GAO-12-1004R Open World Leadership Center

September 21, 2012

The Honorable Ben Nelson

Chairman

The Honorable John Hoeven

Ranking Member 

Subcommittee on Legislative Branch

Committee on Appropriations

United States Senate

The Honorable Ander Crenshaw

Chairman

The Honorable Michael M. Honda

Ranking Member 

Subcommittee on Legislative Branch

Committee on Appropriations

House of Representatives

Subject: Status of Open World Exchange Program’s Efforts to Strengthen Financial 

Management and Performance Measurement

Since its establishment in 1999,1 the Open World Leadership Center (Open World) 

exchange program has brought nearly 18,000 emerging leaders from Russia and 13 other 

participating countries to the United States to give them firsthand exposure to the U.S. 

economic system and democratic institutions.2

 Open World is governed by a Board of 

Trustees3

 

1

The Russian Leadership Program was established in Pub. L. No. 106-31, § 3011 (May 21, 1999). The 

program was renamed the Open World Leadership Center by Pub. L. No. 108-7, Div. H, §1401 (Feb. 20, 

2003).

and has seven permanent staff, led by an Executive Director, that work with 

numerous partners to carry out its program. U.S. embassies in participating countries play 

a key role by nominating many individuals for the program, vetting applicants for final 

selection, and processing visas for participants. Open World awards grants to U.S. 

national host organizations that, in conjunction with local partners, develop programs for 

2

The Library of Congress served as the administrator of the Open World program during the exchange's pilot 

phase. The program is now managed by the Open World Leadership Center, a separate entity within the U.S. 

legislative branch. Although the Center is independent of the Library, it has an interagency agreement with the 

Library to provide financial management and administrative support services to support Open World’s 

operations. 

3

The Board of Trustees is composed of ten members—a Chairman; the Librarian of Congress; one member of 

Congress appointed by the Speaker of the House of Representatives and two members appointed by the 

President Pro Tempore of the Senate; three other individuals appointed by the Librarian of Congress; and the 

two Chairs of the Appropriations Subcommittees on Legislative Branch.

United States Government Accountability Office

Washington, DC 20548
Page 2 GAO-12-1004R Open World Leadership Center

participants and arrange home stays. Program participants stay in the homes of 

American host volunteers. 

In 2003, Congress asked us to review Open World’s progress toward achieving its overall 

purpose and whether the program had appropriate financial management and 

accountability mechanisms in place.4 As a result of our review, we issued a report in 2004 

that contained eight recommendations aimed at enhancing Open World’s financial 

management and performance measurement.5

 In 2011, Congress directed us to 

determine the actions the program had taken to implement our 2004 recommendations.6

 

In response to the mandate, we reviewed (1) Open World’s actions to address our 

recommendations on financial management and internal controls, and how the program’s 

current financial management controls compare with leading practices for accountability; 

and (2) the program’s actions to address our recommendations on performance 

measurement and how its mechanisms for performance measurement compare with

leading practices.

Scope and Methodology

To examine Open World’s actions to address our recommendations on financial 

management and how the program’s current financial management controls compare with 

leading practices for accountability, we met with Open World officials and reviewed 

relevant policies and procedures. We compared selected financial management controls 

to GAO’s Standards for Internal Control in the Federal Government7 and the Internal 

Control Management and Evaluation Tool.

8 Our assessment focused on whether these 

policies and procedures were designed to provide an adequate framework for internal 

controls. We did not conduct an audit of Open World’s financial reports or individual 

transactions. 

To examine Open World’s actions to address our recommendations on performance 

measurement and how its mechanisms for performance measurement compare with

leading practices, we reviewed the performance measures in Open World’s strategic plan 

and compared them to GAO’s Key Attributes of Successful Performance Measures.

9

 

4

In 2003, Congress expanded the scope of the program to include cultural leaders in Russia and extended 

eligibility to 11 countries of the Newly Independent States of the former Soviet Union and 3 Baltic states.

We 

also reviewed Open World’s organizational structure, operational policies and procedures, 

and program documentation. In addition, we met with Open World’s Executive Director, 

5

GAO, International Exchange Programs: Open World Achieves Broad Participation; Enhanced Planning and 

Accountability Could Strengthen Program, GAO-04-436 (Washington, D.C.: Mar. 17, 2004).

