a

GAO

United States Government Accountability Office

Subcommittee on Energy and Water 

Development, Committee on 

Appropriations, House of 

Representatives

September 2005 ARMY CORPS OF 

ENGINEERS

Improved Planning 

and Financial 

Management Should 

Replace Reliance on 

Reprogramming 

Actions to Manage 

Project Funds

GAO-05-946
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-946.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Anu Mittal at 

(202) 512-4852 or mittala@gao.gov. 

Highlights of GAO-05-946, a report to 

Subcommittee on Energy and Water 

Development, Committee on 

Appropriations, House of Representatives 

September 2005

ARMY CORPS OF ENGINEERS 

Improved Planning and Financial 

Management Should Replace Reliance on 

Reprogramming Actions to Manage 

Project Funds 

In fiscal years 2003 and 2004, the Corps reprogrammed funds over 7,000 

times and moved over $2.1 billion among projects within the investigations 

and construction appropriations. Moreover, funds were moved in and/or out 

of nearly two thirds of the projects within these appropriation accounts. 

Comparable data for the operation and maintenance appropriation could not 

be provided by the Corps. 

GAO reviewed a random sample of 271 general investigation, construction 

general, and operation and maintenance projects and found that the Corps 

generally reprogrammed funds in accordance with its guidance. However, in 

eight cases, the Corps’ reprogramming actions did not comply with the 

guidance because it either exceeded established reprogramming thresholds 

and/or did not provide the appropriate notification to the Congress. 

Although in most cases the Corps reprogrammed funds according to its 

guidance, this guidance is written in such a way that most reprogramming 

actions do not count as reprogramming actions toward the congressional 

notification thresholds, thereby diminishing the Congress’ knowledge and 

oversight of how the Corps spends appropriated funds. 

In many cases, the Corps reprogrammed funds from projects that 

experienced unforeseen delays to projects that could make use of additional 

funds. On the other hand, reprogramming actions were conducted that were 

inconsistent with the Corps’ reprogramming guidance, such as to achieve a 

Corps goal that all projects carry no funds into the next fiscal year. Some of 

these movements were as small as 6 and 7 cents. Corps guidance states that 

small reprogramming actions are inconsistent with sound project 

management and increase its administrative burden. Funds were also 

moved into projects that had a reported “need” and then were subsequently 

removed because they were suddenly “excess”– sometimes on the same day 

or within a few days or weeks. Such movements appear to serve little useful 

purpose and create an administrative burden for the Corps because of the 

time and effort needed to accomplish these movements. 

The Corps has come to rely on reprogramming as its primary method to 

manage project funds. The use of reprogramming is no longer used as a tool 

when emergencies and unforeseen circumstances occur but instead has 

become the regular, recurring financial management practice. Finally, the 

use of numerous reprogramming actions to manage project funds, without a 

set of formal Corps-wide priorities, has resulted in an uncoordinated 

movement of funds between projects, with little consideration to pending 

needs or long-term planning. 

In recent years, the Army Corps of 

Engineers (Corps) has had more 

work to accomplish than funds 

available. The Congress has 

supported the Corps' need to 

reprogram funds to complete 

projects. Reprogramming allows 

the Corps to move funds from 

projects that can not use available 

funds to those that can. However, 

concerns have been expressed 

about whether the Corps 

reprogrammed funds in accordance 

with applicable guidance. 

GAO determined for fiscal years 

2003 and 2004 (1) the amount of 

funds reprogrammed; (2) if the 

Corps followed reprogramming 

guidance; (3) why the Corps 

reprogrammed funds; and (4) how 

effective the Corps’ reprogramming 

strategy was in managing funds. 

What GAO Recommends

GAO made five recommendations 

to help the Corps reduce its reliance

on reprogramming actions, institute 

a financial planning and priority 

process for managing project funds, 

and work with congressional 

committees to develop meaningful 

reprogramming guidance. 

In its comments on the draft report, 

the Department of Defense 

concurred with all but one 

recommendation. It did not concur 

with the need to allot funds to 

projects periodically during the 

year. GAO still believes that this 

recommendation is needed 

because project changes occur 

throughout the year. 
Page i GAO-05-946 Army Corps of Engineers

Contents

Letter 1

Results in Brief 3

Background 6

The Corps Reprogrammed Significant Amounts of Funds among 

Hundreds of Projects 10

The Corps Followed Internal Guidance That Allowed Extensive 

Reprogrammings Without Congressional Notification 11

The Corps Reprogrammed Funds for Various Reasons 18

The Corps’ Reprogramming Activities Resulted in Inefficient 

Management of Funds 21

Conclusions 26

Recommendations for Executive Action 27

Agency Comments and Our Evaluation 28

Appendixes

Appendix I: Scope and Methodology 31

Appendix II: Reprogramming Guidance Used by the Corps 32

Appendix III: Projects with Reprogrammings That Did Not Follow Corps 

Guidance 33

Fund Movements Conducted under ER 11-2-201 (October 1, 2002, to 

May 26, 2004) 33

Fund Movements Conducted under Guidance Based on the 

Direction Provided in the House Report 108-554 (May 27 to 

September 30, 2004) 33

Appendix IV: Comments from the Department of Defense 36

Appendix V: GAO Contact and Staff Acknowledgments 39

GAO Contact 39

Staff Acknowledgments 39

Tables Table 1: Fiscal Years 2003 and 2004 Appropriations 7

Table 2: Projects Where the Corps Failed to Follow 

Reprogramming Guidance 12

Figure Figure 1: Reprogramming Categories during Fiscal Years 2003 and 

2004 14
Contents

Page ii GAO-05-946 Army Corps of Engineers

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Page 1 GAO-05-946 Army Corps of Engineers

United States Government Accountability Office

Washington, D.C. 20548

A

September 16, 2005 Letr

The Honorable David L. Hobson

Chairman, Subcommittee on Energy 

and Water Development

Committee on Appropriations

House of Representatives

The Honorable Peter J. Visclosky

Ranking Minority Member

Subcommittee on Energy and Water Development

Committee on Appropriations

House of Representatives

Each year, the Congress provides funding to the U. S. Army Corps of 

Engineers (Corps) for hundreds of investigations, construction, and 

operation and maintenance projects for the nation’s water resources.1

During fiscal year 2004, the Corps’ budget for these types of projects was 

more than $3.8 billion. The conference report accompanying the bill that 

appropriates the funds includes a specific amount of funding for each 

project, in effect providing the Corps with direction for accomplishing 

water resource projects. However, the Corps may reprogram funds among 

the projects. Reprogramming is generally defined as the movement of 

funds among projects within an appropriation account and is permitted to 

provide agencies with the flexibility needed to manage appropriated funds. 

The authority to reprogram funds in and out of projects is implicit in an 

agency's responsibility to manage its funds, and it has evolved largely in the 

form of informal nonstatutory agreements between agencies and their 

congressional oversight committees. Although an agency’s ability to 

reprogram funds may be restricted by statute, more frequently 

congressional guidance on the extent and nature of an agency’s 

reprogramming authority is provided in committee reports that accompany 

appropriation bills. In the case of the Corps, the agency had developed 

internal reprogramming guidance, based on previous congressional 

direction, in 1995 that was in effect until May 2004. At that time, the Corps 

received reprogramming direction from both the Senate and the House 

1

In this report, the terms “investigations” and “construction” are used to describe the 

appropriation accounts entitled “general investigations” and “construction, general,” 

respectively. 
Page 2 GAO-05-946 Army Corps of Engineers

Appropriations Committees. Starting on May 27, 2004, the Corps’ 

reprogramming procedures were based on direction that was subsequently 

included in the House of Representatives report on the fiscal year 2005 

appropriations bill. The Corps’ reprogramming guidance–both before and 

after May 27, 2004–required notifying the Congress of the Corps’ intention 

to move funds when reprogrammings exceeded specific thresholds. The 

thresholds vary by type of project and are set as a specific dollar amount 

and/or a percentage of project funding. The May 27, 2004, guidance was 

somewhat more restrictive, although still permitting the Corps to have 

considerable flexibility in reprogramming funds between projects. 

In this context, for fiscal years 2003 and 2004, we determined (1) how much 

funding the Corps moved within its Civil Works appropriations, (2) the 

extent to which the Corps followed applicable guidance in moving funds 

between projects, (3) the reasons for Corps’ reprogramming actions during 

fiscal years 2003 and 2004, and (4) how effective the Corps’ reprogramming 

strategy was in managing appropriated funds. In conducting our work, we 

reviewed the Corps’ overall reprogramming activity within the 

investigations, construction, and operation and maintenance 

appropriations during fiscal years 2003 and 2004.2

 We selected a random 

sample of 271 investigations, construction, and operation and maintenance 

projects from these 2 years and reviewed each reprogramming activity, 

determined why funds were reprogrammed, and whether funds were 

reprogrammed in accordance with the guidance in effect at the time. We 

also held discussions with program and project managers to obtain further 

details about the projects included in our sample and about the advantages 

and disadvantages of the Corps’ use of reprogramming to manage project 

funds. We conducted our review from December 2004 through June 2005 in 

accordance with generally accepted government auditing standards, which 

included an assessment of data reliability and internal controls. Appendix I 

contains a more detailed discussion of our scope and methodology.

