NUCLEAR 

REGULATORY 

COMMISSION

Additional Action 

Needed to Improve 

Process for Billing 

Licensees

Report to Congressional Requesters

March 2018

GAO-18-318

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-318, a report to 

congressional requesters

March 2018

NUCLEAR REGULATORY COMMISSION

Additional Action Needed to Improve Process for 

Billing Licensees

What GAO Found

The Office of the Inspector General for the Nuclear Regulatory Commission 

(NRC) and internal reviews conducted by NRC identified several problems with 

the agency’s billing process, and NRC has implemented or plans to implement 

several changes to address the recommendations. For example, the codes that 

NRC staff use to record their work hours on time cards—referred to as activity 

codes—did not describe the work and did not have a consistent naming 

convention, which increased the risk of staff charging their time to the wrong 

activity codes. This could lead, in some cases, to billing errors. To address these 

problems, NRC created a standard naming convention for activity codes that 

provides more information about the activity. See the figure below for the steps in 

NRC’s billing process for work that NRC or contractor staff performed.

The Nuclear Regulatory Commission’s Billing Process

Some of the 13 licensees that GAO interviewed identified challenges with NRC’s 

billing process, including its method for delivering paper invoices by mail. For 

example, two of these licensees stated that with invoices taking up to 10 days to 

arrive in the mail, they sometimes do not have sufficient time to properly review 

charges and remit payment to NRC within the 30-day deadline for paying the 

invoice. One licensee said that delays in receiving an invoice resulted in late 

fees. NRC is undertaking an initiative to transition to electronic billing, which may 

address the challenges the licensees identified and, according to NRC staff,

improve the agency’s billing process. However, NRC has not developed planning 

documents for this initiative and, according to staff, the planning phase is already 

past its original deadline of October 2017. The Project Management Institute has 

identified standards related to project management processes, including project 

planning. By developing a project management plan that is consistent with best 

practices and includes steps for involving licensees in system development and 

assessing results of the project, NRC would have reasonable assurance that it 

can better manage its electronic billing initiative.

View GAO-18-318. For more information, 

contact Frank Rusco at (202) 512-3841 or 

ruscof@gao.gov.

Why GAO Did This Study

NRC is responsible for regulating the 

commercial nuclear industry, including 

nuclear power plants. NRC provides 

services, such as inspections, for 

regulated entities that hold licenses—

that is, licensees. NRC recovers the 

costs for these services by assessing 

fees and billing licensees quarterly. In 

fiscal year 2016, NRC collected about 

$321 million in service fees. From 2006

to 2016, audits of NRC’s fees identified 

problems with NRC’s billing process. 

For example, a 2012 audit identified 

about $24 million in unbilled fees from 

fiscal years 2011 and 2012. 

GAO was asked to review NRC’s 

billing process for service fees. This 

report examines (1) the actions NRC is 

taking to address problems with its 

billing process identified by internal 

reviews and (2) the challenges 

selected licensees identified with 

NRC’s billing process and the extent to 

which NRC’s actions are addressing 

them. 

GAO reviewed audits of NRC’s billing 

process and other documents related 

to this process. GAO also interviewed 

NRC staff and a nongeneralizable 

sample of 13 licensees, selected 

based on the amount of service fees

charged from October 2015 through 

July 2017, and compared NRC’s 

actions against criteria on internal 

controls and project planning.

What GAO Recommends

GAO is making five recommendations, 

including that NRC develop a project 

management plan for its electronic 

billing initiative that follows project 

management standards and includes 

steps for involving licensees and 

assessing results. NRC agreed with 

these recommendations.
Page i GAO-18-318 Nuclear Regulatory Commission

Letter 1

Background 5

NRC Has Taken Action in Four Main Areas to Improve Its Billing 

Process 9

Licensees We Interviewed Identified Several Challenges with 

NRC’s Billing Process, and NRC’s Recent and Planned 

Changes May Not Fully Address Them 13

Conclusions 20

Recommendations for Executive Action 20

Agency Comments 21

Appendix I Comments from the Nuclear Regulatory Commission 24

Appendix II GAO Contact and Staff Acknowledgments 25

Figure

Figure 1: The Nuclear Regulatory Commission’s (NRC) Process 

for Billing Licensees for Service Fees 7

Contents
Page ii GAO-18-318 Nuclear Regulatory Commission

Abbreviations

NRC Nuclear Regulatory Commission

OIG Office of Inspector General

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Page 1 GAO-18-318 Nuclear Regulatory Commission

441 G St. N.W.

Washington, DC 20548

March 8, 2018

Congressional Requesters

The Nuclear Regulatory Commission (NRC) is the federal agency 

responsible for regulating the commercial nuclear industry—including 

nuclear power plants and other civilian uses of radioactive material—

through licensing, inspection, and enforcement of its regulations. NRC 

provides licensing services, including conducting inspections, reviewing 

applications for new licenses, and renewing licenses, to regulated entities 

that hold a license or are applying for a license, referred to as licensees 

and applicants, respectively. NRC recovers the full costs for providing 

these services by assessing fees to licensees and applicants—called 

service fees—and billing licensees and applicants each quarter using a 

billing process that includes aggregating all the charges to be billed; 

reviewing the charges and correcting errors, if any; mailing quarterly 

invoices; and then addressing disputes from licensees and applicants, if 

any.1 In fiscal year 2016, NRC collected about $321 million in service fees 

from licensees and applicants. Since 2006, internal audits of NRC’s 

revenue from fees have identified problems with the agency’s billing 

process, some of which resulted in significant billing errors to licensees. 

In fiscal year 2012, for example, an internal NRC audit identified 

approximately $24 million in unbilled fees from fiscal years 2011 and 

2012 that went undetected by NRC staff involved in the agency’s billing 

process.

The Omnibus Budget Reconciliation Act of 1990, as amended, requires 

NRC to annually assess and collect fees totaling about 90 percent of its 

annual budget authority.2 To reach this amount, NRC assesses two types 

 1

According to NRC staff, its billing process is the same for licensees and applicants. This 

report focuses on licensees.