6

See House Conference Report 112-331.

7

GAO, Standards for Internal Control in the Federal Government, AIMD-00-21.3.1 (Washington, D.C.: Nov. 1, 

1999). 

8

GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, D.C.: Aug. 1, 2001).

9

GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance Measures, GAO03-143 (Washington, D.C.: Nov. 22, 2002). As part of this report, we developed key attributes of successful 

performance measures for results-based organizations. We have since used these attributes to assess 

performance measures of entities other than the IRS.
Page 3 GAO-12-1004R Open World Leadership Center

management, and other staff; State Department officials; and international exchange 

Interagency Working Group (IAWG) officials.

We conducted this performance audit from May 2012 to September 2012 in accordance 

with generally accepted government auditing standards. Those standards require that we 

plan and perform the audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

Results in Brief

Since our 2004 report, Open World has taken a number of steps to address our 

recommendations on financial management controls, and has also generally followed 

leading financial management practices. For example, to address our recommendations, 

Open World (1) contracted with an independent public accountant to perform an 

assessment of its ability to be audited; (2) developed Financial Procedures and Directives

guidance that covers key activities such as grants; (3) developed the Grant Procedures

document, which enhanced accountability for its grantees; (4) submitted its financial 

statements to an annual financial statement audit since fiscal year 2005, resulting in clean 

audit opinions since fiscal year 2006; (5) established an audit committee, comprised of 

independent members that have financial and programmatic knowledge, which also 

reviews management’s annual assessment of its internal controls; and (6) developed 

guidelines for grantees to calculate and report the estimated value of U.S. volunteers’ 

contributed services, and also disclosed this value as part of its annual budget 

justification. Open World’s financial management controls also generally followed leading 

practices for financial accountability. For example, Open World (1) developed appropriate 

policies, procedures, techniques, and mechanisms with respect to each of the agency’s 

activities; (2) developed guidance aimed at ensuring that transactions are properly 

documented, approved, and processed; and (3) performed ongoing monitoring of its 

transactions through annual financial audits since fiscal year 2005. Open World has plans 

to further enhance its financial management controls to better align its grant monitoring 

with leading practices by performing reviews of grantees’ compliance with grant 

agreement guidelines.

Open World has taken a number of steps that address our 2004 recommendations and 

reflect several leading practices for performance measurement. For example, to address 

our recommendations, Open World established its first strategic plan covering fiscal years 

2007-2011 and later issued an updated plan covering fiscal years 2012-2016. In addition, 

it (1) presented to the Board the first comprehensive quantitative analysis of annual 

achievement on each of its performance measures for fiscal years 2007 through 2011; 

(2) implemented periodic reports from program participants, hosts, and contractors that 

provide standardized information about program performance and results; and (3) is 

currently converting its performance databases to a web-based system intended to reduce 

time needed to report on program feedback and performance. As of August 2012, Open 

World’s efforts were generally consistent with several of the key attributes that GAO has 

identified for successful performance measures. For example, most performance 

measures in Open World’s strategic plan were clearly stated and could allow for objective 

data to be collected. Although Open World had some intended outcomes that did not link 

to corresponding measures or program activities that contribute to achieving these 

outcomes, Open World officials stated in September 2012 that they revised their 
Page 4 GAO-12-1004R Open World Leadership Center

performance measures to ensure that they directly link the activities of the program to the 

objectives in their strategic plan. In June 2012, Open World set numerical targets that 

could allow management to more systematically track its performance against program 

goals, but Open World had not yet developed an agency performance plan or released 

annual updates comparing its performance targets to actual results. During August 2012 

discussions with us, Open World officials agreed to take the additional steps of preparing 

an annual performance plan and reporting annual updates publicly to further align their

performance measurement efforts with leading practices. In September 2012, Open World 

officials stated that they had finalized an annual performance plan. 

