MANAGING FOR 

RESULTS

Agencies Should More 

Fully Develop Priority 

Goals under the GPRA 

Modernization Act

Report to Congressional Committees

April 2013

GAO-13-174

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-174, a report to 

congressional committees

April 2013

MANAGING FOR RESULTS

Agencies Should More Fully Develop Priority Goals 

under the GPRA Modernization Act

Why GAO Did This Study

GAO’s work has repeatedly shown that 

federal agencies must coordinate 

better to achieve common outcomes. 

The act established a more 

crosscutting and integrated approach 

to achieving results and improving 

performance, including a requirement 

that agencies identified by OMB 

establish APGs. The act directs GAO 

to review its implementation at several 

junctures; this report is part of a series 

doing so. This report (1) examines the 

extent to which 24 agencies identified 

by OMB implemented selected 

requirements related to 102 APGs, and 

(2) comments on the 21 APGs of five 

selected agencies, based on prior 

GAO and IG work, including the status 

of relevant open recommendations. To 

address these objectives, GAO 

reviewed the act’s requirements for 

APGs, OMB guidance, APG 

information from Performance.gov and 

related agency documents; and 

interviewed OMB officials. GAO 

selected DHS, HUD, DOT, VA, and 

OPM for their variety of APG program 

types and linkage to CAP goals. For 

each agency, GAO reviewed its past 

work, as well as that of IGs, related to 

the APGs and updated the status of 

open recommendations.

What GAO Recommends

GAO makes recommendations to OMB 

to improve APG implementation by

revising its guidance to better reflect 

interim target, milestone, and CAP goal 

alignment requirements; and ensure 

that agencies provide complete 

information about external contributors 

to their APGs and describe 

congressional input on APG 

development. OMB staff agreed with 

these recommendations.

What GAO Found

For 102 agency priority goals (APGs) for 2012 to 2013 that GAO reviewed, 

agencies implemented three GPRA Modernization Act of 2010 (the act) 

requirements. Agencies identified (1) a target level of performance within a 2-

year time frame; (2) how their APGs contribute to their strategic goals; and (3) an 

agency official responsible for achieving each APG. These represent important 

accomplishments, but information about other requirements is incomplete: 

Agencies did not fully explain the relationship between APGs and crosscutting 

efforts. The act directs agencies to identify federal organizations, programs, and 

activities that contribute to each APG. Agencies identified internal contributors to 

their APGs, but did not identify external contributors for 34 of 102 APGs. In some 

cases the APGs appeared to be internally focused; however, in others GAO’s 

work has shown there are external contributors, but none were listed. In addition, 

the act requires agencies to identify how, if at all, an APG contributes to any 

cross-agency priority (CAP) goals set by the Office of Management and Budget 

(OMB). Although 29 of 102 APGs appeared to support a CAP goal, only two

described the link. When agencies do not identify external contributors or links to 

crosscutting efforts, it is unclear whether agencies are coordinating to limit 

overlap and duplication. 

Most APGs had performance measures, but many lacked interim targets. The act 

requires agencies to develop quarterly targets for APGs if they provide data of 

significant value at a reasonable level of burden. However, OMB’s guidance does 

not fully address this. Without interim targets when appropriate, agencies cannot

demonstrate that they are comparing actual results against planned performance 

on a sufficiently frequent basis to address performance issues as they arise.

Agencies did not identify milestones with completion dates for many APGs. The 

act requires agencies to develop and publish milestones—scheduled events for 

completing planned actions—for their APGs. However, OMB’s guidance does not 

direct agencies to provide specific completion dates for their milestones. For 39

of 102 APGs, agencies did not provide milestones with clear completion dates for

the next quarter or the remainder of the goal period. Without milestones, 

agencies are unable to demonstrate that they have properly planned for the 

actions needed to accomplish their goals and are tracking progress. 

Most agencies did not describe how APGs reflect congressional input. The act

directs agencies to describe for each APG how input from consultations with 

Congress was incorporated. However, only one agency provided a description. 

Without transparency regarding congressional input, there is less assurance that 

meaningful consultations with Congress are occurring. 