2

42 U.S.C. § 2214. The remaining 10 percent of NRC’s budget authority—known as fee 

relief activities—covers the cost of such activities as international assistance, agreement 

state oversight, and scholarships and fellowships, which do not directly benefit existing 

licensees and are not intended to be recovered through fees. The Omnibus Budget 

Reconciliation Act of 1990 also defines several items that are excluded from fees. For 

fiscal year 2016, the act and the 2016 Consolidated Appropriations Act exclude from fee 

recovery amounts appropriated (1) for NRC’s responsibilities related to Department of 

Energy waste management activities for certain radioactive material resulting from the 

reprocessing of spent nuclear fuel, (2) for generic homeland security activities, (3) to NRC 

from the Nuclear Waste Fund for the fiscal year, and (4) for Inspector General services for 

the Defense Nuclear Facilities Safety Board.

Letter
Page 2 GAO-18-318 Nuclear Regulatory Commission

of fees—service fees and annual fees—that are set through an annual 

rulemaking process.3 Service fees encompass reimbursable contract 

costs and reimbursable NRC staff time costs, which include time spent 

performing work for a specific licensee and certain overhead costs. In 

cases where NRC hires a contractor to perform work related to a specific 

licensee, NRC pays the contractor for the work and then bills the licensee 

for reimbursement. NRC assesses service fees for agency staff time by 

establishing an hourly rate to recover the full cost of specific regulatory 

services. In cases where the cost of an activity will change very little from 

licensee to licensee, NRC has established flat service fees based on the 

hourly rate.4 For service fees, charges on the invoice are to recover the 

costs for work completed in the previous quarter up to the date of the 

invoice and invoices are mailed to licensees quarterly via the U.S. Postal 

Service to collect service fees. NRC assesses annual fees to recover 

regulatory costs that are not otherwise recovered through service fees in 

order to meet the 90 percent statutory requirement. Licensees’ payments 

for service and annual fees are due to NRC within 30 days of the invoice 

date so licensees can avoid paying interest on the charges. This report 

focuses on the billing process for service fees assessed to licensees.5

You asked us to review NRC’s process for billing licensees for service 

fees. This report examines (1) the actions NRC is taking to address 

problems with its billing process identified by internal reviews and (2) the 

challenges selected licensees identified with NRC’s billing process and 

the extent to which NRC’s actions address these challenges.

To determine what actions NRC is taking to address problems with its 

billing process for service fees, we reviewed agency documents and 

interviewed NRC staff. Specifically, we reviewed assessments of NRC’s 

 3

The service fees are established under 10 C.F.R. Part 170 and the annual fees under 10 

C.F.R Part 171. More information on NRC’s fee-setting process is available in GAO, 

Nuclear Regulatory Commission: Regulatory Fee-Setting Calculations Need Greater 

Transparency, GAO-17-232 (Washington, D.C.: Feb. 2, 2017).

4

Flat fees are service fees set at a predetermined amount for the review of certain types of 

license applications, such as licenses to import or export nuclear material for civilian uses. 

NRC calculates flat service fees by multiplying the average number of hours needed to 

process each licensing action by an hourly rate. NRC estimates the amount of hours by 

reviewing the actual number of hours that staff spent performing these actions in the 

previous year. 

5

For purposes of this report, we use the term service fee to refer to fees billed using the 

hourly rate and the term billing process to refer to the process for billing service fees. 
Page 3 GAO-18-318 Nuclear Regulatory Commission

billing process from 2006 to 2016, including two audits by NRC’s Office of 

the Inspector General (OIG) and NRC’s Business Process Improvement 

Project, which was an internal review completed in March 2014 that 

focused on eliminating or greatly reducing billing errors for service fees 

and improving overall efficiency and effectiveness of the billing process.6

We also reviewed NRC’s planning documents related to the actions it is 

taking to address the problems, and NRC policy and guidance related to 

its billing process. We interviewed NRC staff in the Office of the Chief 

Financial Officer who are working on projects and initiatives that are 

designed to address problems with NRC’s billing process. We also 

interviewed NRC staff in the agency’s four regional offices (Region 1 near 

Philadelphia, Pennsylvania; Region 2 in Atlanta, Georgia; Region 3 near 

Chicago, Illinois; and Region 4 in Arlington, Texas) and eight offices 

(Advisory Committee on Reactor Safeguards; Atomic Safety and 

Licensing Board Panel; and the Offices of General Counsel, New 

Reactors, Nuclear Material Safety and Safeguards, Nuclear Reactor 

Regulation, Nuclear Security and Incident Response, and Nuclear 

Regulatory Research) that are responsible for reviewing charges as part 

of the billing process, including staff who review contractor charges.

To determine the challenges licensees have with NRC’s billing process 

and the extent to which NRC is addressing them, we reviewed agency 

documents related to its billing process; interviewed a stratified, 

nongeneralizable sample of 13 non-federal licensees; and interviewed 

NRC staff.7 To select licensees for our sample, we used service feecollection data produced by NRC’s financial management system, called 

the Financial Accounting and Integrated Management Information 

System. From seven of NRC’s nine fee classes,8 we selected to interview 

the 2 licensees that held the licenses that were assessed the highest 

amount of service fees from October 2015 through July 2017. However, 

 6

Nuclear Regulatory Commission, Office of the Inspector General, Audit of NRC’s 

Contract Administration of the EPM Contract, OIG-12-A-18 (Washington, D.C.: September 

2012) and Audit of NRC’s Internal Controls Over Fee Revenue, OIG-15-A-12 

(Washington, D.C.: March 2015). 

7

We focused our review on nonfederal licensees because NRC’s billing process for 

federal agencies follows a different billing process that utilizes the Intragovernmental 

Payment and Collection system. 