2

Investigations are studies to determine the need, engineering feasibility, economic 

justification, and the environmental and social suitability of a project. Investigations also 

include preconstruction, engineering, design work, data collection, and interagency 

coordination and research activities. Construction projects are construction and major 

rehabilitation projects that relate to navigation, flood control, water supply, hydroelectric 

power, and environmental restoration. Operation and maintenance projects include the 

preservation, operation, maintenance, and care of existing river and harbor, flood control, 

and related activities at the projects that the Corps operates and maintains.
Page 3 GAO-05-946 Army Corps of Engineers

Results in Brief In fiscal years 2003 and 2004, the Corps conducted thousands of 

reprogramming actions and moved billions of dollars among its civil works 

projects. Specifically, in fiscal years 2003 and 2004, the Corps 

reprogrammed funds over 7,000 times and moved over $2.1 billion among 

investigations and construction projects; the Corps could not provide 

agency wide data for reprogramming actions for operation and 

maintenance projects.3

 During fiscal years 2003 and 2004, more than 60 

percent of the over 1,500 investigations and construction projects had 

funds reprogrammed. In both years, the Corps reprogrammed over 56 

percent of the total funds appropriated for the investigations and 

construction accounts. 

Although the Corps generally followed its reprogramming guidance, the 

guidance has been developed in such a way that it permits extensive 

movements of funds without congressional notification. As a result, the 

Corps was able to move billions of dollars among hundreds of projects 

without congressional knowledge and oversight. For 263 of the 271 

randomly selected projects we reviewed, the Corps reprogrammed funds in 

fiscal years 2003 and 2004 in accordance with its reprogramming guidance. 

For the 8 projects where the Corps’ reprogramming actions did not comply 

with the guidance, the Corps had exceeded the thresholds established for 

reprogramming but did not provide the appropriate notifications to the 

Congress. Even though the Corps moved funds according to its guidance, 

the guidance had been developed in such a way that most movements of 

funds did not count toward congressional notification thresholds. For 

example, for investigations and construction projects, the Corps 

categorized all reprogrammings of funds out of a project as “revocations” 

which, according to its guidance, did not count toward congressional 

notification thresholds. Consequently, the Corps could move most or all of 

the funds out of a project without having to notify the Congress. Similarly, 

if funds were returned to the same project at a later date, the Corps did not 

consider these movements as reprogrammings that counted toward 

congressional notification thresholds. Except for the period from May 27, 

2004, to September 30, 2004, when different guidance was in effect, only 

those movements of funds into a project that were specifically labeled by 

the Corps as “reprogrammings” counted toward the congressional 

3

In this report, we calculate the dollar amount of reprogramming actions as the total amount 

of funds moved into and out of a project. For instance, if $10,000 was moved into a project 

and $5,000 was subsequently moved out in the same fiscal year, we determined the total 

dollar amount of reprogramming for that project to be $15,000.
Page 4 GAO-05-946 Army Corps of Engineers

notification threshold. This category was seldom used and, according to 

Corps officials, when used, was generally limited to amounts that were less 

than the congressional notification threshold. As a result, only about 16 

percent of investigations and construction reprogramming actions prior to 

May 27, 2004, were categorized as Corps-defined “reprogrammings” that 

counted toward the threshold for congressional notification. We believe 

that all actions should have counted toward the congressional notification 

thresholds, because when the Corps moves funds that create a major 

deviation from the funding direction the Congress provided for these 

projects, the Congress should be informed of the changes and the reason 

for the changes no matter how the Corps chooses to categorize the 

movement.

The Corps reprogrammed funds for a variety of reasons, some which 

appear to be inconsistent with the Corps’ internal reprogramming 

guidance. The Corps’ guidance states that reprogramming to address 

unforeseen events is a valid use of reprogramming and increases the 

efficiency of the entire program. In many cases, the Corps reprogrammed 

funds from projects that were experiencing unforeseen delays to projects 

that could make use of additional funds. Similarly, in other cases, funds 

were moved into projects that experienced unexpected costs, such as a 

lock failure on a waterway. In these cases, funds had to be moved from one 

project to another because the Corps allocated all available funds to 

projects at the beginning of the year and did not keep any funds aside for 

unexpected project contingencies. On the other hand, large numbers of 

reprogrammings were also conducted for reasons that were inconsistent 

with the Corps’ internal reprogramming guidance. For example, to achieve 

a Corps goal that all projects carry no funds into the next fiscal year, even 

though Corps funds are “no year” funds and remain available to the Corps 

until spent, about 23 percent of all movements occurred during the last 

month of the fiscal year. Some of these movements were as small as 6 and 7 

cents. Such movements appear to serve little useful purpose and create an 

administrative burden for the Corps. Corps guidance states that small 

reprogrammings are inconsistent with sound project management, cause 

additional accounting and paperwork efforts at all levels, and increase the 

risk of errors.

The Corps’ financial management practice of conducting thousands of 

reprogrammings resulted in movements of funds that were not necessary 

and reflected poor planning and an absence of Corps-wide priorities for 

projects. Corps reprogramming guidance discourages the temporary 

movement of funds and considers such actions to be inconsistent with 
Page 5 GAO-05-946 Army Corps of Engineers

sound project management practices. In addition, Corps reprogramming 

guidance states that only funds surplus to current year requirements should 

be a source for reprogramming. However, the Corps uses a “just-in-time” 

reprogramming strategy under which it moves funds from projects that 

currently have available funds to projects with an immediate need, 

regardless of the donor projects’ future needs or the relative priority of the 

projects receiving the funds. As a result, funds were removed from projects 

without considering their near-term funding requirements, such as projects 

with impending studies. Funds were also moved into projects that 

reportedly had a “need” and then were subsequently removed because they 

were “excess”—sometimes on the same day or within a few days or weeks. 

For example, in fiscal year 2004, the Corps revoked 7 percent of the funds 

from every construction project—a total of $154.6 million— regardless of 

whether the funds were needed on the project or not. These funds were 

moved primarily to provide funds for “national requirements projects” 

(projects to which Corps headquarters management had promised to 

restore funds moved in prior years). Of the funds revoked and moved to the 

national requirements projects, $38.8 million was eventually moved to 

other projects because some of the national requirements projects had no 

need for these funds. One national requirements project— New York and 

New Jersey Harbor—received nearly $24.9 million. All of those funds, plus 

an additional $10.3 million were not needed on the project and were 

subsequently moved to other projects. 

We are making recommendations that the Secretary of Defense direct the 

Commanding General and Chief of Engineers of the U.S. Army Corps of 

Engineers to eliminate the use of excessive reprogramming actions and to 

provide better financial management of project funds. In commenting on a 

draft of this report, the Department of Defense stated that it was a 

constructive report and concurred with all but one of our 

recommendations. Regarding our recommendation that the Corps develop 

a financial planning and management system for the investigations, 

construction, and operation and maintenance appropriations that changes 

the way the Corps allocates funds from an annual basis to a more frequent 

basis and reflects actual schedule and project performance, the department 

said that it is important that the Corps continue to allocate all funds 

provided by the Congress for each project and that any deviation from that 

amount would not reflect the intent of the Congress. The department also 

said that withholding funds from the initial allocation would add 

administrative burden, increase uncertainty in execution, and would not 

aid in scheduling and schedule review.
Page 6 GAO-05-946 Army Corps of Engineers

We disagree with the department because from the time the Corps submits 

its budget estimates until the appropriation is received, changes may have 

occurred and projects may not need the amount of funds included in the 

conference report or may need additional funds. Our recommendation 

would allow the Corps to make these known changes before allocating all 

funds to a project. Currently, the Corps makes such changes through 

reprogramming actions. Our recommendation would merely serve to 

streamline the process. This would eliminate the administrative burden of 

making project funding allocations that the Corps already knows it is going 

to reallocate through reprogramming actions.

Background The Corps’ Civil Works program is responsible for investigating, 

developing, and maintaining the nation’s water and related environmental 

resources. In addition, the Civil Works program also provides disaster 

response as well as engineering and technical services. The Corps’ 

headquarters is located in Washington, D.C., with eight regional divisions, 

and 38 districts that carry out its domestic civil works responsibilities.

Each year, the Corps’ Civil Works program receives funding through the 

Energy and Water Development Appropriations Act. The act normally 

specifies a total sum for several different appropriation accounts, including 

investigations, construction, and operation and maintenance, to fund 

projects related to the nation’s water resources. The funds appropriated to 

the Corps are “no year” funds, which means that they remain available to 

the Corps until spent. Table 1 shows the appropriations received in fiscal 

years 2003 and 2004 for the investigations, construction, and operation and 

maintenance accounts.
Page 7 GAO-05-946 Army Corps of Engineers

Table 1: Fiscal Years 2003 and 2004 Appropriations

Source: Fiscal years 2003 and 2004 Energy and Water Development Appropriations Acts.

The conference report accompanying the Energy and Water Development 

Appropriations Act specifically lists individual investigations, construction, 

and operation and maintenance projects and the amount of funds 

designated for each project. In effect, this provides the Corps with its 

priorities for accomplishing its water resource projects. In recent years, the 

Congress has appropriated fewer funds than the sum of the amount 

designated to individual projects in the conference report. The difference 

between the total amount designated for projects in the conference report 

and the full appropriation is known as savings and slippage. As directed by 

the Congress, the Corps reduces the conference report amount for each 

project by a percentage to allow for savings and slippage and then releases 

the entire amount of each projects’ funding to the districts’ project 

managers for executing projects.4

 However, once the Corps has allotted the 

funds to specific projects, the Corps may reprogram the funds to other 

projects.