Background

Congress created the precursor of Open World, the Russian Leadership Program, as a 

pilot project within the Library of Congress in 1999 and, about 2 years later, established it 

as an independent, permanent entity. The program’s founders envisioned it as a way to 

promote mutual understanding between the United States and Russia and positively 

influence Russia’s development following the collapse of the former Soviet Union. The 

program aimed to expose emerging political leaders at all levels of government in Russia 

to the American economic system and democratic institutions through visits to 

communities across the United States, allowing participants to see how Americans from 

all walks of life conduct their business and professions and their private, social, and 

cultural lives. As envisioned by its founders, the overall mission of the program was to 

develop a cadre of people in Russia committed to democratic and free market principles 

by reaching out to emerging leaders, similar to the way that young German leaders were 

targeted by the Marshall Plan after World War II. In 2003, Congress changed the 

program’s name to the Open World Leadership Center, expanded its scope to include 

cultural leaders from Russia, and extended eligibility to additional countries in the Newly 

Independent States of the former Soviet Union and the Baltic states.10 

Open World has awarded hosting grants to 61 organizations headquartered in 25 states 

and the District of Columbia. By the end of 2011, about 800 local host organizations—

including universities, community colleges, service organizations, sister-city associations, 

local government agencies, and international visitor councils and other nonprofit 

organizations in all 50 states and the District of Columbia—had conducted exchanges for

Open World. About 6,700 American families have hosted participants in 2,000 

communities. In addition, Open World has contracts with organizations that provide 

logistical support and coordinate alumni activities. In fiscal year 2012, Open World’s 

appropriation was $10 million. In addition, Open World is authorized to seek and accept 

private donations. 

Open World Has Taken Actions to Address Our Recommendations on Financial 

Management Controls and Has Generally Followed Leading Practices 

Since GAO reported in 2004, Open World has taken a number of steps to address our six 

recommendations regarding its financial management and internal controls, as outlined in 

Open World Has Taken Actions to Strengthen Financial Management

 

10The expansion of Open World extended eligibility to the remaining 11 countries of the Newly Independent 

States of the former Soviet Union and 3 in the Baltic states. The countries that have participated in Open 

World exchanges are Armenia, Azerbaijan, Belarus, Georgia, Kazakhstan, Kyrgyzstan, Lithuania, Moldova, 

Russia, Serbia, Tajikistan, Turkmenistan, Ukraine, and Uzbekistan.
Page 5 GAO-12-1004R Open World Leadership Center

table 1. Specifically, Open World (1) contracted with an independent public accountant to 

perform an auditability assessment; (2) developed Financial Procedures and Directives

guidance; (3) developed the Grant Procedures document; (4) submitted its financial 

statements to an annual financial statement audit since fiscal year 2005, resulting in clean 

audit opinions since fiscal year 2006; (5) established an audit committee, comprised of 

independent members that have financial and programmatic knowledge, which also 

reviews management’s annual assessment of its internal controls; and (6) developed 

guidelines for grantees to calculate and report the value of U.S. volunteers’ contributed 

services, and also disclosed this value as part of its annual budget justification.

Table 1: Actions Taken by Open World to Address GAO’s 2004 Financial Management and Internal 

Control Recommendations

2004 GAO recommendations on financial 

management and internal controls

Open World actions to address recommendations

Assess whether the current procedures provide 

adequate internal control over expenditures and 

grantee oversight

• Contracted with an independent public 

accountant to perform an auditability 

assessment, which concluded that Open World’s 

financial reporting structure was sufficient to allow 

a full-scope audit and provided recommendations 

to improve policies and procedures

• Submitted its financial statements since 2005 to 

an annual financial statement audit, which covers 

internal controls over expenditures

• Created an audit committee in 2008 that is 

tasked with reviewing management’s annual 

assessment of its internal controls

Develop and implement written, managementapproved policies, procedures, and internal controls 

