FEDERAL ELECTION COMMISSION

FISCAL YEAR 2021

CONGRESSIONAL BUDGET JUSTIFICATION

February 10, 2020

Concurrently submitted to Congress and the Office of Management and Budget
1 

Table of Contents 

SUMMARY OF FY 2021 BUDGET JUSTIFICATION 2 

MISSION STATEMENT 4 

Section 1: Purpose and Priorities in FY 2021 5 

1A: Commission Overview and Future Outlook 5 

1B: FY 2021 Priorities 8 

Section 2: Budget Overview 11 

2A: OMB Budget Guidance Level 11 

2A.1: Description of Budget Increases and Decreases 14 

2B: Appropriations Language 16 

2C: Recommended Legislative Changes 17 

2D: Federal Election Commission Agency Workforce Plan for 2021 19 

Section 3: FY 2021 Annual Performance Plan and FY 2019 Annual Performance Report 21 

3A: Introduction 21 

3A:1 Mission Statement 21 

3B: Organizational Structure 22 

3C: Performance Framework 25 

3C:1 Strategic Goal 25 

3C:2 Plans and Progress by Strategic Objective 25 

3D: Implementation Factors 44 

3D:1 Major Management Priorities, Challenges and Risks 44 

3D:2 Data Validation and Verification 44 

3E: Conclusion 45 

Office of Inspector General’s Fiscal Year 2021 Budget Request 46 

OIG Summary of Outstanding FEC OIG Audit Recommendations 47 
2 

SUMMARY OF FY 2021 BUDGET JUSTIFICATION

The Federal Election Commission (FEC) is an independent regulatory agency responsible for 

administering, enforcing, defending and interpreting the Federal Election Campaign Act of 1971

(“FECA” or the “Act”), as amended.1

 As the foundation of Federal campaign finance regulation, FECA

reflects Congress’s efforts to prevent corruption through two principal means. First, it ensures that 

voters have access to information about the sources of financial support for Federal candidates, political 

party committees and other political committees. Second, FECA imposes amount limitations and source 

prohibitions on contributions received by certain types of political committees. The Commission’s 

responsibilities also include overseeing the Federal public funding programs for Presidential 

campaigns.2

For the fiscal year (FY) 2021 Budget Submission, the FEC’s total requested funding level is $73.3 

million.

3

 The requested increase for FY 2021 represents growth of approximately two and one-half 

percent from the FEC’s enacted appropriation for FY 2020 and under three percent from the enacted 

appropriations from FY 2016 through FY 2019. The level requested for FY 2020 will help the agency 

meet its priorities and handle the workload generated by the 2020 elections and support the President’s 

Management Agenda. In an average fiscal year, the FEC receives campaign finance reports, statements 

and other disclosure documents from more than 13,000 political committees and other filers. During 

FY 2019, these filers reported more than 100 million financial transactions, which were reviewed by 

FEC staff and disclosed to the public on the FEC’s website. From October 1, 2018 through September

30, 2019, the FEC website’s Application Programming Interface (API), which permits users to 

customize data searches making vast quantities of campaign finance data readily available, received 175 

million hits. 

Recent trends in campaign finance activity illustrate the importance of the agency’s ability to continue 

to implement new programs and systems to ensure the timely disclosure of this increasing volume of 

campaign finance data, including the migration of campaign finance data to a cloud environment and 

efforts to modernize the FEC’s eFiling system. Adequate funding for FY 2021 will be crucial to ensuring 

the FEC meets its mission to provide transparency in the campaign finance process. In addition, during 

and after the 2020 election, which includes a Presidential election, the FEC anticipates processing and 

reviewing historically high levels of campaign finance disclosure filings and meeting an increased 

demand for customer service and data information requests from the public. Historically, after a 

Presidential election, the Office of General Counsel also receives an influx of enforcement cases and 

complaints. In order for the FEC to manage the pressures of increased workload, data processing, and 

customer service requests, the FEC requests a funding level that will ensure the agency is able to 

efficiently, fairly, and effectively achieve its mission. 

Funding at the requested level would also allow the agency to continue its on-going IT modernization 

projects and realize efficiencies to accommodate increased campaign finance transactions. Over the past 

1 Public Law 92-225, 86 Stat. 3 (1972) (codified at 52 U.S.C. §§ 30101-45). 2 The Commission’s responsibilities for the Federal public funding programs are contained in the Presidential Election

Campaign Fund Act, Public Law 92-178, 85 Stat. 562 (1971) (codified at 26 U.S.C. §§ 9001-13) and the Presidential Primary 

Matching Payment Account Act, Public Law 93-443, 88 Stat. 1297 (1974) (codified at 26 U.S.C. §§ 9031-42). 3 As of the date of this Budget Submission, the Commission lacks a quorum of at least four sitting Commissioners. Under the 

Act and Commission Directive 10, this is submitted pursuant to a bipartisan majority vote of current Commissioners. It is not anticipated 

that the Commission will continue to lack a quorum by the start of fiscal year 2021
3 

several years, the FEC has made significant progress to modernize its IT systems and processes. These 

efforts include the redesign of the FEC website and the migration to a cloud environment of the FEC’s 

campaign finance database, which contains over forty years of transaction-level campaign finance data 

reported to the agency. As a result, the FEC has been able to reduce its physical data center footprint. 

To continue to mitigate an anticipated steep rise in future cost from maintaining physical data centers, 

the FEC is pursuing a modernization plan which requires investment now and over the next several years 

to continue cloud migration and realize improvements in its IT processes. Finally, the requested funding 

provides for a scheduled increase in rent for FEC headquarters, increased awards and workforce 

development to support the President’s Management Agenda’s focus in that area, higher retirement costs, 

and an additional FTE. 
4 

MISSION STATEMENT

To protect the integrity of the Federal campaign finance process by providing 

transparency and fairly enforcing and administering Federal campaign finance laws

Congress created the FEC to administer, enforce and formulate policy with respect to FECA. The Act

reflects Congress’s efforts to ensure that voters are fully informed of the sources of financial support for 

Federal candidates, political committees and others and to prevent corruption. Public confidence in the 

political process depends not only on laws and regulations to ensure transparency, but also on the 

knowledge that those who disregard the campaign finance laws will face consequences.

The primary objectives of the FEC are: (1) to engage and inform the public about campaign finance data; 

(2) to promote compliance with FECA and related statutes; (3) to interpret FECA and related statutes;

and (4) to foster a culture of high performance.

Voluntary compliance with the requirements of FECA is a particular focus of the Commission’s efforts, 

and its educational outreach and enforcement programs are both designed to ensure compliance with the 

Act’s limits, prohibitions and disclosure provisions. Because of the large and rising number of political 

committees and the ever-growing number of financial disclosure reports filed with the FEC, voluntary 

compliance is essential to enforcing the requirements of the Act. Accordingly, the Commission devotes 

considerable resources to encouraging voluntary compliance through widespread dissemination of 

educational materials related to Federal campaign finance laws to the public, the press, political 

committees and State election officials.

This Budget Justification is organized in three sections. Section 1 addresses the agency’s purpose and 

priorities in FY 2021. Section 2 provides an overview of the agency’s request. Section 3 provides an 

overview of the agency’s four strategic objectives and describes the agency’s performance goals, 

indicators and targets to ensure continued progress toward meeting these objectives during FY 2021. 
5 

Section 1: Purpose and Priorities in FY 2021

1A: Commission Overview and Future Outlook

The FEC is an independent regulatory agency responsible for administering, enforcing, defending and 

interpreting FECA. The Commission is also responsible for administering the Federal public funding 

programs for Presidential campaigns. 

The FEC is directed by six Commissioners, who are appointed by the President with the advice and 

consent of the Senate. By law, no more than three Commissioners can be members of the same political 

party. The Commissioners meet regularly to formulate policy and to vote on significant legal and 

administrative matters. The Act requires the affirmative vote of four members of the Commission to 

approve official actions, thus requiring bipartisan decision making. 

As part of its responsibilities, the FEC makes available on its website the campaign finance disclosure 

reports all Federal candidates and Federal political committees must file, as required by the Act. These 

disclosure reports and the data contained in them are made available to the public through the 

Commission’s Internet-based public disclosure system on the agency’s website at www.fec.gov. The 

FEC also has exclusive responsibility for civil enforcement of FECA, including the handling of civil 

litigation arising from any legal actions brought by or against the Commission. Additionally, the 

Commission promulgates regulations implementing the Act. The Commission also has a statutory 

responsibility to issue advisory opinions responding to inquiries regarding interpretation and application 

of the Act and the Commission’s regulations to specific factual situations. 

The FEC’s Strategic Plan for FY 2018 through FY 2022, developed pursuant to the Government 

Performance and Results Act of 1993 (GPRA)4 and the GPRA Modernization Act of 2010,5 provides the 

agency’s strategic management framework. This framework is designed to ensure that every employee 

works in support of the FEC’s strategic goal and objectives and that the effectiveness of these efforts 

can be regularly and meaningfully measured. 

4 Public Law 103-62, 107 Stat. 285 (1993) (codified at 31 U.S.C. § 1115 et seq.). 5 Public Law 111-352, 124 Stat. 3866 (2011) (codified at 31 U.S.C. §§ 1115-24).
6 

The FEC is funded by a single annual appropriation for salaries and expenses and is authorized to collect 

fees only to offset the costs of the agency’s educational conferences. Approximately 70 percent of the 

agency’s budget is composed of expenses related to personnel, such as salaries and benefits. Of the 

agency’s remaining operational expenses, the largest categories are IT initiatives, including IT security 

initiatives, and facilities rent. These three requirements constitute 90 percent of the agency’s budget. 

Figure 1 – FY 2021 Budget by Major Category 

Personnel

70%

IT Initiatives

14%

Rent

6%

Other 

10%

FY 2020 Budget Major Categories

Personnel IT Initiatives Rent Other
7 

FEC Organizational Chart 

The Offices of the Staff Director, General Counsel, Chief Information Officer and Chief Financial 

Officer support the agency in accomplishing its mission. The Office of the Inspector General, 

established within the FEC in 1989 under the Inspector General Act Amendments of 1988,6 is 

independent and reports both to the Commissioners and to Congress. The specific roles and 

responsibilities of each office are described in greater detail at http://www.fec.gov/about.shtml. 