Reprogramming Authority Reprogramming is the shifting of funds from one project or program to 

another within an appropriation or fund account for purposes other than 

those contemplated at the time of appropriation. A reprogramming 

transaction changes the amount of funds provided to at least two projects–

the donor project and the recipient project. However, more than two 

projects are often involved in a single reprogramming action. For example, 

in an effort to make effective use of available funding, the Corps may move 

Dollars in thousands

Appropriation accounts

Fiscal year 2003

budget authority

Fiscal year 2004

budget authority

Investigations $135,019 $116,949

Construction 1,756,012 1,722,319

Operation and Maintenance 1,940,167 1,967,925

Total $3,831,198 $3,807,193

4

Part of the appropriation the Corps receives in its appropriation act is designated or 

“earmarked” in the act itself for specific projects. In general, funds that are earmarked to 

specific projects are not available for reprogramming and savings and slippage is not 

deducted from project funding. 
Page 8 GAO-05-946 Army Corps of Engineers

funds from a construction project that has slipped due to inclement 

weather and reprogram the funds to one or more construction projects that 

are ahead of schedule or experiencing cost overruns.

The authority to reprogram funds is implicit in an agency’s responsibility to 

manage its funds; no specific additional statutory authority is necessary. 

While there are no governmentwide reprogramming guidelines, the 

Congress exercises control over an agency’s spending flexibility by 

providing guidelines or nonstatutory instructions on reprogramming in a 

variety of ways. For example, some reprogramming and reporting 

guidelines have evolved from informal agreements between various 

agencies and their congressional oversight committees. Reprogramming 

guidelines frequently involve some form of notification to the House and 

Senate appropriations committees prior to the action.5

 (In this report, 

notification to the House and Senate appropriations committees will be 

referred to as congressional notification or notifying the Congress.) In 

addition to notification, reprogramming arrangements sometimes also 

provide for committee approval prior to the movement of funds that 

exceed certain thresholds. 

The Corps’ reprogramming guidelines have evolved over nearly 50 years, 

stemming from direction provided to the Corps through congressional 

reports and informal agreements with the House and Senate 

Appropriations Committees.6

 In 1995, the Corps published revised internal 

reprogramming guidance based upon previous congressional direction 

(U.S. Army Corps of Engineers, Engineering Regulation ER 11-2-201). 

These reprogramming guidelines set forth procedures and polices on 

reprogramming actions for civil works activities under investigations, 

construction, and operation and maintenance appropriations titles, among 

others. 

5

In most cases, the committee review process is nonstatutory and derives from instructions 

in committee reports, hearings, and other correspondence.

6

Congressional committee instructions to the Corps to reprogram construction project 

funds were first contained in the House and Senate reports on the 1957 Public Works 

Appropriation Bill. Reprogramming instructions have been included many times since in 

subsequent congressional reports. Congressional committee instructions to the Corps to 

reprogram investigations and operation and maintenance project funds were established by 

informal agreement and precedent over the years. It was first formally addressed by the 

Congress in the Senate report on the 1980 Energy and Water Development Appropriations 

Bill.
Page 9 GAO-05-946 Army Corps of Engineers

Under the 1995 guidance, the Corps was permitted to reprogram 

construction funds up to 15 percent of the base amount of a project for any 

fiscal year. The base amount is the amount listed in the conference report 

plus any funds carried in from previous fiscal years and adjusted for funds 

sequestered, deferred, rescinded, or released from deferral.7

 Any 

reprogramming action(s) that exceeded the 15 percent threshold required 

the Corps to coordinate its intentions with both the House and Senate 

Appropriations Committees. There were two exceptions to the 15 percent 

limitation. The Corps may reprogram up to $300,000, without regard to 

percentage, for projects on which the amount available for the fiscal year is 

$2 million or less, and the Corps may move up to $5 million per 

construction project without regard to the percentage limitation when the 

increased requirement results from a settled contractor claim, increased 

contractor earnings due to accelerated rate of operations, or real estate 

deficiency judgments. 

For investigations projects, the Corps was permitted to reprogram up to 

$25,000 for projects that have a base amount of $25,000 or less. When the 

base amount exceeded $25,000, the reprogramming authority was 100 

percent of the base up to $50,000 and 25 percent of the increment over 

$50,000, not to exceed a total reprogramming of $150,000. Any 

reprogramming action(s) that exceeded these thresholds required the 

Corps to coordinate with the Congress its intention to reprogram funds. 

The 1995 guidance does not outline specific thresholds for congressional 

notification in the operation and maintenance appropriation. According to 

Corps officials, the agency interpreted the guidance as allowing unlimited 

reprogramming authority without congressional notification thresholds for 

operation and maintenance projects.

During the spring of 2004, the Corps received new reprogramming 

direction from both the House and Senate Appropriations Committees. On 

May 27, 2004, the Corps issued an internal memorandum changing the 

Corps’ existing reprogramming guidance to reflect direction that was 

subsequently provided in the House of Representatives Committee on 

Appropriations Report accompanying the 2005 Energy and Water 

Development Appropriation Bill (House Report 108-554 accompanying H.R. 

7

Sequestration is the cancellation, in accordance with the Budget Enforcement Act, of 

budgetary resources provided by discretionary appropriations or direct spending law. A 

deferral is a postponement of budget authority for up to 1 year. A rescission, which must be 

approved by the Congress, is a cancellation of previously approved budget authority.
Page 10 GAO-05-946 Army Corps of Engineers

4614). The new guidance required the Corps to notify the Congress for any 

intended single reprogramming action on construction and operation and 

maintenance projects that exceeded $300,000 plus 20 percent of the base 

amount and to obtain approval on any project’s cumulative reprogramming 

actions that exceeded $4 million. The base amount under House Report 

108-554 was defined as the amount appropriated for the project or program 

in the budget plus any amounts carried over from previous fiscal years or 

reprogrammed during the budget year. For investigations, the Corps was 

the required to notify the Congress for any intended single reprogramming 

action that exceeded $50,000 plus 25 percent of the base and to obtain 

approval on a project’s cumulative reprogramming actions that exceeded 

$250,000. 

The Corps followed this guidance until the end of November 2004. At that 

time, the Corps again received new direction from the Congress, contained 

in the conference report accompanying the 2005 Energy and Water 

Development Appropriation Act. These guidelines provided cumulative 

reprogramming percentage thresholds for investigations, construction, and 

operation and maintenance accounts. The guidelines further required the 

Corps to provide quarterly reports notifying the Congress of 

reprogramming actions that fell between certain thresholds and required 

congressional approval for reprogramming actions that exceeded an upper 

threshold limit. The guidelines also allowed certain categories of 

reprogramming actions to be excluded from counting toward 

congressional notification thresholds. Appendix II shows the 1995 and 2004 

Corps reprogramming guidance.

The Corps 

Reprogrammed 

Significant Amounts of 

Funds among 

Hundreds of Projects

In fiscal years 2003 and 2004, the Corps reprogrammed funds over 7,000 

times (3,415 actions in fiscal year 2003 and 3,641 actions in fiscal year 2004) 

among investigations and construction projects. Sixty-three percent (988 of 

1,578) of fiscal year 2003 and 64 percent (998 of 1,533) of fiscal year 2004 

investigations and construction projects had funds either moved in and/or 

out. On average, of the projects that had at least one reprogramming, there 

were approximately 3.6 (3.5 in fiscal year 2003 and 3.6 in fiscal year 2004) 

actions per project. Corps-wide reprogramming data on operation and 

maintenance projects are not available.

In terms of dollars, in fiscal years 2003 and 2004, the Corps reprogrammed 

approximately $2.1 billion of the $3.7 billion available for investigations and 

construction project funds. Additionally, the average amount of funds 

moved per reprogramming action was approximately $298,026 ($306,133 in 
Page 11 GAO-05-946 Army Corps of Engineers

fiscal year 2003 and $290,423 in fiscal year 2004) for investigations and 

construction projects. 

Because the Corps could not provide us with Corps-wide reprogramming 

data for operations and maintenance projects, we reviewed the 107 

operations and maintenance projects in our sample and found that the 

Corps reprogrammed funds 459 times for this sample, which averaged to 

4.29 reprogramming actions per project. These 459 reprogramming actions 

totaled approximately $31 million, and the average amount of funds moved 

per operation and maintenance reprogramming action was $67,592.

The Corps Followed 

Internal Guidance That 

Allowed Extensive 

Reprogrammings 

Without Congressional 

Notification

For the majority of the reprogrammings that we reviewed as part of our 

sample of 271 projects, the Corps followed the reprogramming guidance it 

had in place at the time (under both the Corps’ 1995 guidance and the May 

2004 guidance). In the few instances where the guidance was not followed, 

most involved the Corps failing to notify the Congress when it intended to 

reprogram funds that would exceed certain limits. The Corps’ 

reprogramming guidance allowed most reprogrammings to be categorized 

as fund movements that did not count toward the congressional 

notification thresholds. As a result, the Corps was able to follow its 

reprogramming guidance, but still conduct a large number of fund 

movements (that represented a major deviation from the funding direction 

the Congress provided for the projects in its conference report) and not 

have to inform the Congress of the changes and the reason for the changes. 

The Corps Generally 

Followed Its 

Reprogramming Guidance 

In our sample of 271 projects, reprogramming actions related to only 8 

projects did not follow the reprogramming guidance in place at the time 

when the funds were moved.8

 For these 8 projects, there were a total of 12 

movements of funds that did not conform to the reprogramming guidance. 

