United States General Accounting Office

GAO Testimony

Before the Subcommittee on Risk Management and

Specialty Crops, Committee on Agriculture

House of Representatives

For Release on Delivery

Expected at

9:00 a.m., EDT

on Thursday

October 8, 1998

RESULTS ACT

Observations on CFTC’s

Annual Performance Plan

Statement of Richard J. Hillman, Associate Director

Financial Institutions and Markets Issues

General Government Division

GAO/T-GGD-99-10

Summary 

Results Act: Observations on CFTC’S Annual

Performance Plan

The House Subcommittee on Risk Management and Specialty Crops,

House Committee on Agriculture, asked GAO to assess the fiscal year 2000

annual performance plan of the Commodity Futures Trading Commission

(CFTC) for compliance with the Government Performance and Results Act

of 1993 (Results Act). Under the Results Act, executive agencies are

required to prepare annual performance plans to set out measurable goals

that define what will be accomplished during a fiscal year. The

performance plan is to reinforce the connection between the long-term

strategic goals outlined in the agency’s strategic plan and the daily

activities of program managers and staff.

On the basis of its review, GAO found that CFTC actions clearly show a

good faith effort to comply with the Results Act. However, as discussed

below, GAO identified several areas in which CFTC could improve its

performance plan.

• Performance goals, measures, and targets could provide a clearer picture

of intended performance.

• Mission, goals, and activities could be better connected to more fully

demonstrate how CFTC will chart annual progress toward achieving its

strategic goals.

• Crosscutting efforts could be addressed more fully if CFTC worked with

the affected federal agencies to develop performance goals and measures

that reflect the nature and extent of their common efforts.

• Strategies and resources used to achieve goals could be discussed in

greater detail to better enable congressional and other decisionmakers to

judge their reasonableness.

• The means for verifying and validating that performance information is

sufficiently complete, accurate, and consistent, as well as the extent to

which such information and the means for collecting, maintaining, and

analyzing it are reliable, should be discussed.

Although opportunities exist for CFTC to improve its performance plan,

the areas for improvement are some of the same areas in which we found

that many other federal agencies, including federal financial regulators,

could improve their plans. It is also important to recognize that the Results

Act anticipates that the process of developing an effective planning

process and plans could take several planning cycles.

Page 1 GAO/T-GGD-99-10
Statement 

Results Act: Observations on CFTC’S Annual

Performance Plan

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to assist the Subcommittee in its review of

the Commodity Futures Trading Commission’s (CFTC) fiscal year 2000

annual performance plan. Hearings like this one and the one you held last

year on CFTC’s 1997-2002 strategic plan continue to be an important

means of ensuring that the intent of the Government Performance and

Results Act of 1993 (Results Act) is met.

As you know, annual performance plans can be an invaluable tool for

making policy decisions, improving program management, enhancing

accountability, and communicating to both internal and external

audiences on how the long-term direction outlined in strategic plans is

translated into the day-to-day activities of managers and staff. Successful

implementation of a performance-based management system, as

envisioned by the Results Act, represents a significant challenge requiring

sustained agency attention.

My testimony today focuses on five areas in which CFTC could improve its

performance plan to make it a more useful tool for congressional and

executive branch decisionmakers. Although opportunities exist to improve

CFTC’s fiscal year 2000 performance plan, CFTC actions to date clearly

show a good faith effort to comply with the Results Act and the Office of

Management and Budget (OMB) guidance in developing its plan. In our

discussions with CFTC staff, we found CFTC fully committed to meeting

both the requirements of the Act and congressional expectations that the

plan inform Congress and the public about CFTC performance goals,

including how the agency will accomplish these goals and measure results.

In addition, the areas in which CFTC could improve its plan are some of

the same areas in which we found that many other federal agencies,

including federal financial regulators, could improve their plans.

Specifically, CFTC could improve its plan in the following five areas:

• Performance goals, measures,1 and targets could provide a clearer picture

of intended performance.

• Mission, goals, and activities could be better connected to more fully

demonstrate how CFTC will chart annual progress toward achieving its

long-term strategic goals.

1

CFTC’s plan uses the term “performance indicator” instead of “performance measure” to refer to the

measures used to assess progress toward achieving performance goals.