6 Public Law 100-504, 102 Stat. 2515 (1988). 
8 

1B: FY 2021 Priorities

The FEC priorities for FY 2021 are in line with the agency’s FY 2018 to 2022 strategic plan and are 

limited to those needs that will allow the agency to fulfill its mission as required by law and support the 

President’s Management Agenda. Funding at the requested amount of $73.3 million would permit the 

FEC to take measures to enhance the delivery of campaign finance data and legal resources. The 

requested funding would also improve the agency’s systems and processes, allowing the Commission to 

reduce dependency on costly legacy systems and improve the efficiency of the agency’s IT 

infrastructure, including migration to cloud-hosted data and services, improvements to the eFiling 

platform and continued enhancements to cyber security and tools. These priorities will ensure that the 

agency can improve customer experience and service delivery as it meets increasing public demand for 

its services. As part of this effort, the agency is prioritizing workforce development and rewarding high 

performing employees. These are the FEC’s priorities for FY 2021, and they are discussed in more detail 

below. 

IT Modernization

The FEC protects the integrity of the Federal campaign finance process by providing transparency and 

fairly enforcing and administering Federal campaign finance laws. Fair enforcement and full disclosure 

of the sources and amounts of campaign funds allow the public to make informed decisions in the 

political process. Transparency requires that information is not only kept by the FEC but also that it is 

provided to the public in a way that is intuitive to users and provides the necessary context for 

understanding how Federal elections are funded. The FEC must make election-related reports and 

information accessible to the public in a timely, reliable and useful fashion. The Commission is therefore 

committed to providing the public with robust access to campaign finance data, compliance information 

and legal resources. Funding at the full requested amount of $73.3 million would permit the FEC to 

improve the quality of services delivered to the public. 

The FEC provides free electronic filing software, FECFile, to support political committees in reporting 

their campaign finance activity to the FEC. During FY 2017, the FEC completed and published a study 

to determine ways to modernize the agency’s eFiling system, platform and software to receive better 

quality data, be more responsive to user needs and handle the increasing volume of data reported.7 

During FY 2018, the FEC began designing a new e-filing platform. In this request, the agency seeks 

funds for FY 2021 to complete the eFiling platform and support its release to the filing community. The 

redesigned eFiling platform will improve ease of filing for users by allowing greater operating system 

flexibility when generating filings for submission to the Commission. The FEC’s new eFiling platform 

will also improve the process for validating filings prior to acceptance and generate modern file outputs 

that will provide for more flexibility in accessing data. In addition, the modernization efforts will provide 

for seamless integration with the data portion of the website and, therefore, more efficient use of the 

agency’s resources. The study of the FEC’s eFiling system showed that 59 percent of electronic filers 

use the agency’s software. Improvements to modernize this tool continues to be an important priority 

for the Commission.

7 Available at https://fec.gov/about/reports-about-fec/agency-operations/e-filing-study-2016/.
9 

In conjunction with the redesign of the agency’s website, the FEC has begun the process of migrating 

appropriate data and systems, such as the campaign finance database, to a cloud environment. Cloud 

hosting offers a number of benefits for the FEC in particular. The agency’s Internet traffic is variable, 

with many more visitors accessing the website during election years and near reporting deadlines. In 

addition to website visitors, filers need to access the electronic filing system and Commission staff need 

to access applications, including the website and databases, to perform their work-day duties. With a 

cloud-hosted application and database infrastructure, the FEC will only need to pay for the actual usage, 

rather than constantly maintaining the capacity to support peak usage, even during periods of reduced 

usage. Website downtime will be minimized and server maintenance will be managed by the cloud 

computing provider. 

In addition, the move to a cloud-hosted model provides the Commission with opportunities to retire a 

number of costly legacy systems and reduce the agency’s data center footprint.8

 For example, the agency 

successfully migrated its campaign finance database and website to a cloud environment and shut down 

one if its four physical data centers. Migrating these assets to a cloud environment significantly lowers 

the cost of maintaining these systems, even as the campaign finance database continues to grow each 

year. Planned improvements to the eFiling system, which was designed in the mid-1990s, will provide 

an opportunity to migrate the eFiling data center to a cloud environment as well, reducing our costs for 

the support and maintenance of the legacy eFiling physical data center. Thus, in addition to improving 

service delivery to the public, migrating to a cloud environment will help the agency to confront the 

increasing long-term costs of maintaining IT legacy systems. 

The FEC is currently conducting a study of its remaining legacy systems to develop a cloud migration 

plan for these applications and systems. There are eleven legacy systems that need to be migrated to the 

cloud including the FEC’s primary disclosure database and systems used on a day-to-day basis by both 

public facing offices and mission support staff. This cloud migration plan will also include 

recommendations for migrating the FEC’s disaster recovery environment to a cloud environment. To 

realize the full value of this study, and to more quickly realize the cost and efficiency benefits of 

migrating appropriate applications and systems to a cloud environment, the FEC request would allow 

the agency to begin implementation of the study’s recommendations. Funding below the requested FY 

2021 level would require the FEC to wait until a future year to implement the next steps of the cloud 

migration project, during which time the value of the current study would degrade and the agency could 

be required to take short-term steps to meet mission requirements, resulting in higher costs over the long 

term.

Managing Customer Experience and Improving Service Delivery

Key to all of these efforts are the FEC’s continuing efforts to maintain the current high performance of 

staff and the excellent service they provide to the public. The Commission has established a series of 

data-driven metrics to measure customer satisfaction with educational outreach efforts and to ensure that 

matters are moved efficiently and fairly through the enforcement and compliance processes, with 

complainants and respondents afforded sufficient transparency regarding the processes. To improve 

8 The FEC’s efforts to reduce spending on operation and maintenance costs is consistent with the Government Accountability 

Office’s May 2016 report, Federal Agencies Need to Address Aging Legacy Systems.
10

customer service, in FY 2021 the FEC plans to roll out a redesigned eFiling platform which is being 

created using customer experience design. The new eFiling system will be user friendly and promote 

regulatory compliance. During FYs 2020 and 2021, the FEC is pursuing a plan to hire staff in publicfacing offices such as the Reports Analysis Division, the Office of the General Counsel, and in the Office 

of the Chief Information Officer to better serve the public’s information needs. In FY 2021, the agency 

will also need to create a new position to comply with government-wide records management directives. 

The FEC is pursuing a hiring initiative to ensure the agency is properly staffed for the substantial and 

likely permanent increase in workload that occurs in a Presidential election year and reflects campaign 

finance trends. The FEC also continues to carefully manage attrition to ensure the agency develops a 

workforce for the 21st Century. The FY 2021 request level of $73.3 million would allow FEC to support 

these efforts and support an updated awards program as called for in OMB’s memorandum on “Guidance 

on Awards for Employees and Agency Workforce Fund Plan,” M-19-24 (July 12, 2019). 
11

Section 2: Budget Overview

2A: OMB Budget Guidance Level 

In this section, pursuant to Office of Management and Budget (OMB) guidance, budget increases and 

decreases are identified, and the fiscal year (FY) 2021 budget request is compared to the Consolidated 

Appropriations Act, FY 2020. For FY 2021, the requested appropriation is $1.8 million more than the 

FY 2020 appropriation, representing a 2.56 percent increase. Three quarters of the increase is due to a 

1 percent pay increase, higher retirement benefits costs, an additional FTE, and cash awards. The 

remainder of the increase is due to an increase in rent expense resulting from the expiration of free and 

reduced rent periods and supplies and materials needed to support workforce development. 

Personnel 

The FEC has historically experienced a spike in customers during years leading up to and including the 

fiscal year of a Presidential election, including increased campaign finance disclosure, increased public 

interest in data available from the FEC website and increased requests for assistance and advice from 

campaigns and filers. The FEC is currently filling high-priority vacancies in anticipation of the 2020 

Presidential and other federal elections and to handle increasing workloads. Consequently, the FEC seeks 

an addition of $1,346,201 above the FY 2020 enacted level to support an increase in awards, personnel 

benefits, and personnel compensation. These funds would provide the agency with vitally needed 

flexibility to fill critical vacancies. In total, this level would support 328 FTE. 

Table 1 

Changes from FY 2020 Personnel Budget to FY 2021 Personnel Budget Request

Category Amount

FY 2020 Personnel Budget $50,310,674

Cash Awards 54,255

Personnel Benefits 319,935

Personnel Compensation 972,011

Total Change: $1,346,201

FY 2021 Personnel Budget Request $51,656,875 
12

Non Personnel 

The FY 2021 request includes funding at FY 2020 levels for non-capitalized and capitalized equipment 

in order to meet the challenges of the 2020 election and to upgrade and refresh hardware. Delaying these 

necessary upgrades raises the risk of performance and security issues resulting from running updated 

software on outdated hardware. In a presidential election year and in the year after, the FEC processes 

an increased number of campaign finance transactions and increases data hosting demand associated 

with making this volume of information secure and accessible. The requested level will ensure the FEC 

is able to achieve it mission of data transparency. 

Funding at the requested level will also continue to support IT modernization projects described above, 

including the eFiling modernization effort. The FEC’s modernized eFiling platform will be administered

by existing FEC staff and hosted in a cloud environment, which will reduce contractor support costs. 

Delaying this investment would imperil these future efficiencies and could diminish the value of prior 

investments in this modernization project.

The agency seeks an additional $485,586 above its FY 2020 budget for non-personnel expenses. Free 

and reduced rent periods for the FEC expired during FY 2020 and rent expense will increase in FY 2021. 

Sixty percent of this increase would be absorbed by utilizing efficiencies from IT modernization efforts, 

strengthening support offices in order to reduce costs for federal goods and services, and reducing travel 

costs. Additional funding would also be used to pay supplies and materials costs associated with

workforce development. 
13

Table 2 

Changes from FY 2020 Appropriation to FY 2021 Budget Request

Category Amount

FY 2020 Appropriation $71,497,000

Personnel Changes 

Personnel Compensation and Benefits 1,346,201

Personnel Changes Subtotal: $1,346,201

Non-Personnel Changes

IT Contracts -279,244

Federal Goods & Services -178,000

Travel -97,195

Supplies & Materials 59,909

GSA Rent 980,116

Non-Personnel Changes Subtotal: $485,586

Total Change: $1,831,787

FY 2021 Budget Request $73,328,787
14

2A.1: Description of Budget Increases and Decreases

Program Increases and Decreases ................................................................................$1,831,787

Personnel Increases ......................................................................................... $1,346,201/+1 FTE 

The personnel increase supports an awards program, consistent with OMB memorandum M-19-

24, and an increased FTE. It supports the agency’s approved staffing strategy and the President’s 

Management Agenda in Developing a Workforce for the 21st Century and would support offices 

vital to the 2020 Presidential election, including the Office of the General Counsel, Office of the 

Chief Information Officer and Reports Analysis Division. 