One of these movements occurred during the period from October 1, 2003, 

to May 26, 2004, when the Corps’ reprogramming guidance was contained 

8

The Corps’ reprogramming guidance changed during the fiscal year 2003 through 2004 

timeframe of our review, and the guidance contains different, specific criteria for 

investigations, construction, and operation and maintenance projects. However, the 

guidance for all projects during this timeframe generally contains limitations on the amount 

of funds that can be reprogrammed by Corps districts and divisions and instructions for 

notifying the Congress of the Corps’ intention to reprogram funds that exceed a specified 

amount. 
Page 12 GAO-05-946 Army Corps of Engineers

in the 1995 guidance. The remaining 11 movements occurred after May 26, 

2004, when the Corps’ guidance was revised in accordance with the 

direction provided in House Report 108-554. Table 2 lists the projects and 

the reprogramming actions, and describes how the Corps failed to follow 

its guidance. 

Table 2: Projects Where the Corps Failed to Follow Reprogramming Guidance

Source: GAO.

In general, in cases where the Corps failed to notify the Congress of its 

intention to move funds in excess of the notification threshold, Corps 

officials said that the actions were conducted at the district and that the 

district personnel were confused about the guidance. Additional 

information on the eight projects and 12 movements are provided in 

appendix III. 

Project Action Guidance not followed

Green and Barren Rivers Navigation 

Disposition in Kentucky

Reprogrammed $25,000 into the project Exceeded congressional notification 

threshold and did not notify the Congress

New York City Watershed in New York Revoked $800,000 Exceeded congressional notification 

threshold and did not notify the Congress 

until after the funds were moved

McAlpine Locks and Dam in Kentucky and 

Indiana

Moved $5.3 million into the project using 

accelerated contractor earnings authority

Exceeded limit for accelerated earnings 

movements and the reason funds were 

moved was not a correct use of this 

authority

Ramapo River at Oakland in New Jersey Revoked $600,000; revoked $1,700,000; 

revoked $600,000

Exceeded congressional notification 

threshold and did not notify the Congress or 

notified the Congress after the funds were 

moved

Ohio River Flood Protection in Indiana Revoked $500,000 Exceeded congressional notification 

threshold and did not notify the Congress

New York and New Jersey Harbor Revoked $6,900,000; revoked $8,587,000; 

revoked $8,500,000

Exceeded congressional notification 

threshold and did not notify the Congress 

until after the funds were moved

Bonneville Powerhouse Phase 1 in Oregon 

and Washington

Restored $332,000 prior years savings and 

slippage

Exceeded congressional notification 

threshold and did not notify the Congress

Plattsburgh Harbor in New York Revoked $625,000 Exceeded congressional notification 

threshold and did not notify the Congress
Page 13 GAO-05-946 Army Corps of Engineers

The Corps’ Reprogramming 

Guidance Allows Numerous 

Movements of Funds 

without Congressional 

Notification

Although in the majority of cases we reviewed the Corps complied with its 

guidance, this guidance has been developed in such a manner that it 

provides the agency with maximum flexibility to move funds without 

notifying the Congress. Specifically, we found that most movements of 

funds that were actually reprogramming actions were categorized by the 

Corps, in accordance with its guidance, as other types of fund movements, 

which did not have to be reported to the Congress. For example, the Corps 

guidance allowed reprogrammings to be categorized under one of the 

following categories, which did not count toward congressional 

notification. 

• Revocations, which are movements of funds out of a project.

• Restorations of current year savings and slippage, which are 

movements of funds into a project to restore that projects’ current year 

savings and slippage reduction. 

• Restorations of prior year savings and slippage/revocation, which are 

movements of funds into a project to restore savings and slippage 

reductions and/or funds reprogrammed out of a project in prior fiscal 

years.

• Restorations of current year revocations, which are movements of 

funds into a project to restore funds previously reprogrammed out of 

that project in the same fiscal year. 

• $5 million accelerated contractor earnings, which are movements of 

funds into a project to cover increased project requirements due to 

settled contractor claims, increased contractor earnings due to 

accelerated rate of operations, or a real estate deficiency judgment. 

The Corps used another category—“reprogram”—to categorize some 

movements of funds into a project. However, this category was seldom 

used and, according to Corps officials, when it was used, in most cases was 

generally limited to amounts under the congressional notification 

threshold. Figure 1 shows the reprogramming categories that were most 

commonly used for the investigations, construction, and operation and 

maintenance appropriations and which categories counted and did not 

count towards the congressional notification thresholds under the Corps’ 

1995 and 2004 guidance. 
Page 14 GAO-05-946 Army Corps of Engineers

Figure 1: Reprogramming Categories during Fiscal Years 2003 and 2004

The following three examples illustrate how the Corps can move large 

amounts of funds into or out of a project without notifying the 

Appropriations Committees and still be in compliance with its guidance. 

For the first project, the New York and New Jersey Harbor construction 

project in fiscal year 2003, the Corps moved over $65 million in and out of 

the project in the following 10 separate actions. 

• April 15, 2003; $28,052,000 revoked (funds needed for other projects);

• April 23, 2003; $2,685,000 restoration of current year revocation (funds 

needed to continue project);

Thresholds did not exist

Source: GAO.

Construction Reprogramming Categories during Fiscal Years 2003 and 2004

Operation and Maintenance Reprogramming Categories during Fiscal Years 2003 and 2004

Type of Corps Reprogramming Action

Reprogramming

Revocation

Restoration of current year savings and 

slippage

Restoration of current year revocation

Reprogramming

Revocation

Reprogramming

Revocation

Restoration of current year savings and 

slippage

Restoration of current year revocation

Restoration of prior year savings and 

slippage/revocation

$5 million accelerated contractor earnings

Counts toward

threshold

Counts toward

threshold

Does not count

toward threshold

Does not count

toward threshold

Investigations Reprogramming Categories during Fiscal Years 2003 and 2004

1995 Reprogramming

Guidance

2004 Reprogramming

Guidance
Page 15 GAO-05-946 Army Corps of Engineers

• May 7, 2003; $400,000 restoration of current year revocation (no 

explanation in file);

• June 4, 2003; $13,200,000 restoration of current year revocation (no 

explanation in file);

• June 9, 2003; $5,758, 000 revoked (funds needed for other projects);

• July 18, 2003; $8,782,000 restoration of current year revocation (no 

explanation in file);

• August 22, 2003; $1,600,000 restoration of current year revocation (funds 

needed to continue project);

• September 4, 2003; $1,700,000 restoration of current year revocation 

(funds needed to continue project);

• September 4, 2003; $2,500,000 restoration of current year revocation (no 

explanation in file); and

• September 26, 2003; $460,000 restoration of current year revocation 

(funds needed to continue project).

The amount moved was more than 4 times the cumulative threshold 

amount of $15,665,850 for this project, and the April 15, 2003, movement of 

$28,052,000, by itself, exceeded the threshold. Yet under the 1995 Corps 

guidance, none of these 10 actions were categorized as actions that 

counted toward the notification threshold and therefore the Corps did not 

have to notify the Congress of these movements.

Similarly, in fiscal year 2003, the Corps moved a total of over $3.1 million in 

and out of the Ohio River Greenway Public Access construction project in 

Indiana in the following seven separate actions. 

• April 22, 2003; $1,011,000 revoked (excess funds);

• April 23, 2003; $313,000 revoked (no explanation in file);

• May 14, 2003; $1,112,000 restoration of current year revocation (no 

explanation in file);

• June 17, 2003; $150, 000 revoked (no explanation in file);
Page 16 GAO-05-946 Army Corps of Engineers

• September 5, 2003; $342,000 revoked (excess funds);

• September 9, 2003; $146,000 revoked (no explanation in file); and

• September 29, 2003; $27,000 revoked (excess funds).

The amount moved was more than 10 times the cumulative threshold 

amount of $300,000 for this project, yet under the 1995 Corps guidance, 

none of these seven actions were categorized as actions that counted 

toward the notification threshold and the Congress was not notified of the 

movements.

In the third project, in fiscal year 2003, the Corps moved a total of over 

$10.1 million into the Columbia River Fish Mitigation construction project 

in Oregon in the following seven separate actions. 

• May 9, 2003; $4,700,000 restoration of current year savings and slippage 

(needed for contract payments);

• July 16, 2003; $200,000 restoration of current year savings and slippage 

(needed for continuation of programmed activities);

• July 22, 2003; $500,000 restoration of current year savings and slippage 

(needed for critical research items);

• September 8, 2003; $456,000 restoration of current year savings and 

slippage (needed for contractor earnings);

• September 12, 2003; $87,000 restoration of current year savings and 

slippage (needed to pay contractor);

• September 22, 2003; $408,300 restoration of current year savings and 

slippage (no explanation provided); and

• September 24, 2003; $3,772,000 restoration of current year savings and 

slippage (no explanation provided).

The amount moved exceeded the cumulative threshold amount of 

$9,256,350 for this project, yet under the 1995 Corps guidance, none of 

these seven actions were categorized as actions that counted toward the 

notification threshold and the Congress was not notified of these 

movements. In all of these examples, if all the movements of funds had 
Page 17 GAO-05-946 Army Corps of Engineers

been categorized as “reprogrammings” and therefore had counted toward 

the notification threshold, the Corps would have had to notify the Congress 

that it intended to reprogram funds for these projects.

The consequence of the Corps’ guidance is that it allowed the Corps to 

categorize reprogrammings in fiscal years 2003 and 2004 so that few 

reprogramming actions counted toward notification thresholds. We found 

that from October 1, 2002, through May 26, 2004, when the Corps’ 1995 

guidance was in effect, because of the way the Corps categorized 

movements of funds, only 18.2 percent of investigations movements and 

14.5 percent of construction movements counted toward the notification 

thresholds. (There was no notification threshold for operation and 

maintenance projects.) From May 27 to October 30, 2004, when the 

guidance was revised and made more restrictive, 79 percent of 

investigations movements and 74 percent of construction movements 

counted toward the notification thresholds.