GAO commented on all 21 of the APGs from the Departments of Homeland 

Security (DHS), Housing and Urban Development (HUD), Transportation (DOT), 

and Veterans Affairs (VA), and the Office of Personnel Management (OPM), 

based on past GAO and inspectors general (IG) work. The most frequent theme 

in the comments is that agencies continue to face the long-standing challenge of

measuring performance and collecting accurate performance data. 

View GAO-13-174. For more information, 

contact J. Christopher Mihm at (202) 512-6806 

or mihmj@gao.gov.
Page i GAO-13-174 Agency Priority Goals

Letter 1 

Background 4

Agencies Have Made Progress Implementing Key Requirements for 

Priority Goals, but Some Information Is Incomplete 6

Past Audit Work Provides Perspective on Selected Agencies’ 

Capacities to Achieve Their Priority Goals 35

Conclusions 36

Recommendations for Executive Action 39

Agency Comments and Our Evaluation 39

Appendix I Objectives, Scope & Methodology 41

Appendix II Comments on the Department of Homeland Security’s Priority 

Goals 43

Appendix III Comments on the Department of Housing and Urban 

Development’s Priority Goals 54

Appendix IV Comments on the Department of Transportation’s Priority 

Goals 75

Appendix V Comments on the Department of Veterans Affairs’ Priority 

Goals 90

Appendix VI Comments on the Office of Personnel Management’s Priority 

Goals 101

Appendix VII Comments from the Department of Veterans Affairs 115

Contents 
Page ii GAO-13-174 Agency Priority Goals

Appendix VIII GAO Contact and Staff Acknowledgments 119

Table

Table 1: Number of APG Performance Measures by Frequency of 

Measurement 24

Figures

Figure 1: Example of OPM APG from Performance.gov 7

Figure 2: Example of SSA APG from SSA’s Fiscal Year 2013 

Performance Plan 8

Figure 3: List of Goals that Support SSA’s Strategic Goals, from 

SSA’s Fiscal Years 2013 to 2016 Strategic Plan 9

Figure 4: NSF APG Description in NSF’s Fiscal Year 2013 Budget 

Request to Congress Identifies Internal Contributors 12

Figure 5: DOT APG Description in the DOT Fiscal Year 2013 

Performance Plan Identifies Various Internal Contributors 14

Figure 6: DOT APG Description on Performance.gov Identifies 

Various Internal Contributors 15

Figure 7: State/USAID APG Description in the State Fiscal Year 

2013 Congressional Budget Justification Identifies 

External Contributors 17

Figure 8: State/USAID APG Description on Performance.gov 

Identifies External Contributors 18

Figure 9: List of Activities, Including Tax Expenditures, in HUD’s 

Fiscal Year 2013 Performance Plan that Support a HUD 

APG 20

Figure 10: HHS APG Description on Performance.gov Identifies a 

Performance Measure, Interim Performance Targets, and 

Reported Progress toward those Interim Targets 25

Figure 11: VA’s Presentation of Milestone Information in the March 

2013 Quarterly Performance Update on Performance.gov 28

Figure 12: Excerpt of SBA’s Presentation of Planned Actions in the 

March 2013 Quarterly Performance Update on 

Performance.gov 30

Figure 13: SBA’s Description of Congressional Consultation on 

APGs 33
Page iii GAO-13-174 Agency Priority Goals

Abbreviations

3R incentives recruitment, relocation, and retention incentives

APG agency priority goal

CAP goal cross-agency priority goal

CAST Commercial Aviation Safety Team

CFO Chief Financial Officer

DHS Department of Homeland Security

DOD Department of Defense

DOE Department of Energy

DOT Department of Transportation

DRGR Disaster Recovery Grant Reporting

EDS explosives detection systems

EPA Environmental Protection Agency

ERAM En Route Automation Modernization system

FAA Federal Aviation Administration

FEMA Federal Emergency Management Agency

FHA Federal Housing Administration

FRA Federal Railroad Administration

GAJSC General Aviation Joint Steering Committee

GEAR Goals-Engagement-Accountability-Results

GPRA Government Performance and Results Act of 1993

GPRAMA GPRA Modernization Act of 2010

HHS Department of Health and Human Services

HSIPR High Speed Intercity Passenger Rail

HUD Department of Housing and Urban Development

HUD-VASH Department of Housing and Urban Development 

and Veterans Affairs Supportive Housing

IG Inspector General

Interagency Council U.S. Interagency Council on Homelessness

MTW Moving to Work

NextGen Next Generation Air Transportation System
Page iv GAO-13-174 Agency Priority Goals