Non-Personnel Increases and Decreases ........................................................................$485,586

IT Contracts .................................................................................................................... -$279,244 

The agency continues its Information Technology modernization efforts and plans to identify 

associated efficiencies. 

Federal Good and Services ............................................................................................. -$178,000 

The agency is reviewing its Federal agreements for efficiencies, including any efficiencies gained 

from strengthening current offices. 

Travel ................................................................................................................................ -$97,195

This decrease is the result of the Audit Division conducting more in-house audits. The agency has 

exercised this practice when needed as an efficient means of reducing travel related to audits. 

Supplies and Materials .......................................................................................................$59,909 

This increase is to assist the agency with equipping the work force with adequate up-to-date 

supplies and materials. 

GSA Rent ...........................................................................................................................$980,116 

In FY 2018, the agency moved into a new facility. Incorporated in the lease agreement were free

and reduced rent periods in the early years of the lease. The periods of free and reduced rent have 

expired, requiring an increase for GSA Rent.

 
15

Table 2 highlights the FY 2021 OMB Budget Request as compared to the President’s FY 2020 appropriation and FY 2019 actual 

obligations. 

Table 3 

FY 2021 Budget Request Object Class Data

Object Class Data 

Federal Election 

Commission

FY 2019 Actual FY 2020 

Enacted 

FY 2021 

Budget 

Request

Change from FY 

2020 Enacted to 

FY 2021 Budget 

Request

% Change from 

FY 2020 Enacted

to FY 2021 Budget 

Request

11 Personnel Compensation 35,294,095 37,671,320 38,643,331 972,011 2.58% 

11.52 Cash Awards 512,373 575,000 629,255 54,255 9.44%

12.1 Personnel benefits 11,149,316 11,648,609 11,968,544 319,935 2.75%

12.18 Transit Subsidy 324,552 415,745 415,745 0 -

 Subtotal, Personnel $47,280,336 $50,310,674 $51,656,875 $1,346,201 2.68% 

21 Travel & transportation of persons 139,667 347,200 250,005 -97,195 -27.99% 

23.1 GSA Rent 432,351 4,243,450 5,223,566 980,116 23.10%

23.3 Communications, Utilities & Postage 545,586 469,259 469,259 0 - 

24 Printing & Reproduction 152,279 156,940 156,940 0 -

25.11 Training, Commercial Fed. & Tuition 552,365 629,705 629,705 0 - 

25.14 IT Contracts 9,696,393 8,000,000 7,720,756 -279,244 -3.49%

25.2 Contracts & Other Services 1,583,475 2,750,750 2,750,750 0 - 

25.3 Federal Goods & Services 3,432,561 1,791,000 1,613,000 -178,000 -9.94%

26 Supplies and Materials 797,014 1,104,266 1,164,175 59,909 5.43%

31 Non-Capitalized and Capitalized 

Equipment 3,911,737 1,693,756 1,693,756 0 - 

 Subtotal, Non-Personnel $21,243,428 $21,186,326 $21,671,912 $485,586 2.29%

 TOTAL $68,523,764 $71,497,000 $73,328,787 $1,831,787 2.56%
16

2B: Appropriations Language 

The FEC’s request includes the funding level necessary to support the agency’s mission and represents 

a 2.56 percent increase above the FY 2020 funding level. The FEC is including the following 

Appropriations Language: 

FEDERAL ELECTION COMMISSION

Federal Funds 

Salaries and Expenses

For necessary expenses to carry out the provisions of the Federal Election Campaign Act of 1971, 

$73,328,787, of which not to exceed $5,000 shall be available for reception and representation expenses. 
17

2C: Recommended Legislative Changes 

On December 13, 2018, the Commission submitted legislative recommendations to Congress and the 

Administration.

9

 Two of these recommendations represent bold proposals to streamline processes for 

disclosing campaign finance data to the public and ensure that the agency can provide more timely 

disclosure of reported campaign finance data at a lower cost to taxpayers. These initiatives require 

statutory changes to be enacted through legislation, and proposed statutory language for each was 

approved by the Commission and provided to the Congress and the Administration. 

Electronic Filing of Electioneering Communication Reports

Section: 52 U.S.C. § 30104(a)(11)(A)(i) 

Recommendation: Congress should require reports of electioneering communications to be 

filed electronically with the Commission, rather than on paper. 

Explanation: The Treasury and General Government Appropriations Act, 2000, Pub. L. 

No. 106-58, § 639, 113 Stat. 430, 476 (1999), required the Commission to make electronic 

filing mandatory for political committees and other persons required to file with the 

Commission who, in a calendar year, have, or have reason to expect to have, total contributions 

or total expenditures exceeding a threshold amount set by the Commission (which is currently 

$50,000). In addition, many independent expenditure reports are already subject to mandatory 

electronic filing under 52 U.S.C. § 30104(a)(11)(A)(i). However, because electioneering 

communication reports are not filed by political committees, and because funds spent for 

electioneering communications are reported as “disbursements,” and not as “expenditures,” the 

mandatory electronic filing provisions do not apply to electioneering communication reports. 

Compared to data from paper reports, data from electronically filed reports is received, 

processed and disseminated more easily and efficiently, resulting in better use of resources. 

Reports that are filed electronically are normally available to the public, and may be 

downloaded, within minutes. In contrast, the time between the receipt of a report filed through 

the paper filing system and its initial appearance on the Commission’s web site is 48 hours. 

Electronic filings are not subject to delay due to post office processing or disruptions in the 

delivery of mail, such as those arising from security measures put in place after the discovery 

of anthrax powder and ricin in mail. Because of these security measures, the Commission’s 

receipt of mailed paper filings is delayed. In contrast, electronic filings are not subject to these 

delays. 

Only entities that report more than $50,000 of electioneering communications would be subject 

to mandatory electronic filing under the proposal. The current threshold selected by the 

Commission ensures that entities with limited financial resources can file reports on paper, 

which avoids the limited cost of internet access and a computer sufficient to file reports. 

 

9 https://www.fec.gov/resources/cms-content/documents/legrec2018.pdf. The Commission did not issue legislative 

recommendations in 2019.
18

Increase and Index for Inflation Registration and Reporting Thresholds

Sections: 52 U.S.C. §§ 30101, 30104 and 30116 

Recommendation: Congress should increase and index for inflation certain registration and 

reporting thresholds in the Federal Election Campaign Act that have not been changed since the 

1970s. 

Explanation: Most of the Federal Election Campaign Act’s contribution limits and registration 

and reporting thresholds were set in the 1970s. Because over twenty years of inflation had 

effectively reduced FECA’s contribution limits in real dollars, the Bipartisan Campaign Reform 

Act of 2002 increased most of the Act’s contribution limits to adjust for some of the effects of 

inflation. Furthermore, BCRA indexed these limits for inflation to address inflation in future. 

The Commission proposes extending this approach to registration and reporting thresholds, 

which have been effectively reduced by inflation since those thresholds were established in 

1971 or 1979. 

Since 1971, FECA has provided that any group of persons that receives contributions or makes 

expenditures in excess of $1,000 in a calendar year must register and report as a political 

committee. 52 U.S.C. § 30101(4)(A). FECA also requires political committees to abide by the 

contribution limits and source prohibitions specified in FECA. Since 1979, FECA has 

provided that local political party organizations are also subject to a $1,000 threshold for 

federal political committee status. 52 U.S.C. § 30101(4)(C). The Commission recommends 

that Congress increase these thresholds to amounts determined appropriate by Congress, and 

then index those amounts for inflation to prevent erosion in the future. Raising this threshold 

would be particularly beneficial for local and Congressional district committees of political 

parties. These organizations frequently breach the $1,000 threshold. An increased threshold 

would permit limited spending on federal elections without triggering federal political 

committee status for local and Congressional district committees of political parties.

Since 1979, FECA has required persons (other than political committees) who make 

independent expenditures in excess of $250 in a calendar year to report such expenditures to 

the Commission. 52 U.S.C. § 30104(c)(1). The Commission recommends that Congress 

increase this threshold to an amount determined by Congress and index this amount for 

inflation. 

Increasing these thresholds would take into account many years of inflation and the general 

increase in campaign cost and ease the compliance burdens on smaller organizations and 

individuals. Additionally, by increasing the thresholds, Congress would exempt some 

individuals and small organizations that engage in only minimal spending from the Act’s 

registration and reporting requirements. Increasing the registration and reporting thresholds to 

compensate for inflation would leave significant financial activity subject to regulation as 

intended by Congress when it enacted the FECA.
19

2D: Federal Election Commission Agency Workforce Plan for 2021 

The Commission understands that its greatest resource is its employees, and the agency is committed to 

providing a working environment that promotes and supports the best efforts of its staff. The FEC 

maintains a program to provide ratings-based awards for employees who show sustained excellence in 

their work throughout the year. This program supports the FEC’s Strategic Objective to foster a culture 

of high performance. In addition, the FEC’s strategic planning framework provides alignment between 

the FEC’s strategic goal and objectives and the work of individual offices and divisions, as reflected in 

performance appraisals. The FEC launched a revised performance appraisal system for Non-Bargaining 

Unit Employees (NBUE) in the 2013-2014 performance year that directly ties individual performance 

to agency performance objectives, and has made efforts to ensure that employee performance plans 

reflect the agency’s strategic goal.

For FY 2021, the agency intends to increase awards spending by at least 1 percent of non-SES/SL salary 

spending in 2021 to support the President’s Management Agenda in this area. All employees, except 

Commissioners, are eligible for awards. The agency anticipates spending $629,255 on awards in FY 

2021. 