On the basis of our review of 271 projects, if all movements of funds 

counted toward the notification threshold, the Corps would have had to 

notify the Congress about its intention to reprogram in 47 percent of the 

projects in fiscal year 2003 and 10 percent of the projects in fiscal year 

2004. (This assumes that the amount of each movement counts toward the 

threshold whether the funds are moved into or out of the project. The 

results are similar, however, if the cumulative impact of the movements are 

totaled (netted). For example, if the movements are netted, a movement 

into a project for $100,000 would offset another $100,000 movement out of 

that same project for a total of $0 counting toward the threshold. If 

movements were netted, the Corps would have had to notify the Congress 

about its intention to reprogram in 36 percent of the projects in fiscal year 

2003 and 6 percent of the projects in fiscal year 2004.) Instead, for the 

projects included in our sample, the Congress received notifications of 

intended reprogrammings for less than 1 percent of the projects in fiscal 

year 2003 and about 2 percent of the projects in fiscal year 2004. 

In discussing the manner in which the Corps conducted reprogrammings 

during fiscal years 2003 and 2004, Corps officials said that the number of 

reprogrammings and the manner in which they were categorized was 

necessary to fund projects during a period of restricted budgets. We 

believe, however, the movements of funds previously discussed are 

reprogrammings that should be counted toward congressional notification 

thresholds. The number of reprogrammings and the amount of the 

reprogrammings conducted by the Corps can result in a significant 
Page 18 GAO-05-946 Army Corps of Engineers

deviation from the funding profile the Congress provided for the projects in 

its conference report, yet the Congress was seldom informed of the 

changes and the reason for the changes. Such notification would provide 

the Congress with information concerning where the Corps was spending 

its funds and would allow the Congress to provide oversight of Corps 

activities.

The Corps 

Reprogrammed Funds 

for Various Reasons

Because the Corps typically allocates all its appropriations to authorized 

projects and does not keep any centralized funds available for unexpected 

project contingencies, reprogramming provides the flexibility to shift funds 

to respond to project changes and unforeseen events. Some of the reasons 

why the Corps reprogrammed funds in fiscal years 2003 and 2004 include 

weather factors, contract disputes, infrastructure malfunctions, new policy 

requirements, delays in securing cost-sharing agreements, unanticipated 

project starts, and savings and slippage. However, the Corps also 

reprogrammed funds for reasons that were inconsistent with the Corps’ 

guidance, such as to achieve the Corps’ goal of carrying zero funds into the 

next fiscal year and to restore funds to donor projects without regard to 

funding needs. 

The Corps Reprogrammed 

Funds to Respond to Project 

and Funding Changes 

Project and program managers at the Corps typically estimate project 

needs 1 to 2 years prior to receiving appropriated funds. As with all 

agencies that are funded through the annual budget process, by the time 

the Corps obtains its funding, factors upon which such estimates were 

based may have changed and unforeseen events may have occurred. 

Responding to circumstances such as unexpected weather patterns, 

infrastructure emergencies, and hurdles in obtaining cost-share funding 

may require the use of reprogramming actions.

For example, weather may have significant impacts on project costs and 

schedules. Unusually good weather may impact the execution of a project 

by extending the construction season and allowing more work to be 

completed; whereas unexpected weather may cause work delays. Weather 

may also impact project costs by causing damage that must be repaired. 

The Corps has often used reprogramming actions to adjust funding to 

accommodate unanticipated weather impacts. For example, in fiscal year 

2004, mud slides, caused by heavy rains, which breached the top of the dam 

embankment at the Joe Pool Lake operations and maintenance project in 

Texas, required emergency maintenance to stabilize the banks of the lake. 
Page 19 GAO-05-946 Army Corps of Engineers

The Corps reprogrammed $43,000 into the project to ensure the stability 

and safety of the dam.

The Corps has also used reprogramming to fund repairs required as the 

result of unexpected infrastructure malfunctions, such as a lock failure on 

a waterway. In November 2002, an upstream lock gate malfunctioned at the 

John Day Lock and Dam on the Columbia River in Oregon. It took the 

Corps several months to repair the gate. While repairs were being made, 

the Corps found additional structural damage and had to award a new 

contract to fix these problems. In fiscal years 2003 and 2004, the Corps 

reprogrammed nearly $21 million dollars into the project to cover the cost 

of the repairs. 

Similarly, for investigations projects, one-half of the funds for most 

feasibility studies must be provided by a cost share partner, such as a local 

or state government. Delays in securing this second-party funding may 

sometimes slow or halt a project’s schedule and allow the funds to be 

reprogrammed to other projects that could use the funds. For example, in 

the Metropolitan Louisville Mill Creek Basin investigations project in 

Kentucky, the project’s local cost-share sponsor decided not to fund the 

project and the land needed to begin the study could not be acquired. As a 

result, most of the project’s funds could not be used by the Corps and about 

90 percent of project’s fiscal year 2004 funds were reprogrammed to 

projects that could use the funds.

The Corps Also 

Reprogrammed Funds for 

Reasons That Were 

Inconsistent with the Corps’ 

Guidance

In managing its national program, the Corps also conducted some 

reprogramming actions for reasons that were inconsistent with the Corps’ 

internal reprogramming guidance. The Corps’ Civil Works training manual 

on reprogramming advises program managers to round reprogramming 

requests to the thousands or tens of thousands of dollars and states that 

minor reprogramming to close out accounts is not permitted. The Corps’ 

internal reprogramming guidance also advises that staff should not engage 

in small reprogrammings actions, but instead round transactions to the 

nearest $1,000. The guidance cites the negative administrative impact of 

such actions by stating that “minor reprogrammings cause additional 

accounting and paperwork efforts at all levels and increase the risk of 

errors.” However, the Corps conducted reprogramming actions simply to 

achieve an internal goal of a zero carry-over balance for each project at the 

end of the fiscal year. Such reprogramming actions resulted in numerous 

shifts of funds of small dollar amounts, thereby increasing the 

administrative burden on managers. 
Page 20 GAO-05-946 Army Corps of Engineers

Achieving 100 percent execution of project funds and zero carry-over 

balances was a management goal of the Corps’ Civil Works program during 

the time frame covered by our review. Realization of this goal was one of 

the primary performance metrics for project managers, who were rated on 

their ability to reach this target. In regard to achieving this goal, the Chief of 

the Civil Works Programs Integration Division noted that he had verbalized 

to Corps managers that “nothing else was acceptable.” Several Corps 

program managers commented that this internal performance measure 

resulted in large numbers of reprogramming actions. If project managers 

felt that they could not execute all of their project’s funds, they had an 

incentive to reprogram funds out of their project’s account, since their 

performance was measured by their ability to execute only funds remaining 

for the project. Such reprogramming actions make it easier for a manager 

to reach the 100 percent execution target and, therefore, receive a higher 

performance rating. 

Many of these actions occurred at the end of the fiscal year as project 

managers scrutinized their budgets for any funds that could not be 

expended within the fiscal year. Some of these reprogrammings were 

beneficial because the funds were moved to projects with year-end funding 

needs. However, some program managers told us that they felt the need to 

locate even excess “pennies” at the end of the fiscal year in order to achieve 

the target of zero carry over. As a result, in fiscal years 2003 and 2004, more 

reprogrammings occurred during the last month of the fiscal year than any 

other. For all investigations and construction projects in fiscal years 2003 

and 2004, approximately 23 percent of the reprogrammings conducted by 

the Corps occurred in the last month of the fiscal year, resulting in 1,617 

actions moving over $235 million. Just over 6 percent of these movements 

were for amounts of $1,000 or under. We found similar results for our 

sample of 271 projects. About 35 percent of the reprogrammings occurred 

in the last month of the fiscal year (343 actions moving over $31 million). 

Just over 13 percent of these movements were for amounts of $1,000 or 

under, with one as small as 6 cents. We found other projects, not included 

in our sample, with year-end reprogramming actions of $0.07, $13.42, 

$13.84, $14.00, $23.36, and $25.00. Reprogramming such small amounts of 

funds may unnecessarily strain administrative resources. 

Removing most of a project’s funding at the end of the fiscal year may also 

result in the Corps overlooking short-term project needs, particularly those 

at the beginning of the next fiscal year, and ends up resulting in additional 

unnecessary reprogramming actions. For example, in the Grand Isle and 

Vicinity construction project in Louisiana, the Corps revoked $28,000 on 
Page 21 GAO-05-946 Army Corps of Engineers

the last day of fiscal year 2003, based on the rationale that it was surplus to 

the project’s needs. However, just over 1 week later, in fiscal year 2004, 

$17,000 was restored to the project, according to the Corps, to pay labor 

costs. 

Reprogramming actions to restore funds to donor projects from projects 

that did not have a surplus also appears to be inconsistent with the Corps’ 

reprogramming guidance. Corps reprogramming guidance states that only 

funds surplus to current year requirements should be a source for 

reprogramming and that temporary borrowing or loaning is inconsistent 

with sound project management practices. Despite this guidance, in fiscal 

years 2003 and 2004, we found several instances where the Corps returned 

funds to a donor project from projects that had funding needs and did not 

have surplus funds. In some instances, separate reprogramming actions to 

transfer funds out of a project to repay a donor, and to transfer funds into 

that same project in order to complete work schedules, occurred on the 

same day or within a few days or weeks. For example, on May 1, 2003, the 

Corps reprogrammed $425,000 out of the Johnson Creek Upper Trinity 

River construction project in Texas to repay a donor project. On the same 

day, the Corps reprogrammed $1.5 million into the Johnson Creek project 

to provide funds for property acquisition necessary to keep the project on 

schedule. 