for Open World’s resources and expenditures

• Developed Financial Procedures and Directives

guidance, which documented internal controls 

through policies and procedures for areas such 

as procurement of supplies and expert services, 

credit card purchases, reimbursements, travel, 

training, and grants administration and closure

• Communicated and maintained this guidance on 

an internal shared drive for easy access by its 

employees 

• Developed a vulnerability assessment and 

internal control review tools to strengthen its 

ability to monitor internal controls

Develop and implement controls and requirements 

for grantees to provide accountability for grant 

expenditures to ensure that funds are spent for their 

intended purposes

• Developed, in 2005, the Grant Procedures

document, which provides grantees with 

information on the grants process, allowable 

expenses, and procedures that grantees must 

follow to be eligible for grants and to ensure 

accountability

• Included in this document specific guidance for 

the grantees’ budget calculation and for 

documentation that needs to be provided to Open 

World during grant closing procedures

• Required grantees to file a quarterly financial 

report that identifies the amount of grant funds 

expended and unobligated
Page 6 GAO-12-1004R Open World Leadership Center

• Required grantees to submit a variance report 

identifying differences between actual expenses 

and the approved grant budget

• Prohibited variances of greater than 10 percent 

without approval by Open World in advance

• Required each grantee to submit either an 

opinion from its most recent financial statement 

audit or detailed receipts to support its grant 

expenses

• Updated the Grant Procedures document 

annually and posted it to Open World’s website 

after approval

Develop and implement plans for routinely preparing 

financial statements that are annually subject to an 

independent audit

• Prepared and submitted its financial statements 

to an annual financial statement audit since fiscal 

year 2005

• Since 2006, these audits have resulted 

in clean audit opinions with no material 

weaknesses or significant deficiencies in 

internal controls, and no instances of 

noncompliance with laws and 

regulations 

Consider establishing an audit committee or financial

management advisory committee to provide the 

Board of Trustees and management with 

independent advice on financial management, 

accountability, and internal control issues

• Established an audit committee in 2008 that 

consisted of three members and adopted a

charter in 2009 

• Audit committee meets at least annually 

to discuss internal controls over financial 

management and communicate with the 

independent public accountant and the 

Library of Congress’s Inspector General 

• Audit committee reports the results of its 

reviews of internal controls and the 

financial statement audit to the Board of 

Trustees

• Audit committee currently consists of 

three members who have the financial 

and programmatic knowledge necessary 

to read and understand audit reports 

and help oversee Open World’s 

activities. For example, two members 

have financial management experience 

and one member has grants-related 

experience.

Estimate and disclose the value of contributed 

services from U.S. volunteers to better reflect the 

total scope of the program

• Developed guidelines for grantees to assess the 

value of the contributed services in each of their 

budget category estimates

• Required grantees to report the value of 

contributed services annually 

• Disclosed the estimated value of contributed 

services in Open World’s Annual Report and 

Budget Justifications

Source: GAO.
Page 7 GAO-12-1004R Open World Leadership Center

Open World Follows Leading Financial Management Practices and Plans to Enhance 

Grantee Monitoring 

Open World’s financial management controls generally follow leading practices for 

financial accountability. For example, Open World has (1) developed appropriate policies, 

procedures, techniques, and mechanisms with respect to each of the agency’s activities, 

such as grants; (2) developed guidance aimed at ensuring that transactions are properly 

documented, approved, and processed; (3) performed ongoing monitoring of its 

transactions through annual financial audits; and (4) established a three-member 

independent audit committee with relevant financial management experience to assist in 

oversight of financial management and internal controls. GAO’s Standards for Internal 

Control in the Federal Government state that internal controls should generally be 

designed to assure that ongoing monitoring occurs in the course of normal operations. In 

addition, GAO’s Internal Control Management and Evaluation Tool states that appropriate 

policies and procedures should exist with respect to each of the agency’s activities. Open 

World’s Financial Procedures and Directives includes grant procedures for advance 

payments, reimbursements, general management, and grant closing. However, we 

advised Open World that additional procedures could further enhance Open World’s 

ability to determine its grantees’ compliance with requirements outlined in its Grant 