NHTSA National Highway Traffic Safety Administration

NIC Neighborhood Investment Clusters

NOFA Notice of Funding Availability

NSF National Science Foundation

NSP Neighborhood Stabilization Program

OMB Office of Management and Budget

OPM Office of Personnel Management

PAC Performance Accountability Council

PIC Performance Improvement Council

Recovery Act American Recovery and Reinvestment Act of 2009

SBA Small Business Administration

SES Senior Executive Service

SMS safety management systems

SPOT Screening of Passengers by Observation

Techniques 

SPR State Preparedness Reports

SSA Social Security Administration

State Department of State

THIRA threat, hazard, identification and risk assessment

TRCC traffic records coordinating committee

Treasury Department of the Treasury

TRF The Reinvestment Fund

TSA Transportation Security Administration

USACE U.S. Army Corps of Engineers

USAID U.S. Agency for International Development

USDA U.S. Department of Agriculture

VA Department of Veterans Affairs

VBA Veterans Benefits Administration

VBMS Veterans Benefit Management System

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Page 1 GAO-13-174 Agency Priority Goals

United States Government Accountability Office

Washington, DC 20548

April 19, 2013

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Mark R. Warner

Chairman

Task Force on Government Performance

Committee on the Budget

United States Senate

The Honorable Elijah Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

Many of the meaningful results that the federal government seeks to 

achieve, such as those related to protecting food and agriculture, 

providing homeland security, and ensuring a well-trained and educated 

workforce, require the coordinated efforts of more than one federal 

agency and often more than one sector and level of government. Both 

Congress and the executive branch have recognized the need for 

improved collaboration across the federal government. Accordingly, in 

January 2011 the almost two-decades-old Government Performance and 

Results Act of 1993 (GPRA)1 was updated with the GPRA Modernization 

Act of 2010 (GPRAMA or the act).2

 

1

Pub. L. No. 103-62, 107 Stat. 285 (Aug. 3,1993).

The act establishes a new framework 

aimed at taking a more crosscutting and integrated approach to focusing 

on results and improving government performance. Effective 

implementation of the act could play an important role in clarifying desired 

outcomes, addressing program performance that spans multiple 

organizations, and facilitating future actions to reduce unnecessary 

duplication, overlap, and fragmentation. Furthermore, under GPRAMA, 

2

Pub. L. No. 111-352, 124 Stat. 3866 (Jan. 4, 2011).

 
 

Page 2 GAO-13-174 Agency Priority Goals

agencies are to more frequently review and report the results they are 

achieving, which could lead to improved performance if agencies take 

more timely actions to address performance challenges as they arise.

Among other things, GPRAMA requires certain agencies, as determined 

by the Office of Management and Budget (OMB), to develop a limited 

number of agency priority goals (APGs) every 2 years.3 These goals are

to reflect the highest priorities of each selected agency, as identified by 

the head of the agency, and be informed by broad crosscutting federal 

government priority goals (also known as cross-agency priority or CAP 

goals) as well as input from relevant congressional committees. In 

implementing these goals under the act, agencies are to identify the 

various federal organizations, programs and activities—both within and 

external to the agency—that contribute to each goal, and review progress 

on a quarterly basis. In February 2012, concurrent with the submission of 

the President’s Budget, OMB published the 103 APGs developed by 24 

agencies on a single, government-wide performance website—

Performance.gov.4

 

3

31 U.S.C. § 1120(b). This provision applies to the 24 agencies identified in the Chief 

Financial Officers (CFO) Act of 1990, as amended (31 U.S.C. § 901(b)), unless OMB 

determines otherwise. The 24 CFO Act agencies, generally the largest federal agencies, 

are the Departments of Agriculture, Commerce, Defense, Education, Energy, Health and 

Human Services, Homeland Security, Housing and Urban Development, the Interior, 

Justice, Labor, State, Transportation, the Treasury, and Veterans Affairs, as well as the 

Agency for International Development, Environmental Protection Agency, General 

Services Administration, National Aeronautics and Space Administration, National Science 

Foundation, Nuclear Regulatory Commission, Office of Personnel Management, Small 

Business Administration, and Social Security Administration.