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Statement 

Results Act: Observations on CFTC’S

Annual Performance Plan

• Crosscutting efforts could be addressed more fully if CFTC worked with

the affected federal agencies to develop performance goals and measures

that reflect the nature and extent of their common efforts.

• Strategies and resources used to achieve goals could be discussed in

greater detail to better enable congressional and other decisionmakers to

judge their reasonableness.

• The means for verifying and validating that performance information is

sufficiently complete, accurate, and consistent, as well as the extent to

which such information and the means for collecting, maintaining, and

analyzing it are reliable, should be discussed.

My comments today apply to the fiscal year 2000 annual performance plan

that CFTC prepared for OMB in September 1998. Our assessment of

CFTC’s plan was based on knowledge of the agency’s operations and

programs; past reviews of CFTC, including a review of its 1997-2002

strategic plan; results of work on other agencies’ performance plans and

the Results Act; discussions with CFTC staff; and other information

available at the time of our assessment. The criteria we used to determine

whether CFTC’s plan complied with the requirements of the Results Act

were the Results Act itself; OMB guidance on preparing strategic and

performance plans (OMB Circular A-11, Part 2); and GAO guidance on

assessing agency performance plans.2

Background CFTC, an independent agency created by Congress in 1974, administers

the Commodity Exchange Act (CEA), as amended.3

 The principal purposes

of the CEA are to protect the public interest in the proper functioning of

the market’s price discovery and risk-shifting functions. In administering

the CEA, CFTC is responsible for fostering the economic utility of the

futures market by encouraging its efficiency, monitoring its integrity, and

protecting market participants from abusive trade practices and fraud.

The Results Act seeks to improve the management of federal programs, as

well as their effectiveness and efficiency, by establishing a system under

which agencies set goals for program performance and measure their

results. The Results Act is intended to shift the focus of government

decisionmaking and accountability away from a preoccupation with

activities—such as the number of market surveillance reports

2

See The Results Act: An Evaluator’s Guide to Assessing Agency Annual Performance Plans

(GAO/GGD-10.1.20, Apr. 1998).

3

7 U.S.C. §§ 1-25.

Page 3 GAO/T-GGD-99-10
Statement 

Results Act: Observations on CFTC’S

Annual Performance Plan

prepared—to a focus on the results of those activities, such as protecting

the economic functioning of the commodity futures and option markets.

Under the Results Act, strategic plans are the starting point for setting

goals and measuring progress towards them. The Results Act requires

virtually every executive agency to develop a strategic plan, covering a

period of at least 5 years forward from the fiscal year in which the plan is

submitted. In September 1997, CFTC formally submitted its fiscal years

1997-2002 strategic plan to Congress and OMB. This plan established three

strategic goals: (1) protect the economic functions of the commodity

futures and option markets; (2) protect market users and the public; and

(3) foster open, competitive, and financially sound markets.

The Results Act also requires a federal agency to prepare an annual

performance plan covering the program activities set out in its budget. In

establishing the requirement for a performance plan, the Results Act

establishes the first statutory link between an agency’s budget request and

its performance planning efforts. The performance plan is to reinforce the

connections between the long-term strategic goals outlined in the agency’s

strategic plan and the daily activities of program managers and staff.

Finally, the Results Act requires executive agencies to prepare annual

reports on program performance for the previous fiscal year. The

performance reports are to be issued by March 31 each year, with the first

(for fiscal year 1999) to be issued by March 31, 2000. In each report, the

agency is to compare its performance against its goals, summarize findings

of program evaluations completed during the year, and describe the

actions needed to address any unmet goals.

Performance Goals,

Measures, and Targets

Could Be Improved

The Results Act requires that annual performance plans establish

performance goals that (1) define the levels of performance to be

achieved; (2) express these goals in an objective, quantifiable, and

measurable form; (3) establish performance indicators to be used in

measuring or assessing progress toward achieving the goals; and

(4) provide a basis for comparing actual program results with the

established goals. CFTC’s performance plan makes great strides in

addressing these requirements. However, the performance plan could

provide a clearer picture of intended performance and be of greater use in

assessing progress toward achieving intended performance if performance

goals, measures, and targets were improved. Specifically, the plan could

be improved if (1) performance goals and measures were more

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Statement 

Results Act: Observations on CFTC’S

Annual Performance Plan

results-oriented, and goals were provided for all measures and internal

management challenges; (2) some performance goals were made

self-measuring4

 and others were made more objective; (3) certain

performance measures were replaced, restated, or deleted; and

(4) baselines were established against which annual targets could be

compared.