Procedures, such as the proper use of funds. Such enhanced policies and procedures to 

monitor and evaluate the grantees’ compliance with grant requirements could further 

increase accountability and help ensure that funds are being used for their intended 

purpose. These procedures are important to Open World because grant obligations 

totaled approximately $3.4 million, or 28 percent of its $12.3 million total obligations in 

fiscal year 2011. Open World officials agreed that enhancements can be made to further 

assure accountability and that they are assessing the best way to provide assurance that 

the expenditures of grantees are in compliance with grant agreements. Open World 

officials noted that they would develop a process that is risk-based and also noted a 

number of activities to augment Open World’s effectiveness in this area. For example, 

they cited plans to (1) obtain signed affidavits from the heads of local hosting 

organizations, attesting that funds were spent in accordance with the requirements of the 

grants; (2) obtain signed statements of assurances completed by each grantee; (3) obtain 

summary reports of planned versus actual grant expenditures; (4) obtain reports 

evaluating hosting activities; and (5) perform sampling of grant expenditures to monitor 

and assess grantees’ compliance with fund expenditure requirements. 

Open World Has Taken Steps to Address Our Recommendations on Performance 

Measurement, and These Actions Reflect Several Leading Practices

Open World Has Taken Actions to Strengthen Performance Measurement

Since our 2004 report, Open World has taken steps to improve its efforts to measure 

performance. In addition, Open World has taken a number of steps to strengthen its 

mechanisms for collecting data and reporting on performance, such as reporting to its 

Board the results achieved for each of its performance measures and requiring periodic 

reports on performance from program stakeholders (see table 2). 
Page 8 GAO-12-1004R Open World Leadership Center

Table 2: Actions Taken by Open World to Address GAO’s 2004 Performance Measurement 

Recommendations 

2004 GAO recommendations on performance 

measurement 

Open World actions to address recommendations

Establish strategic and performance plans that 

articulate Open World’s direction and set 

measureable goals and indicators

• Established its first Strategic Plan for Fiscal Years 

2007-2011. The plan contained:

o mission statement,

o goals, and 

o performance indicators

• Developed its second Strategic Plan for Fiscal 

Years 2012-2016, which also includes the 

elements that we recommended

Strengthen the program’s mechanisms for collecting 

data and reporting on program performance

• Presented at the February 2012 Board meeting 

Open World’s first comprehensive quantitative 

analysis of annual achievement on each of its 

performance measures for fiscal years 2007 to 

2011

• Implemented periodic reports from program hosts, 

facilitators, and contractors to ensure that 

management receives standardized information 

and feedback about program performance and 

results

• Launched efforts to convert Open World’s 

performance databases to a web-based system 

intended to reduce time needed to find, utilize, 

and report on program feedback and performance 

data

• Established targets for each performance 

measure in its Strategic Plan for Fiscal Years 

2012-2016 

Source: GAO.

Open World’s Performance Measurement Efforts Are Generally Consistent with Several 

Leading Practices 

Open World’s efforts to measure performance are generally consistent with several 

leading practices, and it has plans to further strengthen its performance measurement 

mechanisms to better align them with leading practices. Although not required for Open 

World, the Government Performance and Results Act’s (GPRA) requirement for executive 

branch agencies to establish measures of performance serves as a leading practice for all 

federal agencies.11 

In a previous report, we identified nine key attributes of successful performance measures 

and used them to assess the indicators agencies use to measure their performance.12

 

11Government Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285, as amended by 

GPRA Modernization Act of 2010, Pub. L. No. 111-352, 124 Stat. 3866 (2011). 

As 

12GAO-03-143. The key attributes of successful performance measures are (1) objectivity, (2) clarity, (3) 

linkage between measure and agencywide goals, (4) measurable target, (5) reliability, (6) covering core 

program activities, (7) limited overlap, (8) balance, and (9) covering governmentwide priorities.
Page 9 GAO-12-1004R Open World Leadership Center

of August 2012, Open World’s performance measures were consistent with several of 

these key attributes, and Open World had plans to further align them with the attributes. 

For example, most performance measures in Open World’s Strategic Plan for 2012-2016 

were clearly stated. All of the 23 measures clearly required either a number, percentage, 

or amount. In addition, Open World’s measures allowed the collection of objective data. 