In December 2012, OMB and agencies provided 

additional information about the APGs as part of the site’s first update. 

Going forward, the site is to be updated at least each quarter.

4

The 24 agencies that developed 2012 to 2013 APGs varied slightly from the CFO Act 

agencies. OMB did not require the Nuclear Regulatory Commission to develop these 

goals; instead, it directed the U.S. Army Corps of Engineers Civil Works program 

(USACE-Civil Works) to develop priority goals. According to OMB staff, this decision was 

consistent with these agencies’ involvement in past governmentwide performance 

management activities. OMB has previously exempted the Nuclear Regulatory 

Commission from and included USACE-Civil Works in the activities associated with the 

President’s Management Agenda under the George W. Bush Administration and the 

development of 2010 to 2011 high priority performance goals under the Obama 

Administration.
 

Page 3 GAO-13-174 Agency Priority Goals

This report is part of our response to a mandate to assess initial 

implementation of GPRAMA.5 Our specific objectives for this report were 

to (1) examine the extent to which agencies implemented selected 

planning and reporting requirements and leading practices related to 

APGs; and (2) comment on the APGs of several selected agencies based 

on our prior work and the work of relevant agency inspectors general 

(IGs) and identify related open recommendations and matters for 

congressional consideration. To address both objectives, we reviewed 

information about the APGs published on Performance.gov in February 

2012 and updated in December 2012,6 as well as the updated strategic 

plans and performance plans agencies published in 2012 to reflect 

GPRAMA requirements. To assess the reliability of data presented on 

Performance.gov we reviewed relevant documentation and interviewed 

OMB staff about data quality control procedures. We determined that the 

data were sufficiently reliable for the purposes of this report. In addition, 

to accomplish our first objective, we reviewed and assessed agencies’ 

implementation of selected GPRAMA planning and reporting 

requirements for 102 of the 103 APGs.7

 

5

Pub. L. No. 111-352, § 15(b)(1).Other reports issued pursuant to this mandate include 

GAO, Managing for Results: Data-Driven Performance Reviews Show Promise But 

Agencies Should Explore How to Involve Other Relevant Agencies, 

In addition to the requirements, 

our assessment was also informed by the Senate committee report 

accompanying GPRAMA, relevant OMB guidance, and our past work on 

how to effectively implement GPRA. For our second objective, we 

selected five of the 24 agencies that developed APGs—the Departments 

of Homeland Security (DHS), Housing and Urban Development (HUD), 

Transportation (DOT), and Veterans Affairs (VA), and the Office of 

Personnel Management (OPM)—based on several factors, including the 

number and variety of types of federal programs involved in achieving the 

goals, such as direct service, grant, and regulatory programs, and 

whether the APGs were related to any of the CAP goals. We then 

GAO-13-228

(Washington, D.C.: Feb. 27, 2013), and Managing for Results: GAO’s Work Related to the 

Interim Crosscutting Priority Goals under the GPRA Modernization Act, GAO-12-620R

(Washington, D.C.: May 31, 2012).

6

However, for the figures throughout this report that reflect illustrative examples from 

Performance.gov, we used the most recent information, as of March 2013. 

7

The Department of Defense has published limited information about its APG to improve 

cybersecurity due to the sensitive nature of the goal. According to Performance.gov, 

progress updates for this goal will be internal to the government. Because we used 

publicly available information, we excluded this goal from our implementation assessment.
 

Page 4 GAO-13-174 Agency Priority Goals

reviewed the work that we and relevant IGs have conducted over a 

number of years related to each of the 21 APGs developed by the five 

agencies. Because the 21 APGs are a non-generalizable sample of all 

APGs, our views on those APGs cannot be generalized to the entire 

universe, but provide insights about each of the 21 APGs, as well as a 

theme common to several APGs. We also updated the status of related 

key open recommendations and matters for congressional consideration. 