8

For the purpose of setting fees, NRC established the following nine fee classes: fuel 

facilities, import/export, materials users, operating power reactors, rare earth, research 

and test reactors, spent fuel storage/reactor decommissioning, transportation, and 

uranium recovery.
Page 4 GAO-18-318 Nuclear Regulatory Commission

one of the seven fee classes had only 1 licensee that was assessed 

service fees in that class during this established period. Also, two fee 

classes were excluded from our sample.9 Our selection process resulted 

in 13 licensees of varying size and scope, including 1 holding multiple 

licenses that was assessed service fees of almost $28 million during the 

established period, and another holding a single license that was 

assessed service fees of almost $420,000 during the same period. If a 

licensee meeting our selection criteria was unwilling or unable to 

participate, we elected to interview the licensee that held the license that 

was assessed the next highest amount of service fees during this period. 

We interviewed licensees using a standard set of questions to collect 

consistent information. We analyzed licensee responses to our standard 

set of questions to identify key themes and grouped their responses into 

common categories. We interviewed NRC staff and reviewed related 

documentation to determine whether the agency’s recent or planned 

actions to address problems with its billing process could address 

licensees’ challenges. We compared NRC’s current billing practices 

against the agency’s Organizational Values10 and Standards for Internal 

Control in the Federal Government, as applicable.11 We also identified 

leading practices for project planning in the Project Management 

Institute’s A Guide to the Project Management Body of Knowledge.

12

We conducted this performance audit from March 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 

 9

The import/export fee class was excluded because no licensee in this class incurred 

service fees in the established fee-collection period. The transportation fee class was 

excluded because NRC adds its costs for regulating transportation activities to the annual 

fee amount for each fee class and separately to the Department of Energy.

10Nuclear Regulatory Commission, NRC Organizational Values, accessed December 6, 

2017, http://www.nrc.gov/about-nrc/values.html#values. 

11GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014). 

12Project Management Institute, A Guide to the Project Management Body of Knowledge

(PMBOK® Guide) - Fifth Edition (Newtown Square, Pa.: 2013). PMBOK is a registered 

trademark of the Project Management Institute, Inc. The Project Management Institute is a 

not-for-profit association that provides global standards for, among other things, project 

and program management. These standards are utilized worldwide and provide guidance 

on how to manage various aspects of projects, programs, and portfolios. 
Page 5 GAO-18-318 Nuclear Regulatory Commission

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

NRC is an independent agency established by the Energy Reorganization 

Act of 1974 to license and regulate civilian uses of nuclear materials in

the United States for commercial, industrial, medical, and academic 

purposes.13 Under the Atomic Energy Act of 1954, as amended, NRC is 

responsible for issuing licenses for civilian uses of radioactive material 

and conducting oversight activities under such licenses to protect the 

health and safety of the public, among other things.14 NRC regulates 

commercial nuclear power plants; research, test, and training reactors; 

nuclear fuel cycle facilities; the transport, storage, and disposal of 

radioactive materials and waste; and the use of radioactive materials in 

medical, academic, and industrial settings.15 NRC is authorized to 

conduct inspections and investigations; enforce regulatory requirements 

by, among other things, issuing orders and imposing civil (monetary) 

penalties; and revoke licenses. NRC is headed by a five-member 

Commission, with members appointed by the President and confirmed by 

the Senate; one commissioner is designated by the President to serve as 

the Chair and official spokesperson of the Commission. NRC staff from 

headquarters and the four regional offices implement the agency’s 

programs for developing regulations, licensing, inspection, enforcement, 

and emergency response, among other responsibilities. NRC’s Office of 

the Chief Financial Officer establishes, maintains, and oversees the 

implementation and interpretation of the agency’s regulatory user fee 

policies and regulations, among other responsibilities.

The Office of the Chief Financial Officer is responsible for assessing 

service fees to licensees for each license they hold and sending licensees 

invoices quarterly. The quarterly invoices for service fees may include 

costs in the following three categories:

 13Pub. L. No. 93-438, 88 Stat. 1233, (1974), codified as amended at 42 U.S.C. §§ 5801-

79.

14Pub. L. No. 83-703, 68 Stat. 919, (1954), codified as amended at 42 U.S.C. 2011 et seq.

15In addition, NRC has agreements with 37 states under which the states assume 

regulatory responsibility for the use of certain nuclear materials used or possessed within 

their borders.

Background
Page 6 GAO-18-318 Nuclear Regulatory Commission

• NRC staff work. NRC staff record their time related to services, such 

as licensing, inspections, special projects, and license reviews, which 

is then billed to licensees to recover the full cost of these services. To 

calculate the cost of work performed by NRC staff, NRC applies an 

hourly rate—as established during the agency’s annual rulemaking 

process—to the number of staff hours spent on work that is directly 

attributable to a specific licensee.

• Overhead costs for project managers and resident inspectors.

Some licensees work with an NRC project manager or resident 

inspector,16 and NRC allocates the overhead costs for these NRC 

staff to the licensees. Overhead costs cover the costs of these staff 

doing tasks that are not assigned to a specific licensee, but that 

benefit licensees, such as training, according to NRC staff. Project 

manager and resident inspector overhead costs are calculated for 

each relevant licensee as 6 percent of the licensee’s total NRC staff 

time charges for the quarter.

• Contractor charges. NRC sometimes hires a commercial contractor 

or other federal agency, such as the Department of Energy (referred 

to collectively as contractors), to perform services that are directly 

attributable to a licensee, such as reviewing license applications. In 

these cases, NRC pays the contractor for the work and then bills the 

licensee for reimbursement of the contractor’s charges.

NRC’s billing process for service fees begins by identifying work that can 

be billed to a specific licensee and ends when the licensee pays the 

quarterly invoice. Once NRC determines that billable work needs to be 

done, the agency follows the steps in the billing process shown in 

figure 1.

 16Project managers are NRC staff responsible for overseeing projects for licensees and 

resident inspectors are NRC staff assigned to a specific facility who provide major onsite 

NRC presence for inspection and assessment of licensee performance. 
Page 7 GAO-18-318 Nuclear Regulatory Commission

Figure 1: The Nuclear Regulatory Commission’s (NRC) Process for Billing Licensees for Service Fees

The steps in NRC’s billing process are described in more detail below.

• NRC assigns activity code: After billable work is identified, NRC 

assigns an activity code, which is a project code to which NRC 

employees charge time for billable work performed.