Goals and Measures Could

Be More Results-Oriented

and Complete

Results-oriented, or outcome, goals and measures provide the clearest

picture of intended and actual performance. However, most of CFTC’s

performance goals and measures focus on program outputs—such as the

number of meetings attended and number of research projects or reports

completed. In our testimony before this Subcommittee last year, we

highlighted a similar problem with CFTC’s strategic plan.5

 Although we

recognize that establishing outcome measures is particularly challenging

for regulatory agencies as they move from a focus on the activities they

undertake to the results they are trying to achieve, a key shortcoming of

CFTC’s performance plan is that it relies on output measures that describe

completed activities, not program results. Also, these measures are

weighted toward measuring the quantity of completed activities, rather

than the quality, cost, or timeliness of performance outcomes. As

mentioned earlier, the Results Act is intended to shift the focus of

government decisionmaking and accountability away from a

preoccupation with completed activities to a focus on the results of such

activities.

The focus of CFTC’s performance plan on output measures appears to

flow from its strategy of deriving performance goals from program

activities. For example, one performance goal is to aggressively identify,

investigate, and take action against individuals engaged in fraudulent

Internet and media activities. This goal is associated with the program

activity of monitoring the Internet and other media for fraudulent activities

and other possible violations of the CEA. The measure for the goal is the

number of referrals to enforcement authorities generated from Internet

and media monitoring—an output of the activity, not an outcome of a

program.

CFTC could refer to the narrative sections of its performance plan that

discuss CFTC’s fiscal year 1998 accomplishments to identify more

4

Self-measuring goals are expressed objectively and quantifiably and thus do not require the use of

additional measures.

5

Results Act: Observations on CFTC’s Strategic Plan (GAO/T-GGD-98-17, Oct. 22, 1997).

Page 5 GAO/T-GGD-99-10
Statement 

Results Act: Observations on CFTC’S

Annual Performance Plan

results-oriented performance goals. For example, the Enforcement

Program accomplishment section discusses the effectiveness of its

quick-strike ability—the ability to file injunctive actions quickly after

detecting fraud—to, among other things, obtain timely injunctive relief and

enhance the possibility that customer funds will be recovered. This

accomplishment section describes cases, filed within days or weeks of

CFTC’s discovering an illegal activity, that stopped fraud at an early stage

and preserved customer funds. CFTC’s performance measures could be

made more results-oriented by replacing measures, such as reports on

activities related to bringing injunctive actions and sanctioning violators,

with more outcome-related measures, such as the percentage of

quick-strike cases filed within a certain number of days of starting an

investigation that resulted in sanctions and the percentage of funds

recovered.

CFTC could also learn from the plans of other federal financial regulators

that are attempting the transition to results-oriented goals. For example,

the National Credit Union Administration is developing new outcome

performance goals. One outcome goal of the National Credit Union

Administration is to ensure that federally insured credit unions are

adequately capitalized. A performance goal is to reduce the percentage of

federally insured credit unions that are undercapitalized by 10 percent,

from 372 to 335.

CFTC’s plan could also be improved if performance goals were provided

for all activities and performance targets as well as for internal

management challenges. Currently, the plan has 16 activities for which no

performance goals exist. For example, no performance goal exists for the

activity of reviewing and overseeing self-regulatory organization audit and

financial practices. Without a performance goal, it is not clear what

performance is expected. Also, CFTC’s strategic plan identifies several

internal management challenges that the performance plan does not

address. These challenges include diminishing resources, recruiting and

retaining qualified professionals, remaining abreast of current technology,

and remaining educated and informed as innovation changes the industry.

To better respond to the intent of the Results Act, CFTC could add

agencywide performance goals to the plan to address these challenges or

incorporate these challenges in existing performance goals and measures.