Appendix I provides additional information about our objectives, scope, 

and methodology.

We conducted this performance audit from July 2012 to April 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

GPRAMA specifies that APGs are to have

• ambitious targets that can be achieved within a 2-year period;

• a clearly identified agency official, known as a goal leader, who is 

responsible for achieving the goal;

• clearly defined quarterly milestones; and

• interim quarterly targets for performance measures, if more frequent 

updates of actual performance provide data of significant value.8

Other GPRAMA requirements provide additional information and context 

for the priority goals. For example, agencies are to describe how their 

APGs contribute to the agency’s long-term strategic goals,9 as well as 

any of the CAP goals developed by OMB, as applicable.10

 

8

31 U.S.C. § 1120(b).

This 

information can help illustrate how an agency’s efforts to achieve its 

priority goals fit within a broader, crosscutting context—both within the 

agency and across the federal government. In addition, agencies are to 

9

5 U.S.C. § 306(a)(6); 31 U.S.C. § 1115(b)(3)(A).

1031 U.S.C. § 1115(b)(3)(B).

Background 
 

Page 5 GAO-13-174 Agency Priority Goals

describe how they incorporated any input on their priority goals received 

during consultations with relevant congressional committees.11

GPRAMA also lays out a schedule for gradual implementation of its 

provisions, with a 3-year period of interim implementation following 

enactment in January 2011. It required agencies to identify their APGs 

and related information in their strategic plans and performance plans, 

published concurrently with the President’s Budget in February 2012. 

Agencies also were to provide information about their APGs for OMB to 

publish on Performance.gov by October 1, 2012, and agencies are to 

update this information on at least a quarterly basis.12 OMB provided 

guidance to agencies on implementing the act’s provisions, including 

those related to APGs, in several memorandums and its annual Circular 

No. A-11 in both 2011 and 2012.13

In addition to OMB’s guidance, the Performance Improvement Council 

(PIC) shared practices related to developing and implementing APGs with 

agencies in 2011 and 2012.14

 

1131 U.S.C. § 1122(b)(1).

The PIC established the Goal Setting 

Working Group in May 2011 to assist agencies in setting their 2012 to 

2013 APGs. The group produced a draft guide to goal setting, which 

included criteria for selecting priority goals as well as elements and 

examples of effective goal statements. In September 2012, the PIC also 

produced a draft best practices guide for developing milestones; the 

guide described the characteristics of milestones and provided several 

examples.

12We have ongoing work reviewing Performance.gov and plan to issue a report on the 

results in the spring of 2013. 

13Memorandums providing guidance on implementing APG requirements are OMB, 

Delivering on the Accountable Government Initiative and Implementing the GPRA 

Modernization Act, M-11-31 (Washington, D.C.: Apr. 14, 2011), and Delivering an 

Efficient, Effective, and Accountable Government, M-11-31 (Washington, D.C.: Aug. 17, 

2011).

14The PIC is an interagency council chaired by OMB’s Deputy Director for Management 

and composed of the performance improvement officers (PIOs) of the 24 CFO Act 

agencies, as well as other PIOs and individuals as designated by the Chairperson. Initially 

established by executive order in 2007, it was codified in law by GPRAMA in 2011. 31 

U.S.C. § 1124(b). For our work reviewing federal performance management leadership 

roles, including PIOs and the PIC, see GAO, Managing for Results: Agencies Have 

Elevated Performance Management Leadership Roles, but Additional Training Is Needed, 

GAO-13-356 (Washington: D.C: Apr. 16, 2013). 
 

Page 6 GAO-13-174 Agency Priority Goals

For each APG, agencies were required, by GPRAMA or OMB guidance, 

to make available to OMB for publication on Performance.gov and in their 

strategic plans or performance plans (1) a performance goal with a target 

level of performance to be achieved in a 2-year time frame; (2) an 

explanation of how the goal contributes to agency strategic goals; and (3) 

the identification of an agency official as the goal leader responsible for 

achieving the goal. Agencies provided information about each of these 

requirements for all of the 102 APGs on Performance.gov included in our 

assessment—which represents an important accomplishment in the 

development of priority goals.