• NRC performs work: NRC staff perform work that is billable to a 

licensee and record their time biweekly in electronic time cards in 

NRC’s time and labor management system. If NRC staff discover that 

they have recorded time incorrectly in a previous pay period, such as 
Page 8 GAO-18-318 Nuclear Regulatory Commission

by charging time to an incorrect activity code, they can correct the 

error by making a prior-period adjustment. Adjustments that are made 

within 6 weeks of the date of the error can be made directly in the time 

and labor management system; adjustments made 6 weeks or more 

after the date of the error require a memo with justification from the 

employee’s office director to NRC’s Controller.

• Supervisors review hours: At the end of each 2-week pay period, 

NRC supervisors review and approve the time cards for the staff they 

supervise, including the hours charged to activity codes.

• Contractor performs work: If work is done by a contractor, the 

contractor submits a status report and invoice to NRC each month. 

Each monthly status report includes a description of the work done, 

the planned completion date, the total charges for the current invoice, 

the cumulative charges to date, and an estimate of future charges.

• NRC reviews charges: NRC staff responsible for managing the 

agency’s contracts review the monthly status reports and invoices and 

must approve invoices before paying the contractor. After paying a 

contractor’s invoice, NRC bills the licensee for reimbursement of the 

amount NRC paid to the contractor. Contractor charges are included 

on a licensee’s quarterly invoice, and NRC may bill a licensee for 

contractor charges after the quarter in which the work was performed.

• NRC aggregates charges: NRC’s financial management system 

aggregates all NRC staff hours and charges from contractors biweekly 

for each licensee. The financial management system obtains data on 

staff hours from NRC’s time and labor management system.

Contractor charges are entered manually into the financial 

management system.

• NRC validates charges: NRC regional and program offices review 

and certify all charges to licensees after the end of each quarter. To 

accomplish this, the Office of the Chief Financial Officer produces 

quarterly validation reports—one for staff charges and one for 

contractor charges—from NRC’s financial management system.

• NRC invoices licensees: NRC creates invoices each quarter and 

sends them to licensees via the U.S. Postal Service. Licensees’

payments are due to NRC within 30 days of the invoice date to avoid 

paying interest on the charges.

• Licensee reviews and pays invoice: Licensees review the invoice 

and may pay the invoice, request that NRC review the fees assessed, 

or dispute the fees. These billing disputes generally start informally 

with the licensee contacting NRC. According to NRC staff, most 

disputes are handled informally and generally entail explanations of 
Page 9 GAO-18-318 Nuclear Regulatory Commission

the agency’s billing or licensing policies. If NRC staff are unable to 

resolve a licensee’s concern informally, the licensee can write a letter 

to the Chief Financial Officer, which begins a formal dispute process. 

According to NRC staff, to address a licensee’s concerns with the 

charges, the Office of the Chief Financial Officer reviews the charges 

on the invoice and may involve the relevant regional or program 

offices to determine whether the charges are valid for the work 

performed. Additionally, NRC’s Office of the General Counsel may be 

included in disputes regarding NRC’s fee policy. After the dispute is 

resolved, the licensee pays the invoice.

NRC’s OIG and internal reviews conducted by NRC in the last 5 years 

identified problems with the agency’s billing process. In 2012 and 2015, 

for example, OIG audits identified problems with NRC’s management and 

review of billable charges and recommended changes to the agency’s 

internal processes and procedures—called internal controls—to improve 

the accuracy of invoices. In 2013, NRC launched the Business Process 

Improvement Project to determine the root causes of billing errors, many 

of which were discovered during the quarterly validation step of the billing 

process. The project was completed in 2014 and made recommendations 

focused on strengthening internal controls and improving efficiency and 

effectiveness of the billing process. Additionally, in 2016 NRC requested 

feedback from the public, including licensees and other stakeholders, on 

the general communications the agency provides about its fees, intending 

to use the feedback to improve the transparency of its fees development 

and invoicing practices. Following this effort, NRC launched its Fees 

Transformation initiative to improve transparency of its fee-setting and 

billing processes.

NRC has recently implemented or plans to implement changes in four 

main areas of its billing process to address problems identified by NRC’s 

OIG and NRC internal reviews: controls over activity codes, guidance and 

training for NRC staff, quarterly validation of charges, and charging 

licensees for billable overhead costs.

NRC’s OIG and internal reviews found problems with NRC’s internal 

controls over activity codes, which affected the quality of data used for 

billing and other agency processes. The management of activity codes 

was decentralized, meaning that staff in NRC’s offices generated the 

codes and each office followed its own policies and procedures regarding 

the setup and use of these codes. NRC also did not have a standardized 

NRC Has Taken 

Action in Four Main 

Areas to Improve Its 

Billing Process

Controls over Activity 

Codes
Page 10 GAO-18-318 Nuclear Regulatory Commission

set of activity codes to be used across the agency. Activity codes were 

instead linked to specific licensees, meaning that identical work activities 

for two licensees would require two different activity codes. These 

conditions resulted in an excessive number of activity codes in the 

agency’s time and labor management system. According to an internal 

NRC review, the decentralized management and absence of 

standardized activity codes weakened internal controls and put NRC at 

risk for incomplete or inaccurate billing. Further, there was no consistent 

naming convention, and activity code titles often lacked the specificity 

necessary for NRC staff to readily identify the correct code for the work 

activity performed, according to the OIG.17 NRC staff could also search 

and access the entire inventory of activity codes, including those 

unrelated to their work. According to the OIG, these conditions increased 

risk for staff to inadvertently select the wrong activity codes when 

recording their time; in such cases, the wrong licensee could be billed for 

the work.

Starting in fiscal year 2016, the Office of the Chief Financial Officer began 

taking responsibility for overseeing and managing activity codes, 

including establishing, maintaining, and closing activity codes available in 

the agency’s time and labor management system. Further, NRC 

developed a set of standardized activity codes with titles related to the 

specific work activities completed. The transition to centralized activity 

code management and standardized activity codes was completed in 

October 2017, according to NRC staff. Also in October 2017, the agency 

implemented controls that prevent a staff member from charging time to 

an activity code unless a project manager has granted that staff member 

access to the code.