Page 6 GAO/T-GGD-99-10
Statement 

Results Act: Observations on CFTC’S

Annual Performance Plan

Some Goals Could Be

Made Self-Measuring, and

Others Could Be Made

More Objective

Although not required by the Results Act, CFTC could redefine some

performance goals so that they are self-measuring, thereby reducing the

complexity of the plan. Currently, all but 2 of CFTC’s 31 performance

goals are stated as abstract goals—that is, as goals requiring that specific

performance measures be defined to assess progress toward their

achievement.

Performance goals that can be redefined so that they are self-measuring

generally have one measure or two or more measures that can be

combined. For example, the performance goal for the activity of reviewing

the adequacy of self-regulatory organization disciplinary actions might be

restated in the following way: On an annual basis, review a certain

percentage of self-regulatory organization disciplinary actions to ensure

compliance with CFTC standards. This approach, which has been taken by

other federal financial regulators, such as the National Credit Union

Administration and Federal Deposit Insurance Corporation, clearly defines

performance expectations. For example, the Federal Deposit Insurance

Corporation has the following performance goal: Market 80 percent of a

failing financial institution’s assets based on book value at the time of

resolution or within 90 days.

CFTC’s performance plan could also be improved by reducing the extent

to which performance goals require interpretation. To the extent possible,

goals should not require subjective considerations to dominate

measurement. For example, one performance goal is defined as follows:

Bring important cases (including matters involving ongoing conduct and

complex transactions) aggressively. The performance goal does not define

what an important case is or what it means to aggressively bring a case.

Certain Performance

Measures Could Be

Replaced, Restated, or

Deleted

CFTC’s performance plan has 31 performance goals with 228 performance

measures to address them. CFTC could replace, restate, or delete

performance measures for certain performance goals to strike a better

balance between too few and too many measures and to enhance its

ability to assess the progress made in achieving performance goals.

First, CFTC could replace certain performance measures to better capture

key aspects of the performance they are trying to assess. For example, one

of the plan’s performance goals is to review every designation application

and rule change request within 10 to 45 days. This goal’s performance

measures are the number of designation applications processed and the

number of contract market rule changes processed. Because neither

Page 7 GAO/T-GGD-99-10
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Results Act: Observations on CFTC’S

Annual Performance Plan

measure captures the amount of time it takes to process applications or

changes, they could be replaced with one measure that captures the

percentage of applications and changes processed in 45 days or less.

Second, CFTC could restate or delete certain performance measures,

because they do not appear to be clearly related to their performance

goals and/or appear to be unduly affected by external factors. For

example, the number of active futures and option markets is used to

measure, in part, two goals: (1) identify traders who can influence futures

prices and (2) determine whether traders are influencing futures prices.

The number of active futures markets is determined by futures exchanges

and other external factors and has little direct bearing on the two goals. As

a result, the measure could be deleted.

Third, CFTC could restate or delete certain performance measures,

because they may have limitations that preclude them from accurately

capturing intended performance and may promote unintended

consequences. For example, one of the plan’s performance goals is to

conduct important investigations and refer potential violations to other

authorities as appropriate. The performance measures for this goal include

the number of documents obtained through subpoena or inspection,

number of witnesses from whom testimony was taken, and number of

witnesses interviewed. These output-oriented measures could provide an

incentive for staff to conduct more interviews, take more testimonies, and

obtain more documents than necessary, which could add cost and time to

investigations without necessarily contributing commensurately to their

success.

Baselines Could Be

Established Against Which

to Compare Annual Targets

Although CFTC’s performance plan includes annual targets for

performance goals, it could make such information more useful by

providing baselines, or a context, for assessing the reasonableness and

appropriateness of such targets. As we recently reported, agencies that go

beyond the requirements of the Results Act and include baseline or trend

data for their goals provide a more informative basis for assessing

expected performance.

CFTC’s performance plan provides many quantitative annual targets for

each fiscal year from 1998 through 2000. Many are set at the same

performance level as or at a lower performance level than in prior fiscal

years without an explanation. For example, the performance measures for

assessing sanctions under CFTC’s first strategic goal are the same in each

Page 8 GAO/T-GGD-99-10
Statement 

Results Act: Observations on CFTC’S

Annual Performance Plan

year covered by the plan for the number of cease and desist orders,

registration sanctions, and trading prohibitions. However, the basis for

setting the specific targets and the contributions of these targets to the

outcome objective are not readily apparent.6

 Without this contextual

information, the reader does not know if CFTC’s output-oriented

performance targets are reasonable.

