foundation; the Nuclear Regulatory 

Commission; the Office of Personnel Management; the Small Business Administration; the 

Social Security Administration; and the U.S. Agency for International Development. Chief 

Financial Officers Act of 1990, Pub. L. No. 101-576, § 205, 104 Stat. 2838, 2842-43 (Nov. 

15, 1990) (codified as amended at 31 U.S.C. § 901(b)). For the purposes of this report, 

“agencies” refers to the 24 CFO Act agencies unless otherwise specified.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-18-304 Federal Buildings

use to reduce their real-property footprints. As part of their plans, each 

agency is required to include a section detailing approaches it plans to 

use to reduce space. While these sections were the primary focus of the 

analysis, we analyzed the Plans as a whole for any additional mention of 

agencies’ approaches to reduce space. Based on the frequently identified 

approaches, codes were developed. An analyst reviewed all the 

agencies’ Plans and coded the approaches and another analyst reviewed 

the coding. If there was a disagreement, the two analysts reviewed and 

discussed until they reached an agreement. As a result of the analysis, 

five approaches were identified that agencies most frequently reported 

using or were planning to use to achieve their RTF targets. These five 

approaches are described in more detail in the report: (1) consolidation; 

(2) co-location; (3) disposition of unneeded space;2 (4) better utilization of 

existing space; and (5) teleworking and hoteling. For the purposes of our 

report, telework and hoteling were combined because these approaches 

are often used in combination. For example, agencies can use telework 

strategically to reduce space needs and increase efficiency by making 

hoteling (i.e., desk sharing) possible.

To identify any challenges agencies faced in achieving their RTF targets, 

we similarly conducted a content analysis of agencies’ fiscal year 2016 

and 2017 Plans. As part of their Plans, each agency included a section 

describing challenges it faced to reducing space. While these sections 

were the primary focus of the analysis, we analyzed the Plans as a whole 

for any additional mention of agencies’ challenges. Based on the 

frequently identified challenges, codes were developed. An analyst went 

through all the agencies’ Plans to code the challenges and another 

analyst reviewed the coding. If there was a disagreement, the two 

analysts reviewed and discussed until they reached an agreement. As a 

result of the analysis, we identified the four challenges that agencies most 

frequently described in their Plans: (1) space reduction costs; (2) mission 

delivery; (3) employee organization concerns; and (4) workload growth. In 

 2

Consistent with our content analysis methodology, we analyzed the narrative portion of 

agency Plans for fiscal year 2016 and 2017 to determine whether agencies were 

employing disposal as an approach to reducing their square footage. As part of their 

annual submissions, agencies were also required to submit spreadsheets that identify 

specific office and warehouse acquisitions, consolidations, co-locations, disposals, and 

construction projects. We did not include these spreadsheets in our content analysis 

because one or more agency disposal actions can be the result of employing other 

approaches to reduce square footage, such as a consolidation. As a result, not all 

agencies that list specific disposal actions in their spreadsheets employ disposal as a 

general approach or strategy to reducing their square footage.
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-18-304 Federal Buildings

our report, we relied specifically on agencies’ fiscal year 2016 and 2017 

Plans to provide examples and context for our description of the 

approaches agencies use and challenges they experience in achieving 

their RTF targets. However, after these Plans were submitted, agencies 

reported that the specific details as described in their Plans may in some 

instances, have changed due to a variety of factors. For our case study 

agencies, to the extent possible, we have provided updated information 

from agency officials as of December 2017.

We selected five agencies as case studies to inform our first two 

objectives. We selected the agencies using a variety of considerations 

such as the diversity in the size of the agency’s domestic office and 

warehouse portfolio, the extent to which the agency met its fiscal year 

2016 RTF targets, the types of real property authorities the agency has,3

as well as suggestions from GSA and OMB related to agencies’

experiences. Based on these factors, we selected the: (1) Department of 

Commerce (Commerce); (2) Department of Energy (Energy); (3) 

Department of Housing and Urban Development (HUD); (4) Department 

of the Interior (Interior); and (5) Department of the Treasury (Treasury). 

While our case-study agencies and their experiences reducing their 

space are not generalizable to all CFO Act agencies, they provide a 

range of examples of how agencies are implementing the RTF policy. We 

interviewed officials at the selected agencies as well as GSA and OMB, 

and reviewed relevant agency real-property management and RTF 

guidance, to obtain more detailed information about agencies’ RTF 

approaches, challenges, specific RTF projects, RTF project funding and 

prioritization, and experiences in meeting their RTF targets. In addition, 

we visited three office buildings of our case study agencies in 

Washington, D.C., with ongoing or recently completed RTF projects that 

illustrated approaches the agencies used to reduce space and met with 

officials to discuss the projects in more detail. The spaces we visited were 

the headquarters buildings for Commerce, HUD, and Interior. We 

selected the buildings based on recommendations from officials at our 

case study agencies.