NRC’s OIG and internal reviews found problems with staff’s 

understanding of their roles and responsibilities for accurate time and 

labor reporting and management of billable contracts, which, according to 

NRC documents, contributed to avoidable time card errors and billing 

errors. To address these problems, NRC provided training and updated 

guidance for staff covering the following two areas:

• Time and labor reporting. According to an internal NRC review, staff 

were making avoidable data entry errors in time cards that 

 17Nuclear Regulatory Commission, Office of the Inspector General, Audit of NRC’s 

Internal Controls Over Fee Revenue, OIG-15-A-12. 

Guidance and Training
Page 11 GAO-18-318 Nuclear Regulatory Commission

supervisors who approved the timecards were not identifying, 

meaning incorrect time cards were sent to the Office of the Chief 

Financial Officer for billing.18 In late fiscal year 2015, NRC provided 

training to all agency staff to emphasize the importance of accurate 

time reporting, the process for selecting correct activity codes, and the 

relationship of time card entry to billing. According to NRC officials, 

the agency also provided specialized training to staff in offices where 

errors were common. Additionally, the agency updated its time and 

labor reporting guidance and provided supplemental guidance to staff 

related to time and labor reporting. Furthermore, in preparation for 

changes to activity codes that were implemented in October 2017, 

NRC provided additional training to staff on the new activity code 

structure and making corrections to their time cards.

• Management of contracts. According to an internal NRC review, 

approximately one-third of the billing errors identified during the 

quarterly validation step of the billing process resulted from 

administrative errors in managing contracts. NRC’s OIG also found 

that agency guidance related to the invoice review process was 

outdated and did not provide staff with sufficient criteria for verifying 

information contained in contractor invoices.19 Without such criteria, 

NRC could not ensure that it was evaluating contractor charges

consistently and appropriately before billing those charges to 

licensees. In 2015, NRC provided training to staff who manage 

contracts, which, according to NRC officials, resulted in an immediate 

decrease in associated billing errors. NRC also revised its guidance to 

clarify responsibilities, procedures, and instructions for reviewing and 

approving contractor invoices.

NRC’s OIG and internal reviews identified conditions that made the 

quarterly validation step in the billing process challenging for staff to 

perform and that led to inconsistent validation procedures among 

program and regional offices. NRC has taken or plans to take the 

following two actions to address these problems:

 18Although incorrect hours were entered and sent to the Office of the Chief Financial 

Officer for billing, the Office of the Chief Financial Officer has validation and quality 

assurance steps in the billing process that are designed to identify and correct errors 

before it sends invoices to licensees.

19Nuclear Regulatory Commission, Office of the Inspector General, Audit of NRC’s 

Contract Administration of the EPM Contract, OIG-12-A-18.

Quarterly Validation
Page 12 GAO-18-318 Nuclear Regulatory Commission

• Improving validation reports. According to NRC documents, the 

quarterly validation reports contained billing data for all program and 

regional offices—sometimes amounting to more than 4,000 pages of 

data—and the reports did not have the sorting functionality or 

querying capability that would allow NRC staff to extract relevant 

information. Staff in program and regional offices instead relied on 

manually generated reports to compile information they needed. 

Additionally, according to the OIG, the quarterly validation reports did 

not include sufficient detail on contractor charges for NRC’s staff to 

properly review them.20 To address these problems, in 2014 NRC 

started providing the quarterly validation report in electronic 

spreadsheet format, which gave staff the sorting and filtering 

capabilities needed to extract data relevant to their respective reviews 

and eliminated the need for manually generated reports, according to 

NRC staff. Further, NRC began providing validation information for 

contractor charges in a separate report. The new validation report for 

contractor charges has more detailed information and specific 

instructions for NRC staff for verifying the accuracy of the charges.

• Standardizing the quarterly validation process. According to NRC, 

the current quarterly validation process is not standardized across the 

regional and program offices and there is no agency guidance to 

ensure that staff in different offices conduct the process consistently. 

Further, there is currently no way to ensure that an adequately trained 

person in each program or regional office is conducting the validation, 

according to NRC staff. To address these problems, NRC is planning 

to standardize the quarterly validation process and to establish clear 

roles and responsibilities for staff participating in the process. One key 

change NRC is planning is to have the individual leading the work 

validate the accuracy of the charges. According to NRC’s planning 

documents—dated August 2017—NRC expects to pilot the new 

validation process in June 2018 and to implement it agency-wide by 

October 2018.

At the end of fiscal year 2012, an internal NRC audit identified 

approximately $24 million in unbilled overhead hours. NRC staff 

explained that the hours went unbilled because project managers and 

resident inspectors charged billable overhead time to nonbillable activity 

codes, rather than to the billable activity codes associated with licensees. 

 20Nuclear Regulatory Commission, Office of the Inspector General, Audit of NRC’s 

Internal Controls Over Fee Revenue, OIG-15-A-12. 

Charging for Billable 

Overhead Costs
Page 13 GAO-18-318 Nuclear Regulatory Commission

According to an internal NRC review, these errors accounted for 

approximately two-thirds of the billing errors identified during the quarterly 

validation process. At the beginning of fiscal year 2016, NRC started 

billing this overhead time as a separate fee on invoices that is calculated 

as 6 percent of all NRC billable hours on an invoice, which eliminated the 

billing errors related to overhead. However, NRC analyzed this billing 

method again in fiscal year 2017 and determined that eliminating the 

percentage charge and having staff charge their billable overhead time to 

billable activity codes would be more equitable. NRC intends to 

implement a new process for charging billable overhead time at the start 

of fiscal year 2019. According to NRC staff, the agency has made 

administrative changes to address the factors that contributed to project 

managers and resident inspectors incorrectly charging overhead time in 

the past.

Licensees we interviewed identified challenges with the amount of 

information available about NRC’s billable work, and NRC’s recent 

changes have made more information available, but some licensees are 

not aware of the information. Licensees also identified challenges with 

NRC’s method of delivering paper invoices by mail, and although NRC’s 

recent and planned changes may help address these challenges, NRC’s 

plans are incomplete.