Mission, Goals, and

Activities Could Be

Better Connected

Consistent with the Results Act, CFTC’s performance plan attempts to

show the relationship between the agency’s annual performance goals and

its fiscal years 1997 through 2002 mission and strategic goals. To do so, the

plan uses tables that connect each strategic goal to its accompanying set

of performance goals, measures, and annual targets. The plan also ranks

the agency’s outcome objectives by dollars budgeted, which is a starting

point for providing useful information about its priorities. However, the

plan could better connect mission, goals, and activities by more fully

demonstrating how CFTC will chart annual progress toward achieving its

long-term strategic goals.

As we found with other agency performance plans, CFTC’s plan associates

one performance goal with multiple program activities and strategic goals.

Such associations make it difficult to determine whether all activities are

substantially covered or to understand how specific program activities are

intended to contribute to CFTC’s strategic goals. For example, the

performance goal—assess sanctions that are remedial and deter

violators—is associated with three different program activities and three

different strategic goals. Moreover, the measures and targets for this

performance goal differ with each program activity and strategic goal.

Similarly, the performance plan’s presentation of many separate program

areas, program activities, and performance goals, measures, and targets

makes it difficult to link CFTC’s mission and strategic goals to

performance goals across the entire agency. The plan’s 31 performance

goals and 228 performance measures support 3 strategic goals and 9

strategic objectives, covering 5 program areas. Although the plan’s ranking

of outcome objectives offers a useful perspective on CFTC’s priorities,

given the high level of complexity, it is difficult to (1) identify the agency’s

key priorities among the many goals and measures, (2) differentiate efforts

to meet these priorities, and (3) understand what will be achieved if all the

performance goals are met.

6

The outcome objective is to foster futures and option markets that accurately reflect the forces of

supply and demand for the underlying commodity and are free of disruptive activity.

Page 9 GAO/T-GGD-99-10
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Results Act: Observations on CFTC’S

Annual Performance Plan

Crosscutting Efforts

Could Be More Fully

Addressed

The Results Act seeks to ensure that crosscutting goals of federal

programs are consistent; strategies are mutually reinforcing; and, as

appropriate, progress is assessed through the use of common performance

measures. OMB guidance tasks performance plans with identifying those

performance goals that are being mutually undertaken with other federal

agencies in support of programs or activities of a crosscutting nature.7

CFTC’s plan recognizes the need to address crosscutting efforts. However,

it could more fully address such efforts if the agency worked with the

cognizant federal agencies to develop performance goals and measures

that better reflect the nature and extent of their common efforts.

CFTC’s performance plan could be expanded to include performance

goals and measures to more adequately address crosscutting efforts, such

as those identified in its budget justification that accompanied its

performance plan to OMB. These include CFTC’s participating in the

President’s Working Group on Financial Markets;8

 sharing information

with other financial regulators; working with the U.S. Department of

Agriculture on a risk management education program; contributing to a

Department of the Treasury initiative that encourages global financial

stability; as well as cooperative enforcement efforts with the Department

of Justice, the Federal Bureau of Investigation, the Federal Reserve Board,

the Federal Trade Commission, the Securities and Exchange Commission,

and the U.S. Postal Inspection Service.

CFTC’s performance plan briefly discusses CFTC’s need to work with

other U.S. financial regulators through, among other means, the

President’s Working Group on Financial Markets. However, the related

performance goals and measures do not directly address the type of

crosscutting performance that the Working Group was created to address.

For example, CFTC’s performance goal covering the Working Group is for

CFTC to contribute to the performance of the group. The measure for this

goal is the number of meetings attended, and the fiscal year 2000 target is

two meetings.

7

OMB Circular A-11 guidance states that, at a minimum, the performance plan should indicate those

programs or activities that are being undertaken with other agencies to achieve a common purpose or

objective. An agency should also review the performance plans of other agencies participating with it

in a crosscutting program or activity to ensure that goals and indicators are consistent and

harmonious.