Ratings-Based Awards

Under the 2013 Labor Management Agreement between the FEC and the National Treasury Employees 

Union, as amended in 2015 (LMA), a Bargaining Unit Employee (BUE) receives a ratings-based award 

when an employee’s overall performance rating is at the “Exceeds Requirements” level or higher. Under 

the LMA, awards amounts are determined according to a formula based on the employee’s summary 

rating level and the employee’s salary. This formula serves to ensure that ratings-based awards are 

allocated in a manner that provides a meaningful distinction in performance. 

The FEC determines the amounts of ratings-based awards for Non-Bargaining Unit Employees (NBUEs)

based on a parallel calculation that applies to the NBUE performance appraisal rating system. For both 

BUE and NBUE, no award will be given if the employee receives a rating of “unacceptable” on any 

element of the performance appraisal.

BUE Performance Awards Calculation 

Summary Rating / Percentage of Mid-Point Salary

4.0 to 4.24 .75% 

4.25 to 4.49 1.00% 

4.50 to 4.99 1.75% 

5.00 2.75% 
20

NBUE Performance Awards Calculation 

Summary Rating / Percentage of Mid-Point Salary

400 to 424 .75% 

425 to 449 1.00% 

450 to 474 1.75% 

474 to 500 2.75% 

The LMA further specifies that, in years where there are insufficient funds to provide bargaining unit 

employees awards in amounts indicated by the LMA because the total funds available for BUE and 

NBUE is insufficient, the FEC will reduce all ratings-based awards by the same amount. 

Individual Contributions Awards 

The FEC terminated its individual contributions awards program in part due to budget and management 

constraints. The FEC is considering ways to re-implement the program for individual contributions 

awards, which provided recognition for employees and teams in areas of strategic values, such as 

innovation, teamwork, and special acts. The FEC is currently researching how to re-implement this 

program for the 2020 fiscal year. As we consider re-implementing the program, the FEC wants to ensure 

that individual contributions awards align with agency strategic goals and support organizational values, 

and that appropriate mechanisms are in place to evaluate the effectiveness of the awards. 
21

Section 3: FY 2021 Annual Performance Plan and FY 2019 Annual Performance 

Report

3A: Introduction

This Annual Performance Plan and Report (APP/APR) is considered the companion to the Federal 

Election Commission’s Strategic Plan for Fiscal Years (FY) 2018-2022, and designed to provide a solid 

framework for performance planning and reporting in accordance with the requirements of the GPRA 

Modernization Act of 2010.

10 The FY 2021 Annual Performance Plan and FY 2019 Annual Performance 

Report are combined in this document to present accomplishments through FY 2019 and performance 

targets associated with FYs 2019, 2020 and 2021. 

This plan positions the agency to promote compliance and to engage and inform the public about 

campaign finance data and rules. In order to meet these challenges, the FEC must maintain a workforce 

that is highly qualified to achieve the agency’s mission effectively and efficiently. 

3A:1 Mission Statement 

To protect the integrity of the Federal campaign finance process by providing transparency and fairly 

enforcing and administering Federal campaign finance laws.

 

10 The President’s Budget identifies the lower-priority program activities, where applicable, as required under the GPRA

Modernization Act, 31 U.S.C. 1115(b)(10). The public can access the volume at: http://www.whitehouse.gov/omb/budget.
22

3B: Organizational Structure

The FEC is an independent regulatory agency responsible for administering, enforcing, defending and 

interpreting the Federal Election Campaign Act (the Act).

11 The Commission is also responsible for 

administering the Federal public funding programs for Presidential campaigns. This responsibility 

includes certifying and auditing all participating candidates and committees and enforcing the public 

funding laws. 

Under the Act, all Federal political committees, including the committees of Presidential, Senate and 

House candidates, must file reports of receipts and disbursements. The FEC makes disclosure reports 

available to the public through the Commission’s Internet-based public disclosure system at 

www.fec.gov as well as through a public records office at the Commission's Washington, D.C. 

headquarters. The FEC also has exclusive responsibility for civil enforcement of the Act, and has 

litigating authority independent of the Department of Justice in U.S. District Court and the Courts of 

Appeals. Additionally, the Commission promulgates regulations implementing the Act and issues 

advisory opinions responding to inquiries. 

To accomplish its legislative mandate, the FEC is directed by six Commissioners, who are appointed by 

the President with the advice and consent of the Senate. By law, no more than three Commissioners 

may be members of the same political party. Each member serves a six-year term, and two seats are 

subject to appointment every two years. Commissioners may serve beyond their six-year terms until new 

Commissioners are confirmed. The Chairmanship of the Commission rotates among the members. The 

Commissioners are responsible for administering and enforcing the Act and meet regularly to formulate 

policy and to vote on significant legal and administrative matters. The Act requires at least four votes 

for the Commission to approve official actions, thus requiring bipartisan decision-making. The FEC has 

its headquarters in Washington, D.C. and does not have any regional offices.

 

11 The Commission’s primary responsibilities pertain to the Federal Election Campaign Act of 1971, Public Law 92-225, 86 

Stat. 3 (1972) as amended (codified at 52 U.S.C. §§ 30101-30145) (formerly at 2 U.S.C. §§ 431-55) (the Act or the FECA).

The Commission’s responsibilities for the Federal public funding programs are contained in the Presidential Election 

Campaign Fund Act, Public Law 92-178, 85 Stat. 562 (1971) (codified at 26 U.S.C. §§ 9001-13) and the Presidential 

Primary Matching Payment Account Act, Public Law 93-443, 88 Stat. 1297 (1974) (codified at 26 U.S.C. §§ 9031-42). 
23

Figure 1: FEC Organizational Chart 

As noted in Figure 1 above, the offices of the Staff Director, General Counsel, Chief Information Officer 

and Chief Financial Officer support the agency in accomplishing its mission. The Office of the Inspector 

General, established within the FEC in 1989 under the 1988 amendments to the Inspector General Act, 

is independent and reports both to the Commissioners and to Congress. The specific roles and 

responsibilities of each office are described in greater detail immediately below.

 Office of the Staff Director (OSD)

The Office of the Staff Director consists of four offices: 1) Management and Administration; 2) 

Compliance; 3) Communications; and 4) Equal Employment Opportunity. The Office of Management 

and Administration is responsible for the FEC’s strategic planning and performance and works with the 

Commission to ensure the agency’s mission is met efficiently. In addition, this office houses the 

Commission Secretary, the Office of Human Resources (OHR) and the Administrative Services Division 

(ASD). The primary responsibilities of the Office of Compliance are making campaign finance reports 

and data available to the public, review of campaign finance reports, assistance with compliance, audits, 

administrative fines and alternative dispute resolution. The Office of Communications includes 

divisions charged with making enforcement, policy and other Commission documents, as well as 
24

Presidential candidates’ personal financial disclosure reports, available to the public, encouraging 

voluntary compliance with the Act through educational outreach and training, and ensuring effective 

communication with Congress, executive branch agencies, states, the media and researchers, and the 

general public. The Equal Employment Opportunity Office administers and ensures compliance with 

applicable laws, regulations, policies and guidance that prohibit discrimination in the Federal workplace 

based on race, color, national origin, religion, age, disability, sex, pregnancy, genetic information or 

retaliation. The EEO Officer reports to the Staff Director on administrative issues, but has direct 

reporting authority on all EEO matters. See 29 CFR 1614.102(b)(4). 

 Office of General Counsel (OGC)

The Office of General Counsel consists of five organizational units: (1) the Deputy General Counsel—

Administration; (2) the Deputy General Counsel—Law; (3) the Policy Division; (4) the Enforcement 

Division; and (5) the Litigation Division. The Deputy General Counsel—Administration directly 

supervises the Administrative Law Team, the Law Library and all OGC administrative functions. The 

Deputy General Counsel—Law has the primary responsibility for assisting the General Counsel in all of 

the substantive aspects of the General Counsel’s duties and shares in the management of all phases of 

OGC programs, as well as directly supervising the agency’s ethics program. The Policy Division drafts 

for Commission consideration advisory opinions and regulations interpreting the Federal campaign 

finance law and provides legal advice to the FEC’s compliance programs. The Enforcement Division 

recommends to the Commission appropriate action to take with respect to administrative complaints and 

apparent violations of the Act. Where authorized, the Enforcement Division investigates alleged 

violations and negotiates conciliation agreements, which may include civil penalties and other remedies. 

If an enforcement matter is not resolved during the administrative process, the Commission may 

authorize suit in district court, at which point the matter is transferred to the Litigation Division. The 

Litigation Division represents the Commission before the Federal district and appellate courts in all civil 

litigation involving campaign finance statutes. This Division assists the Department of Justice’s Office 

of the Solicitor General when the Commission’s FECA cases are before the Supreme Court. 

 Office of the Chief Information Officer (OCIO)

The Office of the Chief Information Officer (OCIO) consists of four units: (1) Enterprise Architecture; 

(2) Operational Support; (3) Data Administration; and (4) IT Security. The OCIO provides secure, stable 

and robust technology solutions for Commission staff and the public. OCIO both develops and maintains 

the systems that serve as the public's primary source of information about campaign finance data and 

law and ensures agency employees have a technology infrastructure that allows them to perform their 

day-to-day responsibilities administering and enforcing campaign finance law. OCIO also develops and 

supports analytic reporting tools that help staff perform their disclosure and compliance duties. 

 Office of the Chief Financial Officer (OCFO)

The Office of the Chief Financial Officer is responsible for complying with all financial management 

laws and standards, and all aspects of budget formulation, budget execution and procurement. 
25

3C: Performance Framework 

3C:1 Strategic Goal 

The strategic goal of the Federal Election Commission is to fairly, efficiently and effectively administer 

and enforce the Federal Election Campaign Act, promote compliance and engage and inform the public 

about campaign finance data and rules, while maintaining a workforce that delivers results.

3C:2 Plans and Progress by Strategic Objective 

The Act reflects a belief that democracy works best when voters can make informed decisions in the

political process—decisions based in part on knowing the sources of financial support for Federal 

candidates, political party committees and other political committees. As a result, the FEC’s first 

strategic objective is to inform the public about how Federal campaigns and committees are financed. 

Public confidence in the political process also depends on the knowledge that participants in Federal 

elections follow clear and well-defined rules and face consequences for non-compliance. Thus, the

FEC’s second strategic objective focuses on the Commission’s efforts to promote voluntary 

compliance through educational outreach and to enforce campaign finance laws effectively and fairly. 