The Corps’ 

Reprogramming 

Activities Resulted in 

Inefficient 

Management of Funds 

As stated previously, Corps reprogramming guidance states that only funds 

surplus to current year requirements should be a source for reprogramming 

and that temporary borrowing or loaning is inconsistent with sound project 

management practices and increases the Corps’ administrative burden. In 

fiscal year 2003 and fiscal year 2004, the Corps managed its civil works 

project funds using a “just-in-time” reprogramming strategy. The basis for 

this strategy was to allow for the movement of funds from projects that do 

not have urgent funding needs to projects that need funds immediately. 

While the just-in-time approach may have moved funds rapidly, its 

implementation sometimes resulted in uncoordinated and unnecessary 

movements of funds from project to project. We found that funds were 

moved into projects that had a reported “need,” but were subsequently 

removed because they were “excess,” revoked from projects without 

regard to their near-term funding requirements, reprogrammed into and out 

of the same project on the same day, moved into and out of the same 

project multiple times a year, and reprogrammed without a system to 

evaluate the priority level of the affected projects. This strategy has 

resulted in numerous reprogrammings that may otherwise have been 
Page 22 GAO-05-946 Army Corps of Engineers

unnecessary if the Corps had employed a financial planning and 

management process in which funding priorities had been clearly 

established. In addition, the relative convenience and ease of 

reprogramming within Corps districts may have resulted in increased 

numbers of reprogrammings and reprogrammings from projects with 

funding needs.

In our review of projects from fiscal years 2003 and 2004, we found that 

funds were moved into projects, only to be subsequently revoked because 

they were excess to the project’s funding needs. For example, in fiscal year 

2004, 7 percent of the funds (totaling almost $154.6 million) from every 

nonearmarked construction project were revoked in order to provide 

funding to projects designated as “national requirements” by the Corps. 

The national requirements projects were a group of projects to which 

Corps headquarters management had promised to restore funding that had 

been revoked in previous years. These projects included the HoustonGalveston navigation channel construction project in Texas, New York and 

New Jersey Harbor, Comite River diversion channel in Louisiana, 

Guadalupe River channel improvement in California, Lackawanna River at 

Scranton levee project in Pennsylvania, three navigation projects in Alaska 

(Saint Paul Harbor, Nome Harbor, and Wrangell Harbor), and various 

projects under the Continuing Authorities Program.9

After the Corps moved the $154.6 million into the national requirements 

projects, the Corps revoked over a quarter of those funds, $38.8 million, 

from these projects because they actually did not need the funds. For 

example, one national requirements construction project, New York and 

New Jersey Harbor, received $24.9 million. All of these funds, plus an 

additional $10.3 million, were excess to the needs of the project at the time 

and were subsequently reprogrammed to other projects. Corps officials in 

the New York District told us that, prior to receiving the national 

requirements funds, they had informed Corps headquarters that they could 

not use the additional funds. Corps headquarters officials said that the 

district had requested the funds based on need. Other national 

requirements projects that received funds that were subsequently 

reprogrammed include:

9

The Continuing Authorities Program is a program that allows the Corps to conduct small 

water resource projects without specific congressional authorization. Included in this 

program are flood control, beach erosion, shoreline protection, and environmental 

improvement projects that range from $500,000 to $5 million.
Page 23 GAO-05-946 Army Corps of Engineers

• The Comite River construction project received almost $3 million. Later 

in fiscal year 2004, the Corps revoked nearly $1.5 million (about 50 

percent) of that funding. 

• The Lackawanna River at Scranton construction project received $15 

million. Later in fiscal year 2004, the Corps revoked $5 million (about 33 

percent) of that funding. 

• The Houston-Galveston construction project received nearly $28 

million. Later in fiscal year 2004, the Corps revoked about $7.25 million 

(about 26 percent) of that funding. 

The use of the just-in-time strategy also resulted in funds being removed 

from projects without considering their near-term funding requirements, 

such as projects with impending studies. For example, on August 1, 2003, 

the Corps revoked $85,000 from the Saw Mill River and Tributaries 

investigation project in New York with the explanation that the funds were 

excess to the project’s needs in the current year. Six weeks later, however, 

on September 15, 2003, $60,000 of funding was reprogrammed back into the 

project in order to initiate a feasibility study. Corps documents explaining 

the revocation of funds from the Saw Mill River and Tributaries project 

indicate the Corps' awareness of the project’s impending needs, 

acknowledging that funds for the project would be needed again in 

September 2003 to execute a feasibility study. 

We also determined that under the just-in-time reprogramming strategy, 

funds were moved into and out of the same project on the same day. 

Overall, we found that 3 percent of investigations and construction projects 

in fiscal year 2003 and 2 percent of investigations and construction projects 

in fiscal year 2004 moved funds into and out of the same project on the 

same day. Some specific examples include, on February 6, 2004, the Corps 

reprogrammed just over $2 million into the Mill Creek construction project 

in Ohio from the Olmsted ($1,500,000) and Pond Creek ($550,000) projects 

and reprogrammed out $272,000 the same day. The Corps explained that 

they initiated the $272,000 revocation in order to balance the books from 

previous reprogrammings. Also, in fiscal year 2003, the Corps used 18 

separate actions to reprogram approximately $25 million into and about 

$10.5 million out of the Central and Southern Florida construction project, 

including three separate occasions when funds were both moved into and 

out of the project on the same day. 
Page 24 GAO-05-946 Army Corps of Engineers

Furthermore, the Corps reprogrammed funds in and out of some projects 

numerous times during a single fiscal year. For instance, in 12 separate 

actions in fiscal year 2004, the Corps reprogrammed a total of $166,000 into 

the Dalles Lock and Dam operation and maintenance project in Washington 

and Oregon and revoked a total of $817,000. Many of these actions took 

place only days or weeks apart from one another. 

• March 9, 2004; $76,000 revoked; 

• March, 23, 2004; $261,000 revoked; 

• May 27, 2004; $31,000 revoked; 

• June 29, 2004; $200,000 revoked; 

• July 6, 2004; $38,000 revoked; 

• July 28, 2004; $40,000 reprogrammed;

• August 4, 2004; $18,000 reprogrammed; 

• August 12, 2004; $125,000 revoked; 

• August 24, 2004; $105,000 reprogrammed; 

• August 31, 2004; $3,000 reprogrammed; 

• September 17, 2004; $8,000 revoked; and 

• September 29, 2004; $78,000 revoked.

Similarly, in the San Antonio Channel Improvements construction project 

in Texas, the Corps reprogrammed slightly over $1.9 million into and 

$81,000 out of the project in 15 separate actions in fiscal year 2004. Forty 

percent of the actions took place in the final weeks of the fiscal year, with 

six separate transactions recorded between September 13 and September 

30. 

The just-in-time reprogramming strategy also moved money into and out of 

projects without regard to the relative priorities of the projects. During the 

period of our study, the Corps lacked a set of formal, Corps-wide priorities 

for use when deciding to reprogram funds from one project to another. 
Page 25 GAO-05-946 Army Corps of Engineers

Instead, according to the Chief of the Civil Works Programs Integration 

Division, during fiscal years 2003 and 2004, reprogramming decisions were 

left up to the intuition of program and project managers at the district level. 

While this decentralized system might have allowed for prioritized decision 

making at the district level, when reprogramming actions occurred across 

districts or across divisions, the Corps lacked any formal system of 

evaluation as to whether funds were moving into or out of high priority 

projects. The lack of a Corps-wide priority system limits its ability to 

effectively manage its appropriations, especially in an era of scarce funding 

resources when choices have to be made between competing needs of 

donor and recipient projects.

Finally, the Corps’ practice of allocating all funds to projects as soon as the 

funds are allotted to the Corps, coupled with the reprogramming flexibility 

provided to the districts, may result in an elevated number of 

reprogramming actions. Typically, once the Corps receives appropriated 

funds from the Congress, the Corps disperses all of these funds directly 

into project accounts at the district level. Allocating funding in this manner, 

according to Corps officials, is done to remain consistent with 

congressional direction. However, projects that have experienced delays in 

the time period between the Corps initial budget submittal and the agency’s 

receipt of its appropriation may receive more money than they are able to 

spend. In some cases we reviewed, the Corps dispersed an entire fiscal 

year’s worth of funding to a project even though they knew that the project 

manager could not spend all of the funding. This type of allotment system 

may result in an elevated number of reprogramming actions. For instance, 

within 2 weeks after the Corps dispersed its fiscal year 2003 appropriation 

to specific projects, it made 369 reprogramming actions to realign funding 

in its investigations and construction appropriations; within 2 weeks after 

dispensing fiscal year 2004 dollars, the Corps made 64 such actions. 

The flexibility provided to district managers once they receive their funding 

may also increase the number of reprogramming transactions. Corps 

reprogramming guidance allows the districts to reprogram funds up to a 

certain amount without notifying division or headquarters staff. According 

to some Corps program managers, the relative ease of conducting 

reprogramming actions at the district level, without the need to obtain 

division or headquarters approval, creates incentives for project managers 

to transfer funds among projects within the district even if it creates a 

greater number of reprogramming actions. For example, when project 

managers have an immediate need for funds, they may be more likely to 

reprogram funds between projects within their own district, even if the 
Page 26 GAO-05-946 Army Corps of Engineers

donor project has a need for funds in a few weeks or months, because the 

guidance allows them to do so. 