8

The President’s Working Group on Financial Markets was created following the October 1987 stock

market crash to address issues concerning the competitiveness, integrity, and efficiency of the

financial markets. The Secretary of the Treasury chairs the group, and other members include the

chairs of CFTC, the Federal Reserve System, and the Securities and Exchange Commission.

Page 10 GAO/T-GGD-99-10
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Results Act: Observations on CFTC’S

Annual Performance Plan

As supported by OMB guidance, CFTC could strengthen its performance

plan by participating with the members of the Working Group and other

federal regulators involved in crosscutting programs to develop common

performance goals and measures. For example, the continued growth and

development of the over-the-counter (off-exchange) derivatives market

has raised a number of potential regulatory concerns that affect CFTC and

other members of the Working Group. In addition, the potential need to

develop a financial markets contingency plan to address the “Year 2000”

computer dating problem9

 could involve coordination among CFTC and

other federal financial regulators.

Strategies and

Resources Used to

Achieve Goals Could

Be Discussed in

Greater Detail

CFTC’s plan provides important information on how strategies and

resources will be used to achieve goals. However, expanding this

discussion could better enable congressional and other decisionmakers to

judge the reasonableness of CFTC’s strategies and anticipated resource

deployment.

Consistent with the Results Act and OMB guidance, CFTC’s performance

plan attempts to address the strategies that CFTC will use to achieve its

performance goals. Although this discussion should cover operational

processes, skills, and technologies, CFTC’s discussion focuses on the

agency’s operational processes and, to a much lesser extent, on skills and

technologies. Aligning its discussion with CFTC’s strategic goals, the plan

briefly describes the major activities of each program in relation to its

performance goals and measures. In a few cases, the plan also discusses

skills or technologies that programs will use in relation to performance

goals and measures. The plan could be made more useful by providing

additional information on the skills and, if appropriate, technologies used

in connection with operational processes to achieve program goals.

Also, consistent with the Results Act, CFTC’s performance plan discusses

the resources that will be applied to achieve the agency’s performance

goals. Using tables and graphics, the plan shows the amount of budget

funding and the number of full-time equivalent employees that will be

needed to achieve each strategic goal and the individual outcome

objectives covering each strategic goal. CFTC’s plan could be further

improved by describing the resources required to achieve each

performance goal.

9

The Year 2000 computer dating problem relates to the need for computer systems to be changed to

accommodate dates beyond the year 1999.

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Results Act: Observations on CFTC’S

Annual Performance Plan

The Means for

Verifying and

Validating

Performance

Information Should

Be Described

Although required by the Results Act and OMB guidance, CFTC’s fiscal

year 2000 performance plan does not describe the procedures that the

agency will use to verify10 and validate11 that performance information is

sufficiently complete, accurate, and consistent. Nor does the plan discuss

the extent to which the performance information and the means for

collecting, maintaining, and analyzing it are reliable. CFTC’s performance

plan should be expanded to address these requirements.

In addition, to assess progress toward achieving its goals, CFTC will need

to collect information on the over 200 performance measures in its plan.

For some of these measures, the amount of information to be collected is

voluminous and covers activities across CFTC headquarters and regional

offices. Errors can occur in collecting, maintaining, processing, and

reporting such information—potentially introducing bias and resulting in

inaccurate estimates of program performance. As a result, CFTC should

have procedures for ensuring that its performance information is free of

significant levels of error and that bias is not introduced. Such procedures

can include internal controls over data collection, maintenance, and entry,

as well as audits, evaluations, and peer reviews.

In summary, Mr. Chairman, it is important to recognize that although

CFTC’s performance planning can be further improved, the Results Act

anticipated that the process of developing an effective planning process

and plans could take several planning cycles. We look forward to

continuing to work with Congress and CFTC to ensure that the

requirements of the Results Act are met.

Mr. Chairman, this concludes my prepared statement. My colleagues and I

would be pleased to answer any questions that you or Members of the

Subcommittee may have.

(233588)

10Verify means to check or test performance data to reduce the risk of using data that contains

significant errors.

11Validate means to test the data to ensure that errors do not create significant bias.

Page 12 GAO/T-GGD-99-10
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