The third strategic objective is to interpret the FECA and related statutes, providing timely guidance 

to the public regarding the requirements of the law. The Commission also understands that 

organizational performance is driven by employee performance and that the agency cannot 

successfully achieve its mission without a high-performing workforce that understands expectations 

and delivers results. Consequently, the FEC’s fourth strategic objective is to foster a culture of high 

performance in order to ensure that the agency accomplishes its mission efficiently and effectively. 

The FEC’s strategies for reaching these objectives are outlined below.

3C:2.1 Strategic Objective 1: Engage and Inform the Public about Campaign Finance Data

Leaders: Assistant Staff Director for Reports Analysis Division; Assistant Staff Director for Public 

Disclosure and Media Relations Division 

The FEC protects the integrity of Federal campaigns by providing transparency and fairly enforcing and 

administering Federal campaign finance laws. Full disclosure of the sources and amounts of campaign 

funds and fair enforcement of Federal campaign finance laws allow the public to make informed 

decisions in the political process. Transparency requires that information is not only kept by the FEC, 

but also provided to the public in an easily accessible way. In order to make certain that campaign finance 

disclosure information is quickly available and easily accessible to the public, the agency has made a 

number of improvements to modernize its campaign finance disclosure database and public interface. 

Specifically, the FEC has developed application programming interfaces (APIs) and other tools to 

improve access to campaign finance data. The agency is also committed to providing excellent customer 

service to help the public find and understand campaign finance information. The FEC gauges its 

effectiveness through a series of indicators designed to measure performance in areas that promote 

confidence in the campaign finance process, as detailed in the charts below. 
26

Strategies and Next Steps 

The FEC’s eFiling system acts as the point of entry for submission of electronically filed campaign 

finance reports, providing faster access to reports and streamlining operations. This system provides for 

public disclosure of electronically filed reports, via the FEC website, within minutes of being filed. 

When a committee files a financial disclosure report on paper, the Commission ensures that a copy is 

available for public inspection within 48 hours of receipt, both electronically on the website and at the 

FEC’s offices in Washington, D.C. The FEC is committed to providing timely and transparent campaign 

finance disclosure to the public and delivering data in accessible and easy-to-use formats. 

During FYs 2020 and 2021, the FEC will continue work to upgrade the agency’s eFiling platform. In

FY 2017, the Commission published a study of its current eFiling platform, including a survey of the 

existing functionality of the FEC’s free filing software and an in-depth investigation of needs expressed 

by filers.12 The FEC will rely on the recommendations of this study to improve its eFiling platform to 

allow greater operating system flexibility for users when generating filings for submission to the 

Commission and increase the consistency and accuracy of reporting. The FEC’s new eFiling platform 

is expected to improve the process for validating filings prior to acceptance and generate modern file 

outputs that will provide for more flexibility in accessing data.

The Commission is continuing the redesign of its website by developing a user-centered online platform 

to deliver campaign finance information to its diverse base of users. This effort will ensure that the FEC 

provides full and meaningful campaign finance data and information in a manner that meets the public’s 

increasing expectations for data customization and ease of use.

Performance measures for assessing progress on this Strategic Objective include measures to ensure that 

data from campaign finance reports are quickly made available to the public and that the FEC pursues 

programs to make data more accessible to the public.

 

12 Available at https://fec.gov/about/reports-about-fec/agency-operations/e-filing-study-2016/.
27

Progress Update for FY 2019 

The FEC continued its work to receive and make public campaign finance disclosure information. The 

FEC received 90,618 campaign finance disclosure documents filed during FY 2019 disclosing more than 

100 million transactions. Reports filed electronically are made available on the FEC website, and may 

be downloaded by the public within minutes of submission. Reports filed on paper are scanned and 

made available on the FEC website within 48 hours of receipt. During FY 2019, the FEC ensured that 

100 percent of paper filed reports were made available to the public within two business days and that 

100 percent of independent expenditure filings were made available to the public within one business 

day. 

After reports are imaged for disclosure purposes, the information is coded and entered into the FEC’s 

database for review to assess accuracy and ensure complete disclosure of campaign finance information. 

The agency’s goal is to code and enter 95 percent of the reports within 30 days of receipt. In FY 2019 

the agency processed 94 percent of reports within 30 days of receipt. 

In July 2018, the FEC began development of a cloud-based eFiling platform. The new eFiling 

platform will be browser based and mobile friendly. The cloud-based system will allow the FEC to 

scale up and down easily to match computing power and storage to fluctuating needs. 

During FY 2019, the FEC completed development of the infrastructure to support the new eFiling 

platform. Development of the general user interface and the ability to validate, render and print reports 

and statements is complete. Functionality to provide account management, a suite of forms and 

schedules, data conversion tools and responsive design are pending development. 

Performance Goal 1-1: Improve the public’s access to information about how campaign 

funds are raised and spent.

Key Indicator: Percent of reports processed within 30 days of receipt.

FY 2014

Actual

FY 2015

Actual

FY 2016

Actual

FY 2017 

Actual

FY 2018

Actual

FY 2019

Target

FY 2019

Actual

FY 2020 

Target

FY 2021

Target

79% 92% 100% 96% 100% 95% 94%13 95% 95%

 

13 The agency’s ability to meet its target for this performance goal during FY 2019 was negatively impacted by the lapse in 

appropriations from December 22, 2018 to January 25, 2019.
28

Supporting Indicators 1-1:

Measure Name FY 2014

Actual

FY 2015

Actual

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Target

FY 2019

Actual

FY 2020

Target

FY 2021

Target

Percent of 

reports and 

statements filed 

on paper with 

the FEC made 

available on the 

FEC website 

within two 

business days of 

receipt

100% 91%14 99% 99% 99% 100% 100% 100% 100%

Percent of 24-

and 48-hour 

reports on 

independent 

expenditure 

spending filed on 

paper made 

available on the 

FEC website 

within one 

business day of 

receipt

100% 100% 100% 100% 100% 100% 100% 100% 100%

Implement 

modernized 

eFiling system

N/A N/A N/A N/A 100% 50%

implementation

40% N/A N/A

3C:2.2 Strategic Objective 2: Promote Compliance with the FECA and Related Statutes

Leaders: Deputy Staff Director/Chief Compliance Officer; Deputy General Counsel—Administration; 

Deputy General Counsel—Law; Assistant Staff Director, Information Division

Helping the public understand its obligations under the Act is an essential component of voluntary 

compliance. The FEC places a significant emphasis on encouraging compliance. The FEC measures its 

progress in meeting this Objective through two performance measures, discussed separately below. The 

first measures the agency’s efforts to encourage voluntary compliance through educational outreach and 

information and the second measures the FEC’s efforts to seek adherence to FECA requirements through 

fair, effective and timely enforcement and compliance programs. Progress against these measures and 

supporting indicators is detailed in the charts below. 

Strategies and Next Steps 

Encourage voluntary compliance with FECA requirements through educational outreach and information.

The FEC’s education and outreach programs provide information necessary for compliance with 

campaign finance law and give the public the context necessary to interpret the campaign finance data 

 

14 During FY 2015, the Commission developed an automated process to measure this metric in order to provide a more accurate

assessment.
29

filers disclose. The FEC maintains a toll-free line and public email accounts to respond to inquiries 

regarding campaign finance data disclosed to the public and questions about how to comply with 

campaign finance law and its reporting requirements. The FEC’s Public Disclosure and Media Relations 

Division and Congressional Affairs Office also respond to inquiries. 

One way the Commission encourages voluntary compliance is by hosting conferences across the 

country, where Commissioners and staff explain how the Act applies to candidates, parties and political 

action committees. These conferences address recent changes in the law and focus on fundraising, 

methods of candidate support and reporting regulations. 

The FEC also devotes considerable resources to ensuring that staff can provide distance learning 

opportunities to the general public. The Commission’s website is one of the most important sources of 

instantly accessible information about the Act, Commission regulations, and Commission proceedings. 

In addition to viewing campaign finance data, anyone with Internet access can use the website to track 

Commission rulemakings, search advisory opinions, audits and closed enforcement matters, view 

campaign finance data, and find reporting dates. The Commission places a high emphasis on providing 

educational materials about campaign finance law and its requirements. Toward this end, the FEC has 

moved its focus away from the printing and manual distribution of its educational materials and instead 

looked for ways to leverage available technologies to create and disseminate dynamic and up-to-date 

educational materials through the website. While the Commission continues to make available printed 

copies of its educational brochures and publications, transitioning to primarily web-based media has 

allowed the agency to reduce significantly its printing and mailing costs and use of resources while at 

the same time encouraging new and expanded ways of communicating with the public via the website. 

As part of this broad effort to improve its Internet communications and better serve the educational needs 

of the public, the Commission maintains its own YouTube channel, which can be found at 

http://www.youtube.com/FECTube. The YouTube channel offers a variety of instructional videos and 

tutorials that enable users to obtain guidance tailored to their specific activities. 

The agency’s educational outreach program has been significantly enhanced with the addition of an 

online training service that enables political committees, reporters, students and other groups to schedule 

live, interactive online training sessions with FEC staff. This on-demand service allows the FEC to 

provide tailored, distance learning presentations and training to the public in a manner that will 

significantly increase the availability of FEC staff to serve the public. The service also offers an efficient 

and effective way for alternative dispute resolution and other enforcement respondents to satisfy the 

terms of their agreements with the agency. 

Seek adherence to FECA requirements through fair, effective and timely enforcement and compliance 

programs.

The FEC has formed strategies for ensuring that its enforcement and compliance programs are fair, 

effective and timely. The Commission’s statutory obligation is to administer, interpret and enforce the 

Federal Election Campaign Act, which serves the compelling governmental interest in deterring 

corruption and the appearance of corruption in financing elections. In doing so, the Commission remains 

mindful of the First Amendment’s guarantees of freedom of speech and association, and the practical 

implication of its actions on the political process. 
30

The FEC has exclusive jurisdiction over civil enforcement of Federal campaign finance laws. It consults 

with the U.S. Department of Justice, as appropriate, on matters involving both civil and criminal 

enforcement of the Act. Commission enforcement actions, which are handled primarily by the Office of 

General Counsel (OGC), originate from a number of sources, including external complaints, referrals 

from other government agencies and matters generated by information ascertained by the Commission 

in the normal course of carrying out its supervisory responsibilities. Enforcement matters are handled 

by OGC pursuant to the requirements of the FECA. If the Commission cannot settle or conciliate a 

matter involving an alleged violation of the Act, the Commission may initiate civil litigation by filing 

and prosecuting a civil action in Federal district court to address the alleged violation. Closed 

enforcement matters are available via the FEC website.