The Corps’ reprogramming practices place a large demand on the 

administrative resources of the agency. In fiscal year 2003, after receiving 

their appropriated funds from the Congress, the Corps conducted at least 

one reprogramming action every business day of the fiscal year except for 

4; after receiving their funds in fiscal year 2004, the Corps conducted at 

least one reprogramming action on every business day of the fiscal year 

except for 14. Each reprogramming action conducted requires the Corps to 

expend time and personnel resources to locate donor projects, file 

necessary paperwork, and in some cases obtain the approval of 

appropriate Corps staff and, possibly, the Congress. In particular, locating 

sources of donor funding is often a time-consuming process, as the project 

manager seeking funding must wait for other project managers to 

acknowledge excess funds and offer them for use on other projects. 

Conclusions The ability to move funds among projects is a useful and necessary 

management tool to adjust project funding to reflect changing conditions 

and needs over the life of a civil works project. For an agency like the 

Corps, which has responsibility for hundreds of projects, the ability to 

reprogram funds, if used effectively, provides the flexibility to take funds 

from a project that cannot spend allotted funds because of delays due to 

factors such as bad weather or labor problems and move those funds to a 

project that has a need for additional funding to accelerate or complete 

ongoing work. However, the Corps’ reprogramming guidance allows 

movements of funds by categorizing reprogrammings as fund movements 

that do not count toward notifying the Congress. As a result, following its 

guidance, the Corps is able to effect major deviations from the funding 

direction the Congress provided for projects in its conference report and 

does not have to inform the Congress of the changes and the reason for the 

changes. Because the Corps’ reprogramming reflects the direction and 

guidance provided by the appropriations committees and this guidance has 

changed over time, we believe that the Corps needs to reach agreement 

with the Congress on what types and levels of reprogramming actions are 

appropriate for the Corps to conduct without congressional notification. 

Reprogramming has become the Corps’ routine way of managing project 

funds, and the Corps has used reprogramming as a substitute for an 

effective and fiscally prudent financial planning, management, and prioritysetting system for its Civil Works program. The Corps allocates all funding 
Page 27 GAO-05-946 Army Corps of Engineers

to the projects, on an annual basis, at the beginning of the year and has no 

available means, other than reprogramming, to adjust project funding as 

circumstances change during the year. As a result, reprogramming has been 

used extensively for moving funds among projects in an environment 

where most projects have unmet funding needs and very few have excess 

funding. In addition, there is no formal system to prioritize potential donor 

or recipient projects and no financial planning occurs to monitor project 

schedules and progress. Instead, decisions are made instantly to meet 

immediate funding needs. Consequently, funds are frequently moved from 

projects that have or will have the need for those funds in the not too 

distant future and are shifted to other projects, some which have funding 

needs and some that do not. 

Recommendations for 

Executive Action

To eliminate the burden of excessive reprogramming actions and to 

provide better financial management of projects, we recommend that the 

Secretary of Defense direct the Commanding General and Chief of 

Engineers of the U.S. Army Corps of Engineers to take the following five 

actions:

• work with congressional committees to provide meaningful and 

consistent guidance for the investigations, construction, and operation 

and maintenance appropriations for what actions count as 

reprogrammings and what reporting thresholds should apply on a 

program and project basis;

• develop a financial planning and management system for the 

investigations, construction, and operation and maintenance 

appropriations that, at a minimum, 

• changes the way the Corps allocates funds from an annual basis to a 

more frequent basis that reflect actual schedule and project 

performance; 

• periodically reviews project schedules and performance and revises 

funding allocations as needed; and

• develops and implements criteria for setting reprogramming 

priorities; and

• provide direction and training to change the culture prevalent 

throughout the Corps that reprogramming is an acceptable, routine 
Page 28 GAO-05-946 Army Corps of Engineers

financial management practice and instead place greater emphasis on 

the use of financial planning approaches and priority-setting 

mechanisms for managing project funding.

Agency Comments and 

Our Evaluation

We provided a draft of this report to the Department of Defense for its 

review and comment. The Department stated that the report was very 

constructive and concurred with four of the five recommendations. 

Specifically, the Department concurred with the recommendation that the 

Corps work with congressional committees to provide meaningful and 

consistent guidance for the investigations, construction, and operation and 

maintenance appropriations as to which actions count as reprogrammings 

and what reporting thresholds should apply on a program and project 

basis. The Department said the Corps is preparing an Engineer Circular 

that will address the reprogramming direction provided in the House report 

accompanying the fiscal year 2005 appropriations for energy and water 

development. The Department also said that the Corps is coordinating with 

the appropriate House and Senate subcommittees and the Engineer 

Circular is scheduled to be issued in the first quarter of fiscal year 2006. 

The Department concurred with our recommendation that the Corps 

develop a financial planning and management system for the 

investigations, construction, and operation and maintenance 

appropriations that periodically reviews project schedules and 

performance and revises funding allocations as needed. The Department 

said that during the first quarter of fiscal year 2006, the Corps intends to 

institute improvements in project scheduling to provide more reliable 

estimates of funding capabilities and to emphasize periodic reviews of 

project schedules, performance, and funding allocations.

The Department concurred with our recommendation that the Corps 

develop a financial planning and management system for the 

investigations, construction, and operation and maintenance 

appropriations that develops and implements criteria for setting 

reprogramming priorities. The Department said that the Engineer Circular 

to be issued in the first quarter of fiscal year 2006 will include criteria to 

prioritize reprogramming actions. 

The Department concurred with our recommendation that the Corps 

provide direction and training to change the culture prevalent throughout 

the Corps that reprogramming is an acceptable, routine financial 

management practice and instead place greater emphasis on the use of 
Page 29 GAO-05-946 Army Corps of Engineers

financial planning approaches and priority-setting mechanisms for 

managing project funding. The Department said that the forthcoming 

Engineer Circular and subsequent training of project managers will 

strengthen limits on reprogramming and ensure understanding of those 

limits. 

Regarding our recommendation that the Corps develop a financial planning 

and management system for the investigations, construction, and operation 

and maintenance appropriations that changes the way the Corps allocates 

funds from an annual basis to a more frequent basis that reflects actual 

schedule and project performance, the Department did not concur. The 

Department said that it is important that the Corps continue to allocate all 

funds provided by the Congress for each project and that any deviation 

from that amount would be regarded as a reprogramming and would not 

reflect the intent of the Congress. The Department also said that 

withholding funds from the initial allocation would add administrative 

burden, increase uncertainty in execution, and would not aid in scheduling 

and schedule review.

We disagree with the Department’s views on the effects of changing the 

Corps allocation of funds from an annual basis to a more frequent basis 

during the fiscal year. While the conference report includes amounts for 

each project and that amount does reflect the intent of the Congress, 

changes often occur in the funding needs and project expenditure 

capabilities from the time the Corps submits its budget estimates until the 

appropriation is received 18 or more months later. As a result, when the 

appropriation is received, projects may not need the amount of funds 

included in the conference report or may need additional funds. Our 

recommendation would allow the Corps to make these known needed 

changes before allocating all funds to a project. This would serve to 

streamline the process and eliminate the administrative burden of making 

project funding allocations that the Corps knows it is going to reallocate 

through reprogramming actions almost immediately after the initial 

allocations are made. Providing periodic allocations of funds during the 

year, especially when coupled with reviews of project schedules, 

performance, and fund allocations and the development and 

implementation of criteria for setting reprogramming priorities –which the 

Department said the Corps will implement – should allow the Corps to 

better spend its limited funds in accordance with the intent of the 

Congress. Use of these tools will allow the Corps to allocate funds based on 

the most recent project information to those projects with the highest 

priority and the most immediate need. We also disagree that the use of 
Page 30 GAO-05-946 Army Corps of Engineers

periodic allotments would result in uncertainty in execution. Instead, 

periodic allocation of funds would provide increased certainty in execution 

of projects that needed funds and would not affect the execution of 

projects that did not have a current need for funds. 

In addition to the Department of Defense’s overall comments on our draft 

report (see app. IV for the full text of the Department’s comments), the 

Corps provided a number of technical comments and clarifications, which 

we incorporated in this report as appropriate.

As arranged with your offices, unless you publicly announce its contents 

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

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

interested congressional committees, the Commanding General and Chief 

of Engineers of the U.S. Army Corps of Engineers, and the Director of the 

Office of Management and Budget. We will make copies available to others 

on request. In addition, this report will be available at no charge on the 

GAO Web site at www.gao.gov.

If you or your staff have questions about this report, please call me at (202) 

512-3841 or contact me at mittala@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. Key contributors to this report are listed in appendix V.

Anu K. Mittal

Director, Natural Resources 

and Environment
Page 31 GAO-05-946 Army Corps of Engineers

Appendix I

Scope and Methodology ApApenednxidexiIs

To determine the extent to which the Corps reprogrammed appropriated 

funds among investigations, construction, and operation and maintenance 

projects in fiscal years 2003 and 2004, we obtained relevant funding and 

project data from the Corps. However, the Corps could not provide data 

about reprogramming of operation and maintenance project funds. We 

determined, based on written documentation, interviews with Corps 

officials, and electronic data testing, that the data were sufficiently reliable 

for our purposes. 