Figure 1 illustrates how information on Performance.gov for one of OPM’s 

priority goals meets the three requirements. The full goal statement for 

the APG provides a targeted level of performance to achieve 

(“participation of at least 2 multi-state health plans in State Affordable 

Insurance Exchanges”) within a 2-year timeframe (“by October 1, 2013”). 

The layout of information on Performance.gov shows that this APG 

supports OPM’s strategic goal to “Improve Access to Health Insurance,” 

as part of its strategic objective to “contract with multi-state health plans 

to be offered on affordable insurance exchanges.” Finally, information on 

the site identifies OPM’s Director of Healthcare and Insurance as the goal 

leader for this APG.

Agencies Have Made 

Progress 

Implementing Key 

Requirements for 

Priority Goals, but 

Some Information Is 

Incomplete 

Agencies Have 

Implemented Several 

Requirements Related to 

Priority Goals
 

Page 7 GAO-13-174 Agency Priority Goals

Figure 1: Example of OPM APG from Performance.gov

As an additional example, the Social Security Administration (SSA) 

included information about each of its APGs in an appendix of its fiscal 
 

Page 8 GAO-13-174 Agency Priority Goals

year 2013 performance plan. As shown in figure 2, for SSA’s priority goal 

to ensure faster hearing decisions, the plan provides the targeted level of 

performance (“reduce the average time...to 270 days”) and the timeframe 

(“by the end of fiscal year 2013”) in the “Priority Goals” column. In the 

same column, SSA indicated that the goal is linked to performance 

measure 1.1c, which supports the agency’s strategic goal “Deliver Quality 

Disability Decisions and Services.” In the “Goal Leaders(s)” column, SSA 

identifies the Executive Coordinator for Backlog Initiatives in the Office of 

Disability Adjudication and Review.

Figure 2: Example of SSA APG from SSA’s Fiscal Year 2013 Performance Plan

SSA’s strategic plan for fiscal years 2013 to 2016 also identifies its APGs 

and how each supports an agency strategic goal. Figure 3 provides a 

table from the strategic plan that presents a list of goals that support each 

of its strategic goals and denotes those that are APGs with an asterisk.
 

Page 9 GAO-13-174 Agency Priority Goals

Figure 3: List of Goals that Support SSA’s Strategic Goals, from SSA’s Fiscal Years

2013 to 2016 Strategic Plan

Our past work has shown that although the federal government faces a 

series of challenges that in many instances are not possible for any single 

agency to address alone, agencies often face a range of challenges and 

barriers when they attempt to work collaboratively.15 Our annual reports 

on duplication, overlap, and fragmentation highlight a number of areas 

where a more crosscutting approach is needed—both across agencies 

and within a specific agency.16

 

15GAO, Managing for Results: GPRA Modernization Act Implementation Provides 

Important Opportunities to Address Government Challenges, 

We found that duplication and overlap 

GAO-11-617T (Washington, 

D.C.: May 10, 2011). 

16GAO, 2013 Annual Report: Actions Needed to Reduce Fragmentation, Overlap and 

Duplication, and Achieve Other Financial Benefits, GAO-13-279SP (Washington, D.C.: 

April 9, 2013); 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington, 

D.C.: Feb. 28, 2012); and Opportunities to Reduce Potential Duplication in Government 

Programs, Save Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: 

Mar. 1, 2011).

Agencies Did Not Fully 

Explain the Relationship 

between Their Priority 

Goals and Crosscutting 

Efforts 
 

Page 10 GAO-13-174 Agency Priority Goals

occur because programs have been added incrementally over time to 

respond to new needs and challenges, without a strategy to minimize 

duplication, overlap, and fragmentation among them. Also, there are not 

always interagency mechanisms or strategies in place to coordinate 

programs that address crosscutting issues, which can lead to potentially 

duplicative, overlapping, and fragmented efforts. GPRAMA establishes a 

new framework for taking a crosscutting and integrated approach to 

improving government performance, and effective implementation of that 

framework could play an important role in clarifying desired outcomes, 

addressing performance that spans multiple organizations, and facilitating 

actions to reduce unnecessary overlap, duplication, and fragmentation.