To augment OGC’s traditional enforcement role, the Office of Compliance manages several programs 

that seek to remedy alleged violations of the Act and encourage voluntary compliance. These programs 

include: 1) the Alternative Dispute Resolution Program, 2) the Administrative Fine Program and 3) the 

Audit Program. The Commission’s Alternative Dispute Resolution Program is designed to resolve 

matters more swiftly by encouraging the settlement of less-complex enforcement matters with a 

streamlined process that focuses on remedial measures for candidates and political committees, such as 

training, internal audits and hiring compliance staff. Violations involving the late submission of, or 

failure to file, disclosure reports are subject to the Administrative Fine Program. This Program is 

administered by the Reports Analysis Division (RAD) and the Office of Administrative Review (OAR), 

which assess monetary penalties and handle challenges to the penalty assessments. The Audit Program 

conducts “for cause” audits under the FECA in those cases where political committees have failed to 

meet the threshold requirements for demonstrating substantial compliance with the Act, and conducts 

mandatory audits under the public funding statutes. Subject to limited redactions, threshold 

requirements approved by the Commission and used by RAD and the Audit Division are public. 

The Office of Compliance’s Reports Analysis Division (RAD) reviews an ever-increasing volume of 

reports to track compliance with the law and to ensure that the public record provides a full and accurate 

representation of reported campaign finance activity. If the FEC’s review identifies an apparent 

violation or raises questions about the information disclosed on a report, RAD sends a request for 

additional information (RFAI letter) to the filer, affording an opportunity to take remedial action or

correct the public record, if necessary. If the filer is able to resolve the FEC’s concerns, it may avoid an 

enforcement action. If not, the Commission has several tools available to it, such as the Administrative 

Fine Program, Audit Program, the Alternative Dispute Resolution Program and the traditional 

enforcement program.

The Alternative Dispute Resolution (ADR) Program was implemented in FY 2001 with the primary 

objective to enhance the agency’s overall effectiveness through more expeditious resolution of 

enforcement matters with fewer resources required to process complaints and internal referrals. A case 

is closed when the Commission votes on the recommendation made by the ADR Office as to what final 

action should be taken. 

In response to a legislative mandate, an Administrative Fine (AF) Program was implemented in July 

2000 to address late and non-filing of disclosure reports in a more efficient and effective manner. The 

AF Program is administered by RAD and Office of Administrative Review (OAR), which are within the 

Office of Compliance. 
31

The Commission generally conducts audits when a committee appears not to have met the threshold 

requirements for substantial compliance. The audit determines whether the committee complied with 

the limitations, prohibitions and disclosure requirements of the Act. In addition, the Commission is 

required by law to audit Presidential campaigns that accept public funds. 

Progress Update for FY 2019

Encourage voluntary compliance with FECA requirements through educational outreach and information.

During FY 2019, the Commission continued to meet its mandate to assist the public by providing access 

to campaign finance compliance information. The Commission is deeply committed to providing 

candidates, committees and the public timely advice and support so they can fully understand and 

comply with the Act. The Commission also continues to strive to better understand and meet the needs 

of the public and other stakeholders. During FY 2019, the FEC produced a variety of instructional 

videos and web content, conducted online training workshops and held a comprehensive two-day 

conference in Chicago, Illinois. The FEC again exceeded its customer service target for conferences 

and webinars, achieving an average attendee satisfaction rating of 4.45 on a five point scale. 

Seek adherence to FECA requirements through fair, effective and timely enforcement and compliance 

programs. 

Reports Analysis Division

During FY 2019, RAD continued to ensure that campaigns and political committees file timely and 

accurate disclosure reports that fully disclose their financial activities. During the fiscal year, RAD 

reviewed 93,060 documents totaling 34.9 million pages. RAD continued to demonstrate its commitment 

to assisting filers with compliance, handling 12,562 phone calls and meetings, 658 electronic mail 

inquiries, developing reporting examples for the FEC website, and participating in several FEC 

conferences, seminars and webinars during FY 2019. In addition, the Reports Processing Branch 

demonstrated its commitment to providing the public with timely data, coding 26.4 million transactions 

during FY 2019.

Office of General Counsel

OGC continues to seek improvement in meeting its obligations to the Commission and the public to 

handle its caseload efficiently and effectively despite staffing challenges. In FY 2019, the Commission 

closed 189 enforcement cases in an average of 21 months, which included $2,153,036 in negotiated civil

penalties. The Commission closed 106 cases (56 percent) within 15 months. 

Alternative Dispute Resolution

The ADR program continued to promote compliance with Federal campaign finance law and 

Commission regulations and to reduce the cost of processing complaints by encouraging settlements 

outside the agency’s normal enforcement track. During FY 2019, the Commission completed 49 ADR 

cases, which included $265,755 in negotiated civil penalties. The Commission’s performance measure 

for ADR is to circulate 75 percent of cases to the Commission within 140 days of a case being referred. 

Seventy percent of cases met the 140-day benchmark. The ADR program’s ability to meet its target for 

this performance goal during FY 2019 was negatively impacted by the lapse in appropriations from 
32

December 22, 2018 to January 25, 2019. 

Administrative Fine Program

The Administrative Fine Program continues to successfully reduce the number of late and non-filed 

reports and encourage campaign finance transparency through the timely filing of campaign finance 

reports. During FY 2019, RAD processed 262 reason-to-believe recommendations for Commission 

consideration. RAD processed 88 percent of these recommendations within 60 days of the original due 

date of the untimely or not filed report. OAR reviewed 37 challenges submitted by committees in 

response to a reason-to-believe finding and/or civil money penalty. OAR reviewed 97 percent of these 

challenges within 60 days of receipt. The average completion time for challenges was 43 days. Overall, 

OAR has reviewed 790 challenges submitted from the Program’s inception through FY 2019 

Audit Division

The Audit Division continues to enforce the FECA through an audit process approved by the 

Commissioners each cycle. During FY 2019, the Audit Division publicly released 10 Audit Reports, all 

of which were completed within the two-year performance goal period. During FY 2019 there were no

challenges to preliminary audit findings under the Request for Legal Consideration by the Commission 

program established in 2011, nor were there any Audit Hearings requested. 
33

Performance Goal 2-1: Encourage voluntary compliance with FECA requirements 

through educational outreach and information.

Key Indicator: Educational outreach programs and events achieve targeted satisfaction 

rating on user surveys.

FY 2014

Actual

FY 2015

Actual 

FY 2016

Actual 

FY 2017

Actual 

FY 2018

Actual 

FY 2019

Target

FY 2019 

Actual

FY 2020

Target

FY 2021

Target

N/A 4.34 4.53 4.43 4.53 4.0 or higher 

on a 5.0 scale 

4.45 4.0 or higher 

on a 5.0 scale

4.0 or 

higher on a 

5.0 scale

Supporting Indicators 2-1: 

Measure Name FY 2014

Actual

FY 2015

Actual

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Target

FY 2019

Actual

FY 2020

Target

FY 2021

Target

Increase in the 

number of ELearning 

presentations 

available on the 

FEC website

13 new 

trainings

1 new 

training

4 new 

trainings 

6 new 

trainings

3 new 

trainings

4 new 

trainings

9 new 

trainings 

4 new 

training

s 

4 new 

trainings

Implement 

correspondence 

tracking tool for 

public-facing 

offices

N/A N/A N/A N/A 100% N/A N/A N/A N/A
34

Performance Goal 2-2: Seek adherence to FECA requirements through fair, effective and 

timely enforcement and compliance programs. 

Key Indicator: Of the enforcement matters resolved during the fiscal year, the 

percentage that was resolved within 15 months of the date of receipt.

FY 2014 

Actual

FY 2015

Actual

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Target

FY 2019

Actual

FY 2020

Target

FY 2021

Target

28% 49% 38% 68% 62% 50% 56% 50% 50%
35

Supporting Indicators 2-2: 

Measure Name FY 2014

Actual

FY 2015

Actual

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Target

FY 2019

Actual

FY 2020

Target

FY 2021

Target

Percent of 

notifications 

provided within 

five days of 

complaints filed 

with the FEC

100% 100% 100% 100% 100% 100% 100% 100% 100%

Percent of 

enforcement 

matters presented 

to the 

Commission for 

initial review 

within one year of 

the date of receipt

73% 93% 86% 86% 84% 80% 82% 80% 80%

Percent of RFAIs 

sent within 40 

days of report 

review

84% 92% 92% 88% 88% 75% 88% 75% 75%

Percent of reports 

reviewed by RAD 

within 90 days of 

receipt

85% 79% 93% 77% 92% 75% 76% 75% 75%

Percent of 

Proposed Final 

Audit Reports

(PFAR) approved 

by the 

Commission 

within two years 

from the start of 

fieldwork

93% 43% 56% 25% 45% 60% 100% 65% 65%

Percent of 

Reviewing Officer 

Recommendations

circulated within 

60 days

100% 97% 82% 97% 100% 75% 97% 75% 75%

Percent of 

ADRO 

Recommendations

circulated within 

140 days of 

referral

 72% 90% 97% 78% 74% 75% 

70%15 

75% 75%

 

15 The agency’s ability to meet its target for this performance goal during FY 2019 was negatively impacted by the lapse in 

appropriations from December 22, 2018 to January 25, 2019.
36

3C:2.3 Strategic Objective 3: Interpret the FECA and Related Statutes

Leader: Deputy General Counsel—Administration; Deputy General Counsel—Law 

Commission initiatives, Congressional action, judicial decisions, petitions for rulemaking or other 

changes in campaign finance law may necessitate that the Commission update or adopt new regulations. 

Consequently, the FEC undertakes rulemakings either to write new Commission regulations or revise 

existing regulations. The Commission also provides guidance on how the Act applies to specific 

situations through the advisory opinion process and represents itself in most litigation before the Federal 

district and appellate courts. The Commission’s three primary means for providing interpretive guidance 

for the Act and related statutes are discussed below.