To determine if the Corps followed internal guidance and congressional 

direction when reprogramming funds and why the Corps conducted 

reprogramming funds, we obtained the Corps’ internal guidance for 

reprogramming and congressional reports and correspondence that 

contained direction for conducting reprogramming. We selected four Corps 

divisions randomly with probabilities proportional to the number of 

projects and judgmentally selected one district from each of those divisions 

for review. The divisions and districts selected were Great Lakes & Ohio 

River (Louisville District), North Atlantic (New York District), 

Northwestern (Portland District), and Southwestern (Fort Worth District). 

Within the four districts, we randomly selected a total of 271 projects from 

the population of investigations, construction, and operation and 

maintenance projects that had funds reprogrammed during fiscal years 

2003 and 2004. For the selected projects, we reviewed project files and held 

discussions with managers to obtain background information on the 

project and information on the amount, date, and reason for each 

reprogramming. File information was entered into a data collection 

instrument to ensure uniformity. This information was entered into a 

spreadsheet for analysis. The spreadsheet was independently verified with 

the data collection instruments. We compared the Corps’ reprogramming 

activities for each selected project to the internal guidance and 

congressional direction that was in effect at the time the reprogramming 

was conducted. 

To determine how effective the Corps’ reprogramming strategy was in 

managing appropriated funds, we reviewed the results of our sample 

analysis and discussed those results with program managers. We also 

discussed the Corps’ financial management strategy with program 

managers at Corps headquarters, division offices, and district offices and 

with individual project managers.
Page 32 GAO-05-946 Army Corps of Engineers

Appendix II

Reprogramming Guidance Used by the Corps ApendxiI

Thresholds did not exist

Sources: ER 11-2-201; Internal Corps Memorandum and House Report 108-554.

Construction

Operation and

Maintenance 

Appropriation

Investigations Up to $25,000 when 

the base is less than 

$25,000; when the 

base is greater than 

$25,000, 100 percent 

of the base up to 

$50,000 and 25 

percent of the 

increment over 

$50,000 to a max of 

$150,000

Up to $50,000 plus 

25 percent of the 

base for a single 

reprogramming 

action

Greater than 

$250,000 cumulative 

per project

Up to15 percent of the 

base; up to $300,000 

for projects with a base 

less than or equal to 

$2 million; up to $5 

million for settled 

contractor claims, 

accelerated contractor 

earnings, or real estate 

deficiency judgments

Up to $300,000 plus 

20 percent of the 

base for a single 

reprogramming action

Greater than $4 

million cumulative per 

project

Up to $300,000 plus 

20 percent of the 

base for a single 

reprogramming 

action

Greater than $4 

million cumulative per 

project

In effect from Aug. 31, 1995, 

to May 26, 2004

In effect from May 27 to Nov. 19, 

2004

Reprogrammings 

beyond these 

thresholds must be 

coordinated with the 

Appropriations 

committees.

Reprogrammings 

beyond these 

thresholds must be 

coordinated with the 

Appropriations 

committees.

Reprogrammings 

beyond this 

threshold require 

notification of the 

Appropriations 

committees.

Reprogrammings 

beyond this 

threshold require 

notification of the 

Appropriations 

committees.

Reprogrammings 

beyond this 

threshold require 

notification of the 

Appropriations 

committees.

Must receive 

approval from the 

Appropriations 

committees.

Must receive 

approval from the 

Appropriations 

committees.

Must receive 

approval from the 

Appropriations 

committees.

and

and

and

1995 Reprogramming

Guidance

2004 Reprogramming

Guidance
Page 33 GAO-05-946 Army Corps of Engineers

Appendix III

Projects with Reprogrammings That Did Not 

Follow Corps Guidance ApendxiI

Fund Movements 

Conducted under ER 

11-2-201 (October 1, 

2002, to May 26, 2004)

Green and Barren Rivers 

Navigation Disposition in 

Kentucky

The cumulative threshold amount for notifying the Congress was $25,000 

for this investigations project. On April 22, 2003, $25,000 was 

reprogrammed into the project. On April 28, 2003, another $25,000 was 

reprogrammed into the project, exceeding the cumulative threshold. The 

Corps did not notify the Congress of its intention to reprogram the funds in 

excess of the threshold. Corps officials explained that they made a mistake 

and did not initially realize that the threshold had been exceeded. When 

the error was realized, the Corps revoked $25,000 on May 29, 2003, to undo 

the previous error.

Fund Movements 

Conducted under 

Guidance Based on the 

Direction Provided in 

the House Report 108-

554 (May 27 to 

September 30, 2004)

New York City Watershed in 

New York

The single action threshold was $300,000 for this construction project. On 

September 20, 2004, the Corps revoked $800,000 exceeding the single 

action threshold of $300,000. The Corps notified the Congress of its 

intention to reprogram the $800,000, on September 24, 2004, 4 days after 

the funds had been moved.

McAlpine Locks and Dam in 

Kentucky and Indiana

The single action threshold for this construction project was $7,301,200 and 

the cumulative threshold was $4 million. (In this case, because of the size 

of the project, the threshold calculations resulted in a higher single action 
Appendix III

Projects with Reprogrammings That Did Not 

Follow Corps Guidance

Page 34 GAO-05-946 Army Corps of Engineers

threshold than a cumulative threshold.) On August 6, 2004, the Corps 

moved $5.3 million into the project using its accelerated contractor 

earnings authority. However, the accelerated contractor earnings authority 

only allows the Corps to move up to $5 million and it must be used for 

settling a contractor’s claim, increased contractor earnings due to 

accelerated rate of operations, or real estate deficiency judgment. In 

addition to exceeding their authority to move funds under this provision, 

Corps officials told us that the funds were not moved for any of the 

authorized purposes. Rather, the funds were used to continue funding a 

contract. The Corps had awarded a contract for about $80 million for fiscal 

year 2004, but received only about $27 million for the project. To avoid a 

work stoppage, possible contractor claims, and/or possible interest 

payments, the Corps moved a large amount of funds into the project, 

including the $5.3 million. 

Ramapo River at Oakland in 

New Jersey

The single action threshold for this construction project was $311,800 and 

the cumulative threshold was $4 million. On September 1, 2004, the Corps 

revoked $600,000; on September 20, 2004, the Corps revoked $1,700,000; 

and on September 29, 2004, the Corps revoked $600,000. All these actions 

exceeded the single action threshold. The Corps did not notify the 

Congress of their intention to reprogram the funds in excess of the 

thresholds on September 1 and 24. A letter was sent to the Congress for the 

September 20, 2004, action; however, the letter was sent on September 24, 

2004, after the funds had been moved. 

Ohio River Flood Protection 

in Indiana

The single action threshold for this construction project was $430,000 and 

the cumulative threshold was $4 million. On June 28, 2004, the Corps 

revoked $500,000, exceeding the single action threshold of $430,000. The 

Corps did not notify the Congress of its intention to reprogram the funds in 

excess of the threshold. Corps officials told us that the action was 

processed at the district and they were confused about the procedure. 

New York and New Jersey 

Harbor 

The single action threshold for this construction project was $22,303,000 

and the cumulative threshold was $4 million. (In this case, because of the 

size of the project, the threshold calculations result in a higher single action 

threshold than a cumulative threshold.) In 2004, in 10 different actions, the 

Corps moved a total of $82,559,000 in and out of the project. Specific 

actions that exceeded the $4 million threshold occurred on June 17, 2004, 
Appendix III

Projects with Reprogrammings That Did Not 

Follow Corps Guidance

Page 35 GAO-05-946 Army Corps of Engineers

($6,900,000 revoked), June 22, 2004, ($8,587,000 revoked), June 24, 2004, 

($10,000,000 revoked) and on August 6, 2004, ($8,500,000 revoked). The 

Corps sent notification to the Congress for the June 24, 2004, action on May 

13, 2004. Letters were also sent for the other actions; however, these letters 

were sent after the funds had been moved. The letter for the June 22, 2004, 

action was sent on June 29, 2004. The letters for the June 17, 2004, and the 

August 6, 2004, actions were sent on September 24, 2004. 

Bonneville Powerhouse 

Phase 1 in Oregon and 

Washington

The single action threshold for this construction project was $302,000 and 

the cumulative threshold was $4 million. On May 28, 2004, the Corps 

restored $332,000 prior year savings and slippage, exceeding the single 

action threshold of $302,000. The Corps did not notify Congress of their 

intention to reprogram the funds in excess of the threshold. Corps 

headquarters officials told us that the action was processed at the district 

and they were confused about the procedure while district officials said 

that headquarters approved the action. 

Plattsburgh Harbor in New 

York

The single action threshold for this operation and maintenance project was 

$438,240 and the cumulative threshold was $4 million. On August 16, 2004, 

the Corps revoked $625,000, exceeding the single action threshold of 

$438,240. The Corps did not notify the Congress of their intention to 

reprogram the funds in excess of the threshold. Corps officials told us that 

the action was processed at the district and they were confused about the 

procedure.
Page 36 GAO-05-946 Army Corps of Engineers

Appendix IV

Comments from the Department of Defense ApendxiIV
Appendix IV

Comments from the Department of Defense

Page 37 GAO-05-946 Army Corps of Engineers
Appendix IV

Comments from the Department of Defense

Page 38 GAO-05-946 Army Corps of Engineers
Page 39 GAO-05-946 Army Corps of Engineers

Appendix V

GAO Contact and Staff Acknowledgments ApendxiV

GAO Contact Anu K. Mittal (202) 512-3841

Staff 

Acknowledgments

In addition to the individual named above, Edward Zadjura, James D. 

Ashley, Kenneth E. Lightner Jr., John Mingus, Matthew Reinhart, Elizabeth 

Repko, Carol Herrnstadt Shulman, and Barbara R. Timmerman made 

contributions to this report.

(360533)
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