To determine to what extent agencies reduced their space and met their 

fiscal year 2016 RTF targets, we analyzed the 24 CFO Act agencies’ data 

as submitted to GSA on their RTF targets and reported reductions for 

 3

We looked at whether the agency has custody and control of any of its real property and 

whether it has authority, for example, to lease property directly from a third party and 

dispose of its real property. 
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-18-304 Federal Buildings

fiscal year 2016. The office and warehouse square footage reductions are 

calculated annually using GSA occupancy agreement data and agencies’

self-reported data in GSA’s Federal Real Property Profile. For example, 

for fiscal year 2016, the space reduction calculations based on these data 

sources at the end of the fiscal year was compared to the square footage 

reported in fiscal year 2015.4 At the time of our review, this was the first 

and only year of RTF data available as the policy was implemented in 

March 2015. We conducted a data reliability assessment of the RTF data 

GSA provided by interviewing GSA officials and reviewing documentation, 

and concluded the data were reliable for our purposes. We also 

interviewed officials at GSA and OMB and reviewed relevant 

documentation to learn more about each agency’s role and the 

requirements of the RTF policy. We interviewed officials from our selected 

case-study agencies to obtain supporting documentation and to improve 

our understanding of how agencies set their RTF targets, agencies’

progress toward those targets, and the approaches used and challenges 

faced in meeting those targets. We also asked the agency officials for 

examples of successful practices used to reduce their office and 

warehouse space.

To determine how GSA manages vacated federally owned and 

commercially leased space that it leases to agencies, we reviewed 

federal requirements and GSA policies and vacancy data. We conducted 

a data reliability assessment of GSA’s vacancy and cost avoidance data 

by interviewing GSA officials and reviewing documentation, and 

concluded the data were reliable for our purposes. We also interviewed 

GSA headquarters and regional officials and obtained documentation on 

how GSA manages space returned by agencies.

We conducted this performance audit from April 2017 to March 2018 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.

 4

For the purposes of our report, we reported the combined reduction figures for agencies’

domestic office space and warehouse space, unless otherwise indicated.
Appendix II: Agencies’ Reported Baselines, 

Targets, and Fiscal Year 2016 Reductions

Page 28 GAO-18-304 Federal Buildings

Table 1: Chief Financial Officers (CFO) Act Agencies’ Reported Office and Warehouse Baselines, Target Reductions, and 

Fiscal Year (FY) 2016 Reductions (in square feet)

CFO Act Agencies 2015 baseline FY 2016 

target 

reduction

FY 2016 

reduction

FY 2016 

square footage

FY 2016-

FY 2020 target 

reduction

Met or exceeded target

Department of Agriculture 32,623,505 165,340 425,765 32,197,740 805,585

Department of Commerce 12,124,081 130,000 219,321 11,904,760 530,000

Department of Defense 321,271,955 127,095 7,296,234 313,975,721 5,880,456

Department of Education 1,545,710 28,962 163,935 1,381,775 361,863

Department of Energy 36,665,561 93,000 292,140 36,373,421 774,000

Department of the Interior 38,508,920 395,000 733,078 37,775,842 1,310,000 

Department of Transportation 12,890,095 259,051 706,768 12,183,327 557,164 

General Services Administration 5,183,256 344,917 1,042,334 4,140,922 538,235

National Aeronautics and Space 

Administration

15,715,619 (118,127) 97,541 15,618,078 518,711

Small Business Administration 1,297,809 33,780 59,763 1,238,046 134,144

United States Agency for International 

Development

909,000 0 0 909,000 21,187

Missed target

Department of Homeland Security 31,135,963 669,955 22,092 31,113,871 1,464,474 

Department of Housing and Urban 

Development

3,098,523 259,993 44,232 3,054,291 484,016

Department of the Treasury 26,892,839 621,097 484,191 26,408,648 3,358,386

Department of Veterans Affairs 28,240,990 89,730 66,408 28,174,582 787,912 

Environmental Protection Agency 5,364,495 388,644 174,003 5,190,492 608,032

Nuclear Regulatory Commission 1,079,543 3,000 0 1,079,543 68,122

Office of Personnel Management 1,153,188 31,461 30,591 1,122,597 200,111

Social Security Administration 11,701,596 260,000 174,755 11,526,841 890,000 

Missed target and increased in space

Department of Health and Human 

Services

19,287,500 627,355 (170,147) 19,457,647 791,304 

Department of Justice 47,362,747 0 (520,987) 47,883,734 221,555

Department of Labor 6,927,600 (15,466) (47,946) 6,975,546 67,836

Department of State 7,010,913 0 (56,062) 7,066,975 335,294

Appendix II: Agencies’ Reported Baselines, 

Targets, and Fiscal Year 2016 Reductions
Appendix II: Agencies’ Reported Baselines, 

Targets, and Fiscal Year 2016 Reductions

Page 29 GAO-18-304 Federal Buildings

CFO Act Agencies 2015 baseline FY 2016 

target 

reduction

FY 2016 

reduction

FY 2016 

square footage

FY 2016-

FY 2020 target 

reduction

Not applicable

National Science Foundationa 597,354 N/A 0 597,354 N/A

Government-wide 668,588,762 4,394,787 11,238,010 657,350,752 20,708,387

Source: GAO analysis of GSA data and information included in agencies’ fiscal year 2016 Real Property Efficiency Plans. | GAO-18-304

Note: Square feet reductions are represented as positive numbers and increases are represented by 

negative numbers.

a

As reported by the National Science Foundation, due to its pending relocation plans, the General 

Services Administration and the Office of Management and Budget permitted it not to establish 

reduction targets until one year after its move.
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 30 GAO-18-304 Federal Buildings

Lori Rectanus, (202) 512-2834 or rectanusl@gao.gov

In addition to the individual named above, Maria Edelstein (Assistant 

Director); Lacey Coppage; Edgar Garcia; Delwen Jones; Catherine Kim 

(Analyst-in-Charge); Michael Mgebroff; Malika Rice; Kelly Rubin; and 

David Wise made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102015)
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