Regulations 

The Policy Division of OGC drafts various rulemaking documents, including Notices of Proposed 

Rulemaking (NPRMs), for Commission consideration. NPRMs provide an opportunity for the public to 

review proposed regulations, submit written comments to the Commission and, when appropriate, testify 

at public hearings at the FEC. The Commission considers the comments and testimony and deliberates 

publicly regarding the adoption of the final regulations and the corresponding Explanations and 

Justifications, which provide the rationale and basis for the new or revised regulations.

Advisory Opinions 

Advisory opinions (AO) are official Commission responses to questions regarding the application of 

Federal campaign finance law to specific factual situations. The Act generally requires the Commission

to respond to AO requests within 60 days. For AO requests from candidates in the two months leading 

up to an election, the Act requires the Commission to respond within 20 days. On its own initiative, the 

Commission also makes available an expedited process for handling certain time-sensitive requests that 

are not otherwise entitled to expedited processing under the Act. The Commission strives to issue these 

advisory opinions in 30 days.

Defending Challenges to the Act

The Commission represents itself in most litigation before the Federal district and appellate courts and 

before the Supreme Court with respect to cases involving publicly financed Presidential candidates. It 

also has primary responsibility for defending the Act and Commission regulations against court 

challenges. In addition, the Act authorizes the Commission to institute civil actions to enforce the Act. 

Strategies and Next Steps

The Office of General Counsel continues to focus on its processes to ensure that staff provides timely 

and well-written advice to the Commission so that it can meet its obligations to administer and enforce 

campaign finance law. The Commission considers it a high priority to ensure that guidance is provided 

through the advisory opinion process within the timeframes established by the Act. OGC continues to 

ensure that court filings meet all deadlines and rules imposed by the courts and has set as a performance 

target meeting 100 percent of these deadlines and rules. 
37

Progress Update for FY 2019 

During FY 2019, the Commission met its goal to provide 100 percent of legal guidance within statutory 

and court-ordered deadlines. The Commission also met a separate goal to issue 100 percent of advisory 

opinions within the applicable 60- or 20-day statutory deadlines. During FY 2019, the Commission 

completed work on 18 AO requests and issued 14 opinions in response to those requests.

16 Of the 18 

AO requests that the Commission completed in FY 2019, 17 were 60-day AORs (six of which received 

extended deadlines), and one was a 20-day AOR. These AOs addressed a variety of issues, including

cybersecurity threats faced by political committees, the permissible/impermissible uses of campaign 

funds by federal candidates and officeholders, state party committee status, online contributionprocessing applications, earmarking of contributions and cryptocurrency. The average number of days 

from receipt of a complete AO request to Commission action on it was 44 days for 60-day requests that 

did not have extended deadlines, 127 days for 60-day requests with extended deadlines, and 20 days for 

the 20-day request.

 

 

16 Two advisory opinion requests resulted in split decisions in which the Commission issued a closeout letter rather than an advisory 

opinion because the Commission could not approve an advisory opinion by the required number of affirmative votes. Two advisory 

opinion requests were withdrawn. 
38

Performance Goal 3-1: Provide timely legal guidance to the public.

Key Indicator: Percent of legal guidance provided within statutory and courtordered deadlines.

FY 2014

Actual

FY 2015

Actual

FY 2016

Actual

FY 2017

Actual

FY 2018 

Actual

FY 2019

Target

FY 2019

Actual

FY 2020

Target

FY 2021

Target

100%17 100%18 100%19 100%20 100%21 100% 100%22 100% 100%

 

17 The Commission obtained extensions to consider ten advisory opinion requests in FY 2014; four of those extensions were 

attributable to the Federal government shutdown during October 2013. The Commission did not have any rulemakings during 

FY 2014 with statutory or court-ordered deadlines. 18 The Commission obtained extensions to consider two advisory opinion requests in FY 2015. The Commission did not have any 

rulemakings during FY 2015 with statutory or court-ordered deadlines. 19 The Commission obtained extensions to consider six advisory opinion requests in FY 2016. 20 The Commission obtained extensions to consider seven advisory opinion requests in FY 2017. 21 The Commission obtained an extension to consider one advisory opinion request in FY 2018. 22 The Commission obtained extensions to consider six advisory opinion requests in FY 2019; two of those extensions were 

lengthened by the partial Federal government shutdown during the first and second quarters of FY 2019. 
39

Supporting Indicators 3-1:

Measure 

Name 

FY 2014

Actual

FY 2015

Actual

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Target

FY 2019

Actual

FY 2020

Target

FY 2021

Target

Percent of 

advisory 

opinions 

issued within 

60-day and 

20-day 

statutory 

deadlines

100%23 100%24 100%25 100%26 100%27 100% 100%28 100% 100%

Percent of 

court filings 

that meet all 

deadlines and 

rules 

imposed by 

the courts

100% 100% 100% 98% 99% 100% 97% 100% 100%

 

23 The Commission obtained extensions to consider ten advisory opinions during FY 2014; four of those extensions were 

attributable to the Federal government shutdown during October 2013. 24 The Commission obtained extensions to consider two advisory opinion requests in FY 2015. 25 The Commission obtained extensions to consider six advisory opinion requests in FY 2016. 26 The Commission obtained extensions to consider seven advisory opinion requests in FY 2017. 27 The Commission obtained an extension to consider one advisory opinion request in FY 2018. 28 The Commission obtained extensions to consider six advisory opinion requests in FY 2019; two of those extensions were 

lengthened by the partial Federal government shutdown during the first and second quarters of FY 2019. 
40

3C:2.4 Strategic Objective 4: Foster a Culture of High Performance

Leaders: Deputy Staff Director for Management and Administration/Chief Human Capital Officer and 

Deputy Chief Information Officer, Enterprise Architecture

One of the objectives from the FEC’s Strategic Plan, FY 2018-2022, Foster a Culture of High 

Performance, cuts across the organization and reflects the agency’s strategic priorities for improving the 

efficiency and effectiveness of its workforce and management processes. The FEC’s primary measure 

of success in developing and maintaining a result-driven workforce is at the program level: a workforce 

that delivers results will meet the internal performance targets set by the Commission. Supporting targets 

and results are detailed in the charts below.

Strategies and Next Steps

The Commission understands that the success of its programs depends upon the skills and commitment 

of its staff. The Commission is focused on ensuring that staff training needs are assessed and met at 

every level of the agency and that agency leaders receive training necessary to help manage and maintain 

a fully engage and productive workforce. The FEC is also focused on decreasing the time to hire, 

improving the agency’s performance management systems and developing a supervisory and managerial 

training program for senior leaders, mid-career managers and first time supervisors. 

The FEC is also implementing a multi-phase plan to reduce reliance on physical servers and migrate 

appropriate systems and data to a cloud environment. In conjunction with the redesign of the agency’s 

website, the FEC successfully migrated its largest database, the campaign finance database, to a cloud 

environment and shut down one physical data center during FY 2018. Cloud hosting offers a number of 

benefits for the FEC’s campaign finance database and website. The agency’s Internet traffic is variable, 

with many more visitors accessing the website during election years and near reporting deadlines. With 

a cloud-hosted application and database infrastructure, the FEC only needs to pay for the actual usage, 

rather than constantly maintaining the capacity to support peak usage, even during periods of reduced 

usage. Website downtime is minimized and server maintenance is managed by the cloud computing 

provider. During FY 2020, the FEC is conducting a study to determine how best to migrate other 

appropriate systems and databases to the cloud, allowing the agency to realize greater efficiency and 

performance in future years. The FEC will focus on implementing the results of this study during FY 

2021. 

The Commission’s records management program continues to make advancements, as described 

below. Fiscal Years 2020 and 2021 will bring continued focus on updating the agency’s records 

schedules in compliance with the Transition to Electronic Records Memorandum, updating the agency’s 

Records Management Program, and training all staff on the agency and government-wide records 

schedules, policies and responsibilities. 

Progress Update for FY 2019 

In accordance with the Transition to Electronic Records Memorandum, which superseded the Managing 

Government Records Presidential Directive as of June 28, 2019, the Commission has made important 

progress toward the Memorandum’s goal of managing all permanent records in an electronic format with 
41

appropriate metadata by 2022. In support of that goal, the Commission received approval from the 

Archivist of the United States for its National Archives and Records Administration (NARA) form 1005 

(NA-1005) Verification for Implementing GRS 6.1. This established the Commission’s agency-wide 

Email Management Policy via the Capstone approach. The Commission also received approval from 

the Archivist of the United States for its Commission Meeting Records Schedule. The Commission is 

seeking approval of its January 2018 request, pending with NARA, to electronically maintain all records 

associated with the Office of Alternative Dispute Resolution’s case files, as NARA seeks to finalize and 

formally add to its regulations digitization standards applicable to paper records that are ultimately 

digitized. 

During FY 2019, the FEC partnered with the Office of Personnel Management’s HR Solutions to 

improve the FEC’s staffing, classification and performance management processes. To begin 

streamlining and better documenting the agency’s hiring procedures, the FEC and HR Solutions created 

new standard operating procedures (SOPs) and began to implement these new procedures during the 

third quarter of FY 2019. With these procedures, hiring managers are more directly involved throughout 

the hiring process, are receiving high quality advice and are able to onboard new hires more quickly. 

Despite time lost to the FEC’s lapse in appropriations, from December 22, 2018 to January 25, 2019, the 

agency reduced average days to hire from 153 days in FY 2018 to 132 days during FY 2019. In FY2020 

and 2021, the FEC will continue to focus on using the new SOPs to further streamline the hiring process 

and fill vacant positions faster. 

In addition, the FEC implemented a new web-based performance management system for nonbargaining unit employees during FY 2019. The FEC also leveraged the partnership with the Office of 

Personnel Management to bring broad, high-quality supervisory trainings to the agency’s supervisors 

during the year. 

Consistent with its commitment to fostering the talents and skills of its employees and providing 

excellent service to the public, the FEC launched an Innovation Center during FY 2019. The FEC’s 

Innovation Center is a cross-functional group within the agency that develops and implements usercentered, evidence-based design solutions for achieving the FEC’s mission efficiently and effectively. 

Partnering with staff from across the agency, the core Innovation Center team will leverage staff business 

process knowledge and emerging technological advancements to improve the delivery of mission critical 

functions. The Innovation Center will improve organizational decision making and be tasked with 

harnessing the creativity and ideas of agency employees, and emerging technologies, to restructure 

systems, tools and processes, while building a 21st century IT infrastructure to better serve the American 

public. 
42

Performance Goal 4-1: Foster a workforce that delivers results.