Two provisions in GPRAMA, in particular, direct agencies to link their 

APGs with crosscutting federal efforts. First, the act requires agencies to 

identify federal organizations, program activities, regulations, policies, and 

other activities—both internal and external to the agency—that contribute 

to each of their APGs and include this information in their performance 

plans and provide it to OMB for publication on Performance.gov.17 In 

addition, OMB’s 2012 guidance directs agencies to include tax 

expenditures in their identification of organizations and programs that 

contribute to their APGs,18 as part of their updates to Performance.gov.19

Since 1994, we have recommended greater scrutiny of tax expenditures, 

as periodic reviews could help determine how well specific tax 

expenditures work to achieve their goals and how their benefits and costs 

compare to those of programs with similar goals.20 Second, APGs are to 

be informed by the CAP goals.21

 

1731 U.S.C. §§ 1115(b)(5)(C) and 1122(b)(3)(C).

The act also requires agencies to 

18Tax expenditures are reductions in a taxpayer’s tax liability that result from special 

exemptions and exclusions from taxation, deductions, credits, deferrals of tax liability, or 

preferential tax rates. 

19See Section 210, “Performance.gov and Public Reporting” of OMB Circular No. A-11, 

Preparation, Submission, and Execution of the Budget, Circular No. A-11 (Aug. 3, 2012).

20See, most recently, GAO, Tax Expenditures: Background and Evaluation Criteria and 

Questions, GAO-13-167SP (Washington, D.C.: Nov. 29, 2012). 

21In February 2012, OMB established 14 interim CAP goals. They cover exports; 

entrepreneurship and small business; broadband; energy efficiency; veteran career 

readiness; science, technology, engineering, and math (STEM) education; job training; 

cybersecurity; sustainability; real property; improper payments; data center consolidation; 

closing skills gaps; and strategic sourcing. See GAO-12-620R for a description of how our 

work relates to these goals. 
 

Page 11 GAO-13-174 Agency Priority Goals

demonstrate in their performance plans any alignment between their 

performance goals—including their APGs—and the CAP goals.22 Both of 

these provisions are important because they show how agencies are 

coordinating efforts toward a common crosscutting issue. As we have 

previously reported, uncoordinated program efforts can waste scarce 

funds, confuse and frustrate program customers, and limit the overall 

effectiveness of the federal effort.23

Agencies identified at least one internal contributor for each of their 

APGs, though agencies differed in the amount of detail they provided. For 

example, the National Science Foundation (NSF), as shown in figure 4, 

identified its Directorate of Engineering as a lead organization and its 

Innovation Corps activities and programs as contributing programs to its 

APG to increase the number of entrepreneurs emerging from university 

laboratories.

 

2231 U.S.C. § 1115(b)(3)(B). 

23GAO-13-279SP. 

Agencies Identified Internal 

Contributors for Each Priority 

Goal, but Did Not List External 

Contributors in Some Cases
 

Page 12 GAO-13-174 Agency Priority Goals

Figure 4: NSF APG Description in NSF’s Fiscal Year 2013 Budget Request to Congress Identifies Internal Contributors 
 

Page 13 GAO-13-174 Agency Priority Goals

DOT, in its fiscal year 2013 performance plan, organized the descriptions 

of its planned performance—including its APGs—into broad themes 

under its strategic goals. As shown in figure 5, DOT identified the 

operating administrations, activities, enabling legislation, regulations, and 

other resources that contribute to each theme.
 

Page 14 GAO-13-174 Agency Priority Goals

Figure 5: DOT APG Description in the DOT Fiscal Year 2013 Performance Plan Identifies Various Internal Contributors
 

Page 15 GAO-13-174 Agency Priority Goals

Similarly, DOT identified on Performance.gov a range of contributing 

programs to its APG to reduce the risk of aviation accidents (see figure 

6).