For example, the measures focused on objective counts, such as number of projects 

undertaken, number of partnerships sustained or formed, and the value of cost-shares as 

a percentage of the total appropriation. However, Open World’s strategic plan included 

some intended outcomes that did not link to corresponding measures or program activities 

that contribute to achieving these outcomes. One such intended outcome was that the 

“nominations process is transparent and produces delegates with superior professional 

qualifications.” Without a corresponding performance measure, management may be less 

able to gauge progress and determine whether those outcomes have actually been 

achieved. When we discussed this finding with Open World officials in August 2012, they

stated that they planned to revise their performance measures to ensure that the

measures directly link the activities of the program to the objectives in their strategic plan. 

Commenting on a draft of this report in September 2012, Open World officials stated that 

they had revised their performance measures to address this issue.13

Open World has recently taken steps to report more systematically on its performance 

and has plans to make further improvements to reflect leading practices. We have 

previously reported that performance data can have real value only if they are used to 

identify the gap between an organization’s actual performance level and the performance 

level it has identified as its goal.14 Once the performance gaps are identified, managers 

can determine where to target their resources to improve overall mission accomplishment. 

A leading practice in GPRA directs agencies to release an annual performance update 

that compares actual performance with goals. Before 2012, Open World did not 

systematically report the results for its performance measures.15

 

13Open World revised its performance measures after we completed our audit work. We therefore did not 

assess the revised measures.

In February 2012, Open 

World shared for the first time with its Board annual numerical results for each of the 

indicators in its Strategic Plan for Fiscal Years 2007-2011, but it had not previously 

reported annual performance goals for those years against which it could compare the 

actual results. In June 2012, Open World finalized both 2011 baseline values for each of 

its performance measures and annual targets for fiscal years 2012 through 2016 that 

would allow management to systematically track future performance against program 

goals. When we shared our preliminary findings with Open World officials in August 2012, 

Open World did not have a performance plan that explained the basis for comparing 

results with goals. The officials stated that they planned to use their newly established 

targets to develop an agency performance plan and publicly report on its annual 

performance against such goals. They stated that these actions would better align their 

performance measurement efforts with leading practices. Commenting on a draft of this 

14GAO, Executive Guide: Effectively Implementing the Government Performance and Results Act, GAO/GGD96-118 (Washington, D.C.: June 1996).

15Open World’s annual reports contain anecdotal results of program activities, but do not systematically 

assess results achieved for each of its performance measures. 
Page 10 GAO-12-1004R Open World Leadership Center

report in September 2012, Open World officials stated that they had finalized an annual 

performance plan for 2012.16

Agency Comments

Open World provided written comments on a draft of this report (see Enclosure I). Open 

World generally agreed with our findings. Regarding financial management, Open World 

stated that the enhancements it will undertake as a result of our observations will 

strengthen its financial oversight of its grants. Regarding performance measurement, 

Open World stated that our report provides some useful suggestions on linking strategic 

plan objectives to measures of performance. Open World also reviewed the draft report 

for technical accuracy. Its technical comments have been incorporated into this report, as 

appropriate. 

- - - - - 

We are sending copies of this report to appropriate congressional committees and the 

Executive Director of the Open World Leadership Center. In addition, this report will be 

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

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

Courts at (202) 512-8980, or courtsm@gao.gov, or Beryl H. Davis at (202) 512-2623, or 

davisbh@gao.gov. Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. GAO staff who made major 

contributions to this report are listed in enclosure II.

Michael J. Courts

Acting Director

International Affairs and Trade

 

16Open World finalized its new performance plan after we completed our audit work. We therefore did not 

assess the new performance plan. 
Enclosure I

Page 11 GAO-12-1004R Open World Leadership Center

Comments from the Open World Leadership Center
Enclosure I

Page 12 GAO-12-1004R Open World Leadership Center
Enclosure II

Page 13 GAO-12-1004R Open World Leadership Center

GAO Contacts and Staff Acknowledgments

GAO Contacts

Michael J. Courts, (202) 512-8980

Beryl H. Davis, (202) 512-2623

Staff Acknowledgments

In addition to the persons named above, Jeffrey Baldwin-Bott, Elizabeth Curda, Martin De 

Alteriis, Karen Deans, Cole Haase, David Hancock, James Healy, Joy Labez, Grace Lui, 

and Elizabeth Martinez made key contributions to this report. 

(320908)
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