Key Indicator: Commission-required quarterly updates meet targeted performance 

goals.

FY 2014

Actual

FY 2015 

Actual

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Target

FY 2019

Actual

FY 2020

Target

FY 2021

Target

73% 80% 76% 85% 73% 65% 53%29 65% 65%

 

29 The agency’s ability to meet its target for this performance goal during FY 2019 was negatively impacted by the lapse in 

appropriations from December 22, 2018 to January 25, 2019.
43

Supporting Indicators 4-1: 

Measure 

Name 

FY 2014

Actual

FY 

2015 

Actual

FY 

2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Target

FY 2019

Actual

FY 2020

Target

FY 2021

Target

Average 

number of 

days to hire

N/A N/A N/A N/A 153 80 days 13230 80 days 120 days

Implement 

new 

performance 

management 

system 

N/A N/A N/A N/A N/A Nonbargaining 

unit 

implementation

100% N/A N/A

Develop 

program for 

tiered 

supervisory 

training

N/A N/A N/A N/A Baseline 

Supervisory 

Training 

provided

Launch 

mid-career 

manager 

program

Baseline 

Supervisory 

Training 

provided 

 N/A N/A

Meet 

Records 

Management 

Presidential 

Directive 

milestones

50% N/A31 60% 70% 73% As 

specified 

in Presidential 

Directive 

76% As

specified 

in Presidential 

Directive 

As 

specified 

in Presidential 

Directive 

Reduce 

reliance on 

physical data 

centers

N/A N/A N/A N/A 100% N/A N/A N/A N/A

Develop and 

implement 

Innovation 

Center

N/A N/A N/A N/A N/A Complete 

by 2019

100% N/A N/A

 

30 The agency’s ability to meet its target for this performance goal during FY 2019 was negatively impacted by the lapse in 

appropriations from December 22, 2018 to January 25, 2019. 31 There were no Records Management Presidential Directive milestones for calendar year 2015.
44

3D: Implementation Factors

3D:1 Major Management Priorities, Challenges and Risks 

The FEC identified in the agency’s FY 2018-2022 Strategic Plan a management objective, Foster a 

Culture of High Performance, that sets out strategies and measures designed to help the agency deliver 

greater impact through innovation, increase effectiveness and efficiency, and improve service. Detailed 

information about this Strategic Objective is available in section 3C:2.4, above. In addition, the 

Commission has identified management initiatives as strategic activities in the strategic plan to support 

its mission objectives where those activities are deemed crucial to the success of the objective. 

During FY 2019 the FEC partnered with the Office of Personnel Management’s HR Solutions to improve 

the FEC’s staffing, classification and performance management processes. Goals for the FEC’s human 

capital management processes are detailed in section 3C:2.4. 

Each year the FEC’s Inspector General (IG) is required to provide a summary and assessment of the 

most serious management and performance challenges facing the FEC. In a memorandum dated October 

17, 2019, the IG identified five challenge facing management: governance and management framework: 

1. The resignation of a Commissioner leaves the Commission without a four-person quorum; 

2. Improve IT governance to prevent external threats into FEC systems;

3. The lack of a dedicated, full-time, Chief Information Officer (CIO) and vacancies in key 

leadership positions within the agency; 

4. Address outstanding IG audit recommendations to improve agency operations for compliance 

and effectiveness;

5. Address the results from the annual Federal Employee Viewpoint Survey (FEVS) and 2016 Root 

Causes of Low Employee Morale Study to inform and guide management decisions to increase 

employee morale.

The IG’s assessment and the FEC’s response are included in the FEC’s FY 2019 Agency Financial 

Report, available on the FEC website at https://www.fec.gov/resources/cmscontent/documents/FEC_FY2019_AFR.pdf. 

3D:2 Data Validation and Verification

OMB Circular A-136, as revised, and the GPRA Modernization Act of 2010 (GPRAMA) require each 

agency to describe the accuracy and reliability of the data used to measure progress toward its 

performance goals, including an identification of the means used to verify and validate the measured 

values and the source for the data. Agencies are encouraged to determine the appropriate frequency of 

data validation and verification (V&V) needed for the intended use and should allocate appropriate

resources to carry out validation and verification on an appropriately periodic basis.

Many of the FEC’s performance measures set goals for the timely completion of tasks that are either 

internally generated or triggered through reports or complaints filed with the Commission. As a result, 

the universe of data the FEC must collect and verify to support its performance information is generally 

small, centrally located and easily verified. The FEC tracks data to support its performance measures 
45

through its internal databases and with spreadsheets maintained by program managers. In cases where 

performance is measured based on the timeframe for completing a decision, matter or inquiry, the

universe of data to be measured and the dates on which performance milestones are reached are tracked 

electronically. Data provided by the agency’s litigation, policy, enforcement and compliance offices are 

reported at least quarterly to the Commission, which provides regular opportunities for the accuracy of 

the data to be verified. 

The FEC also tracks its performance in making campaign finance information available to the public. 

Reports filed with the FEC represent the largest universe of data the agency must consider in determining

its performance. Campaign finance reports and statements filed electronically are made available on the

FEC website nearly instantaneously, and reports and statements filed on paper with the FEC are placed 

on the FEC website within 48-hours of receipt. In addition, FEC staff process the data contained in 

campaign finance reports so that the information can be accurately organized, categorized and searched 

in the agency’s databases. The FEC sets as a performance goal processing 95 percent of reports through 

its data and coding system within 30 days. The entry and completion dates for each report are retrievable 

through the FEC’s electronic systems. 

The FEC has completed a broad review of its methods for verifying and validating performance as part 

of its overall assessment of its strategic and performance plans. The FEC has identified senior-level staff 

and key managers to serve as goal leaders for each area of the strategic and performance plans. In 

addition, each strategic activity in the Strategic Plan has been assigned one or more program managers, 

who are responsible for the delivery and performance reporting of that activity. These managers will be

serving as measure managers and data quality leads to ensure the completeness, consistency and 

accuracy of the reported data of their respective strategic activity. 

3E: Conclusion 

As described in this section, the FEC’s plans and strategies for FYs 2020 and 2021 are designed to ensure 

that the agency is well-prepared to provide full campaign finance transparency to the public despite the 

expected increase in campaign finance activity.
46

Office of Inspector General’s Fiscal Year 2021 Budget Request

The Inspector General Reform Act (Pub. L. 110-409) was signed by the President on October 14, 2008. 

Section 6(f)(1) of the Inspector General Act of 1978, 5 U.S.C. app., was amended to require certain

specifications concerning Office of Inspector General (OIG) budget submissions each fiscal year.

Each Inspector General (IG) is required to transmit a budget request to the head of the establishment or 

designated Federal entity to which the IG reports specifying:

• the aggregate amount of funds requested for the operations of the OIG;

• the portion of this amount requested for OIG training, including a certification from the IG that 

the amount requested satisfies all OIG training requirements for that fiscal year; and

• the portion of this amount necessary to support the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE).

The head of each establishment or designated Federal entity, in transmitting a proposed budget to the 

President for approval, shall include: 

• an aggregate request for the OIG;

• the portion of this aggregate request for OIG training; 

• the portion of this aggregate request for support of the CIGIE; and

• any comments of the affected IG with respect to the proposal. 

The President shall include in each budget of the U.S. Government submitted to Congress: 

• a separate statement of the budget estimate submitted by each IG;

• the amount requested by the President for each OIG;

• the amount requested by the President for training of OIGs;

• the amount requested by the President for support of the CIGIE; and

• any comments of the affected IG with respect to the proposal if the IG concludes that the budget 

submitted by the President would substantially inhibit the IG from performing the duties of the

OIG.

Following the requirements as specified above, the OIG of the Federal Election Commission submits 

the following information relating to the OIG’s requested budget for fiscal year 2021: 

• the aggregate budget request for the operations of the OIG is $2,001,946. 

• the portion of this amount needed for OIG training is $42,000; and

• the portion of this amount needed to support the CIGIE is an estimated $6,585. 

I, Christopher L. Skinner, certify as the IG of the Federal Election Commission that the amount I have 

requested for training satisfies all OIG training requirements for fiscal year 2021.
47

OIG Summary of Outstanding FEC OIG Audit Recommendations

The FEC OIG provides the table detailed herein for informational purposes only. It provides an 

update to FEC management as to the current status of the total outstanding recommendations 

reported in the OIG’s most recent semiannual report for the period ending September 30, 2019. 

OIG Audits/Inspections

Total Outstanding 

Recommendations as 

of September 30, 2019

Total Closed 

Recommendations 

(Oct 1, 2019-Jan 23, 2020) 

Total Open as 

of February 

202032

2010 Follow-up Audit of Privacy and 

Data Protection 

9 years outstanding33

17 5 12 

Inspection of the FEC’s Disaster

Recovery Plan and Continuity of

Operations Plans

7 years outstanding

7 0 7 

Audit of the FEC’s Office of Human 

Resources 

6.5 years outstanding

2 0 2 

Inspection of FEC’s Compliance with 

FMFIA/OMB A-123 

5.5 years outstanding

1 1 0 

Audit of the FEC Telework Programs 

3.5 years outstanding 2 0 2 

2017 and 2019 Required Review Under 

the DATA Act Audit34 

2 years outstanding

3 0 3 

Outstanding Recommendations from prior 

Annual Financial Statement (FS)Audits35 

At least 1 year outstanding

8 2 6 

Totals

40 8 32

Total Outstanding Recommendations 3236

 

32 OIG has determined that FEC management has not adequately implemented the remaining recommendations. 

33 Timelines are calculated based on the final report issuance date.

34 OIG notes that the (3) recommendations identified in the 2017 DATA Act audit were closed considering those recommendations were 

repeated in the 2019 Data Act audit and as a result, remain open and are reported herein.

35 OIG recommendations are tracked, reviewed, and updated during the annual financial statement audit which was last updated in 

November 2019.

36 The remaining outstanding recommendations include open recommendations from prior financial statement audits which the OIG does 

not provide in its semiannual report to Congress. Therefore, the total number of outstanding OIG recommendations excluding financial 

statement audit recommendations is 26.
48