Licensees we interviewed identified challenges with the amount of 

information available about NRC’s billable work, including challenges 

related to planning and budgeting for NRC work and verifying charges on

invoices. NRC has recently implemented changes that may address 

some of the challenges.

Licensees We 

Interviewed Identified 

Several Challenges 

with NRC’s Billing 

Process, and NRC’s 

Recent and Planned 

Changes May Not 

Fully Address Them

Licensees Identified 

Challenges with the 

Information Available 

about NRC’s Billable 

Work, and NRC Has Made 

More Information 

Available, but Some 

Licensees Are Not Aware 

of It
Page 14 GAO-18-318 Nuclear Regulatory Commission

Licensees we interviewed identified challenges with planning for future 

work and budgeting to pay future costs because NRC does not provide 

certain information about the agency’s billable work. Specifically, NRC 

does not formally provide information on timeframes for completing 

billable work, customized cost estimates for projects, or the status of 

ongoing work. Eleven of the 13 licensees we interviewed indicated that 

having timeframes, cost estimates, status reports, or a combination of 

these would be useful. One licensee explained that when it receives an 

invoice for work that NRC staff have performed, the licensee does not 

know how much work remains and cannot budget for future expenses.

This challenge may be addressed, in part, by NRC’s Fees Transformation 

initiative. Under this initiative, NRC began reporting on its public website 

in September 2017 resource estimates for various licensing actions, such 

as site permitting, design certifications, inspections, license amendments, 

and license renewals, among others. These resource estimates include 

the low, high, and average number of NRC staff hours billed for each 

action, as well as some estimates for contractor charges for certain tasks. 

These resource estimates are based on historical expenses and were 

calculated using a sample of licensing and oversight actions, though they 

may still be useful to licensees to help plan and budget for future NRC 

costs. According to NRC’s website, the agency will update most of the 

resource estimates every 2 years.

Licensees we interviewed said that they have challenges verifying 

charges on their invoices because NRC’s invoices do not provide enough 

information on work that NRC staff or contractors perform. For NRC staff 

work, invoices include the total hours charged by NRC staff for each 

activity code. However, activity codes often cover broad topics rather than 

specific work activities. Also, activity codes have a 120-character limit, 

according to NRC staff, and NRC uses some of those characters to list 

each licensee’s name and other identifying information, which means that 

there is limited remaining space to identify the specific work activity. Nine 

of the 13 licensees we interviewed explained that more descriptive activity 

codes on invoices would be helpful. One licensee said that it is difficult to 

know what project it is being billed for because the activity code 

descriptions are cryptic and sometimes nondescript. In addition, all 13 

licensees we interviewed indicated that having NRC staff names or their 

positions would be helpful in verifying the accuracy of charges. For 

example, 2 of these licensees explained that they are familiar with the 

NRC staff who consistently work on their projects, so they could consider 

Planning and Budgeting for 

NRC Work

Verifying Charges on Invoices
Page 15 GAO-18-318 Nuclear Regulatory Commission

questioning charges if the invoice showed a new person working on a 

project.

Additionally, licensees said that it is difficult to verify charges on their 

invoices because NRC’s invoices also do not contain detailed information 

on contractor charges. Invoices indicate that work was done by a 

contractor and provide the total cost of the work, but they do not include 

the contractor’s name or describe the work performed. Five of the 

licensees we interviewed said that invoices do not have enough 

information about the contractor and the work performed. Additionally, 4 

of these licensees stated that they cannot determine whether the 

amounts charged were accurate or reasonable without more information.

Challenges related to verifying charges may be addressed by some of 

NRC’s recent changes to its billing process, which include updating 

invoices. NRC is updating its invoices to include (1) standardized activity 

codes that have titles describing the specific work activity completed, (2) 

the names of the NRC staff charging time to the licensee, and (3) the 

name of the contractor that performed the work for which the licensee is 

being billed. NRC staff expected to issue the updated invoices to 

licensees in January 2018, after we completed our audit work. Therefore, 

we could not assess licensees’ satisfaction with the updated invoices. 

According to a planning document for some of NRC’s recent changes, the 

agency intends to solicit feedback from licensees in fiscal year 2018 on 

whether the updated invoices have addressed licensees’ challenges.

However, NRC staff told us that they are not certain when the agency will 

solicit feedback.

In addition to updating invoices, NRC can provide supplemental 

information to licensees to help them verify the accuracy of the following 

charges:

• NRC staff charges: NRC created biweekly reports on staff charges 

that it sends to licensees, when requested.21 These biweekly reports 

provide more frequent cost data and include a level of detail that is not 

provided on the quarterly invoices. For example, the biweekly reports 

include NRC staff names and the charges, by employee, for that 2-

 21NRC staff told us that the agency temporarily stopped sending the bi-weekly reports for 

the first quarter of fiscal year 2018—October through December—while it updated its 

financial management system for changes to the billing process, but planned to start 

sending these reports again in the second quarter. 
Page 16 GAO-18-318 Nuclear Regulatory Commission

week period. Three of the 13 licensees we interviewed that receive 

the biweekly reports said that they use the reports to check the 

quarterly invoice for accuracy by adding up the costs from the 

biweekly reports and comparing them to the quarterly invoice. For 

example, a licensee told us that if the biweekly reports and quarterly 

invoice have similar totals, it does not raise any questions about the 

charges.

• Contractor charges: NRC has supplemental contractor information 

that it can provide to licensees. NRC receives monthly status reports 

from contractors on charges that are ultimately billed to licensees on 

their quarterly invoices. These monthly status reports include current 

work performed and associated charges, as well as remaining work to 

be performed and an estimate of future charges. In 2015, NRC 

developed a process to review and provide to licensees certain 

information from the monthly status reports when licensees request it.

Although this supplemental information on staff charges and contractor 

charges is available, not all licensees know it is available. Specifically, 6 

of the 13 licensees we interviewed told us that the biweekly reports would 

be useful, but did not know the reports are available and can be 

requested. Also, 10 of the 13 licensees we interviewed told us that 

detailed information on contract work would be useful, but 9 of them did 

not know this information is available and can be requested.

Not all licensees know the supplemental information is available because, 

according to NRC staff in the Office of the Chief Financial Officer, the 

agency has not instituted a formal process to inform all licensees of its 

availability. These staff added that the agency has announced the 

availability of this supplemental information at industry conferences or has 

told individual licensees about it. NRC staff explained that the agency is 

meeting statutory requirements for issuing invoices and provides the 

supplemental information as a courtesy to licensees, but is not required to 

do so. According to NRC staff in the Office of the Chief Financial Officer, 

the agency has not formally notified all licensees about the availability of 

this supplemental information because it is time-consuming to provide it 

to licensees. These staff also said that they have found that not all 

licensees may need this information. This is consistent with information 

from the licensees we interviewed. For example, 2 licensees told us that 

they do not need biweekly reports; one said that it operates on a fixed 

annual budget, so additional information on biweekly costs would not be 

useful. In contrast, NRC staff noted that licensees with more complex 

invoices—such as multiple sites and multiple inspections and licensing 

actions—may find the supplemental information useful. Standards for 
Page 17 GAO-18-318 Nuclear Regulatory Commission

Internal Control in the Federal Government explains that management 

should communicate quality information externally so that external parties 

can help the entity achieve its objectives and address related risks.22

Furthermore, being open and transparent in communications is part of 

NRC’s Organizational Values, which guide every action it takes, how it 

performs administrative tasks, and how it interacts with stakeholders.23

Communicating to licensees about what information is available could 

help improve the transparency of NRC’s invoices, in accordance with the 

agency’s values.

Additionally, 2 licensees told us that they requested information on work 

being done by a contractor but NRC staff told them that the information 

could not be provided. NRC staff in the Office of the Chief Financial 

Officer acknowledged that some NRC project managers may not be 

aware that licensees can request contract information because there is no 

policy or guidance to instruct NRC staff on what information they can 

provide or how to do so. Standards for Internal Control in the Federal 

Government states that agency management should clearly document—

in management directives, administrative policies, or operating manuals—

the processes it uses to ensure that it is achieving its objectives.24 By 

developing a policy and guidance for NRC staff, the agency could help 

ensure that staff are aware of the agency’s processes and provide quality 

information consistently.

Licensees we interviewed said that NRC’s method for delivering paper 

invoices by mail created challenges related to the format and timeliness 

of the invoice, though NRC’s recent and planned changes may help 

address these challenges. For example, one licensee told us that, without 

the sorting and filtering capabilities of an electronic spreadsheet, this 

licensee is not able to verify the accuracy of charges for specific 

components of the work that NRC is doing. Another licensee told us that it 

is difficult to track costs of projects to completion without an electronic 

spreadsheet of charges. NRC now provides biweekly reports in an 

electronic spreadsheet format, which may help address the challenges 

these licensees cited. However, as discussed above, NRC does not 

 22GAO-14-704G. 

23Nuclear Regulatory Commission, NRC Organizational Values. 

24GAO-14-704G. 

Licensees Identified 

Challenges with NRC’s 

Method for Delivering 

Invoices, and NRC’s 

Recent and Planned 

Changes May Address 

These Challenges, but Its 

Plans Are Incomplete
Page 18 GAO-18-318 Nuclear Regulatory Commission

provide these biweekly reports unless they are requested, and some 

licensees do not know that they are available.

Licensees also cited challenges with the timeliness of invoices they 

receive via mail. For example, 2 licensees stated that, with invoices taking 

up to 10 days to arrive in the mail, licensees sometimes do not have 

sufficient time to conduct a proper review of charges and remit payment 

to NRC within the 30-day deadline. According to one licensee we 

interviewed, delays in receiving the invoices have resulted in late fees. To 

address the challenge of timeliness, NRC will, upon request from a 

licensee, e-mail a copy of the invoice to the licensee after the hardcopy 

invoice has been mailed. This practice allows the licensee to begin 

reviewing its charges while waiting for the mailed copy to arrive. However, 

of the 11 licensees that told us an e-mailed copy of the invoice would be 

useful, 4 of them did not know this option was available.

NRC staff said the agency intends to transition to electronic billing—that 

is, sending invoices in electronic format via e-mail or providing licensees 

with web access to review and pay invoices. According to NRC staff, the 

agency’s transition to electronic billing is being done to improve efficiency 

and internal controls in NRC’s billing process. However, doing so may 

also help address challenges that some licensees experience with the 

format and timeliness of invoices. For example, 11 of the 13 licensees we 

interviewed affirmed that receiving electronic invoices or periodic 

statements of charges electronically would be beneficial.

In October 2016, NRC’s Commission directed NRC staff to examine 

opportunities to accelerate the transition to an electronic billing system. 

The agency has indicated its intent to complete the planning phase by 

October 2017 and fully implement a new system by October 2019. 

However, according to NRC staff, the planning phase was not completed 

because the agency needed to fully implement the recent changes to its 

billing process before planning for the transition to electronic billing. As a 

result, the agency has not yet developed any planning documents to help 

ensure that it meets its deadlines, achieves its goal of increasing 

efficiency, or addresses licensees’ challenges. NRC staff in the Office of 

the Chief Financial Officer said that they recognize there could be delays 

in planning, but still expect to implement electronic billing by October 

2019.

We have previously found that federal information technology projects too 

frequently incur cost overruns and schedule slippages, but that proper 

planning—including incorporating best practices for project planning and 
Page 19 GAO-18-318 Nuclear Regulatory Commission

scheduling—may help mitigate these effects.25 The Project Management 

Institute’s A Guide to the Project Management Body of Knowledge

identifies standards related to project management processes, including 

project planning.26 In particular, the guide explains that the project plan is 

a comprehensive document that defines the basis of all project work and 

describes how the project will be executed, monitored, and controlled.27

The project plan integrates and consolidates plans for project 

components, such as plans for managing the project’s scope, schedule, 

cost, quality, and risk, among others. Among other things, the project 

management plan may also include requirements and techniques for 

communication among stakeholders and key reviews by management. By 

developing a project management plan that is consistent with best 

practices, NRC would have more reasonable assurance that it is better 

managing its transition to electronic billing.

Furthermore, Standards for Internal Control in the Federal Government

also states that, in deciding what information is required to achieve 

objectives, management should consider the needs of both internal and 

external users. Additionally, we have previously identified common factors 

critical to successful information technology acquisitions.28 Among these 

factors are (1) involving end users and stakeholders in developing 

requirements and (2) including end users in testing of system functionality 

prior to formal end user acceptance testing. As NRC develops a project 

management plan, by involving licensees in developing system 

capabilities for electronic billing, which includes soliciting and considering 

licensees’ information needs, the agency would have better assurance of 

a successful transition to electronic billing.

Additionally, Standards for Internal Control in the Federal Government 

states that management should design control activities to achieve 

objectives.29 Control activities may include establishing performance 

 25GAO, Information Technology Investment Management: A Framework for Assessing 

and Improving Process Maturity, GAO-04-394G (Washington, D.C.: March 2004).

26Project Management Institute, A Guide to the Project Management Body of Knowledge

(PMBOK® Guide) - Fifth Edition.

27Project Management Institute, A Guide to the Project Management Body of Knowledge

(PMBOK® Guide) - Fifth Edition. 

28GAO, Information Technology: Critical Factors Underlying Successful Major 

Acquisitions, GAO-12-7 (Washington, D.C.: Oct. 21, 2011). 

29GAO-14-704G. 
Page 20 GAO-18-318 Nuclear Regulatory Commission

measures and indicators and management reviews that compare actual 

performance to planned or expected results and analyze significant 

differences. As NRC develops a project management plan, including 

steps to assess the results of implementing electronic billing, which 

includes comparing actual performance of the new electronic billing 

system to planned results, would provide the agency more reasonable 

assurance that the project meets desired outcomes.

NRC has recently implemented or plans to implement a number of 

changes to its billing process that—if implemented as intended—could 

address challenges that licensees identified in our interviews. However, 

additional steps could enhance NRC’s efforts to improve its billing 

process. Licensees told us that they could use more detailed information, 

more timely information, and information in an electronic format. NRC has 

made more detailed information on staff charges available in biweekly 

reports and has developed a process to provide detailed information on 

contractor work, upon request from a licensee. NRC is also providing 

invoices in electronic format to some licensees, when requested. 

However, some licensees that would find the information on staff and 

contractor charges useful do not know that it is available, and some NRC 

staff are not aware that they can provide it or how to do so. Until NRC 

communicates to all licensees about what information is available and 

develops a policy and guidance for agency staff, the agency cannot 

ensure that it is providing quality information consistently.

Further, NRC intends to take additional action toward improving its billing 

process and invoices by transitioning to electronic billing. As NRC moves 

forward with this project, developing a project management plan that is 

consistent with best practices, to include establishing plans for the 

project’s schedule and cost, as well as involving licensees in developing 

the plan and assessing the results of implementation, will give the agency 

more reasonable assurance that it is better managing its transition to 

electronic billing and could help ensure that the project meets desired 

outcomes.

We are making the following five recommendations to NRC:

The Chief Financial Officer of NRC should formally communicate to all 

licensees that supplemental billing information—including biweekly 

reports and monthly status reports on contractor charges—is available 

and how to request it. Formal communication that would reach all 

Conclusions

Recommendations for 

Executive Action
Page 21 GAO-18-318 Nuclear Regulatory Commission

licensees could include adding information to their quarterly invoices. 

(Recommendation 1)

The Chief Financial Officer of NRC should develop agency policy and 

guidance for staff on what billing information related to contractor charges 

NRC staff can provide to licensees and how it should be provided. 

(Recommendation 2)

As NRC plans its transition to electronic billing, the Chief Financial Officer 

of NRC should develop a project plan that incorporates standards for 

project management, which includes establishing plans for schedule and 

cost. (Recommendation 3)

In developing the project plan for electronic billing, the Chief Financial 

Officer of NRC should include steps to involve licensees in developing 

system capabilities, which includes soliciting and considering licensees’

information needs. (Recommendation 4)

In developing the project plan for electronic billing, the Chief Financial 

Officer of NRC should include steps to assess the results of implementing 

electronic billing, which includes comparing the actual performance to 

intended outcomes. (Recommendation 5)

We provided a draft of this report to NRC for review and comment. NRC 

provided written comments, which are reproduced in appendix I. In its 

written comments, NRC agreed with our findings and recommendations.

Agency Comments
Page 22 GAO-18-318 Nuclear Regulatory Commission

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

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

report date. At that time, we will send copies to the appropriate 

congressional committees, the Chairman of the Nuclear Regulatory 

Commission, 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 about this report, please contact 

me at (202) 512-3841 or ruscof@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 II.

Frank Rusco

Director, Natural Resources and Environment
Page 23 GAO-18-318 Nuclear Regulatory Commission

List of Requesters

The Honorable John Barrasso

Chairman

Committee on Environment and Public Works

United States Senate

The Honorable Shelley Moore Capito

Chairman

Subcommittee on Clean Air and Nuclear Safety

Committee on Environment and Public Works

United States Senate

The Honorable Greg Walden

Chairman

Committee on Energy and Commerce

House of Representatives

The Honorable Fred Upton

Chairman

Subcommittee on Energy

Committee on Energy and Commerce

House of Representatives
Appendix I: Comments from the Nuclear 

Regulatory Commission

Page 24 GAO-18-318 Nuclear Regulatory Commission

Appendix I: Comments from the Nuclear 

Regulatory Commission
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 25 GAO-18-318 Nuclear Regulatory Commission

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

In addition to the contact named above, Hilary Benedict (Assistant 

Director), Wyatt R. Hundrup (Analyst in Charge), and Breanna Trexler 

made key contributions to this report. Also contributing to this report were 

Ellen Fried, Cindy Gilbert, Heather Keister, Benjamin Licht, Laurel Plume, 

Dan C. Royer, and Barbara Timmerman.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101898)
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