Figure 6: DOT APG Description on Performance.gov Identifies Various Internal Contributors
 

Page 16 GAO-13-174 Agency Priority Goals

Agencies identified external contributors for 73 of the 102 APGs. When 

they did identify external contributors, agencies differed in the amount of 

detail they provided. The Department of State (State), for instance, 

identified in its fiscal year 2013 congressional budget justification external 

contributors for six of the eight APGs it jointly developed with the U.S. 

Agency for International Development (USAID). These external 

contributors are generally at the department/agency, component, or 

program level, such as the Department of Defense (DOD), the 

Department of Justice’s Office of Overseas Prosecutorial Development 

Assistance and Training, and the Department of Justice’s International 

Criminal Investigative Training Assistance Program, respectively (see 

figure 7).
 

Page 17 GAO-13-174 Agency Priority Goals

Figure 7: State/USAID APG Description in the State Fiscal Year 2013 Congressional Budget Justification Identifies External 

Contributors

Similarly, State and USAID identified on Performance.gov external 

contributors to their APG to advance low emissions, climate-resilient 

development, such as the Department of Agriculture (USDA), the Forest 

Service (a USDA component), the Environmental Protection Agency, and 

international governmental and nongovernmental organizations (see 

figure 8).
 

Page 18 GAO-13-174 Agency Priority Goals

Figure 8: State/USAID APG Description on Performance.gov Identifies External Contributors

Note: EC-LEDS is Enhancing Capacity for Low Emission Development Strategies.

We did not verify that agencies included all relevant internal and external 

federal contributors to their APGs. However, it was not always clear why 

external contributors were not identified for 29 of the 102 APGs. In some 
 

Page 19 GAO-13-174 Agency Priority Goals

instances this could be explained by the goal being internally focused. For 

example, the Department of the Interior listed no external contributors to 

its internally-focused APG to “build the next generation of conservation 

and community leaders by supporting youth employment” at the 

department. However, our analysis indicates that 8 of the 29 APGs that 

lack external contributors are related to crosscutting areas that we have 

identified as at risk of potential fragmentation, overlap, or duplication.24

For example, NSF did not list any external contributors to its APG to 

develop a diverse and highly qualified science and technology workforce 

by having 80 percent of institutions funded through NSF’s undergraduate 

programs document the extent of use of proven instructional practices by 

September 30, 2013. Our past work has identified 209 programs across 

13 federal agencies that are focused on science, technology, engineering, 

and mathematics education, some which may have efforts related to 

those NSF is undertaking for this goal.25

In addition, our in-depth examination of a sample of 21 APGs indentified 

several APGs related to our work on fragmentation, overlap, and 

duplication, including one where not all relevant contributors were 

identified. As we have previously reported, HUD, USDA, and the 

Department of the Treasury (Treasury) operate rental housing programs 

with overlapping purposes, although the products, areas served, and 

delivery methods differed, and recommended that further collaboration be 

undertaken and documented in strategic plans and performance plans by 

these agencies.26

 

24

HUD and USDA generally agreed with the 

recommendations; Treasury did not provide comments. As illustrated in 

figure 9, HUD identified two tax expenditures (Treasury) as contributors to 

its APG targeted at preserving affordable rental housing—the only APG 

out of all 102 to have tax expenditures identified as external contributors. 

However, HUD did not identify USDA or its rental housing programs.

GAO-13-279SP, GAO-12-342SP and GAO-11-318SP. Our analysis also identified 26

additional APGs related to crosscutting areas, identified in our past work as at risk of 

potential fragmentation, overlap, or duplication, where agencies identified one or more 

external contributors.

25GAO, Science, Technology, Engineering, and Mathematics Education: Strategic 

Planning Needed to Better Manage Overlapping Programs across Multiple Agencies, 

GAO-12-108 (Washington, D.C.: Jan. 20, 2012). 

26GAO, Housing Assistance: Opportunities Exist to Increase Collaboration and Consider 

Consolidation, GAO-12-554 (Washington D.C.: Aug. 16, 2012). 
 

Page 20 GAO-13-174 Agency Priority Goals

Figure 9: List of Activities, Including Tax Expenditures, in HUD’s Fiscal Year 2013 Performance Plan that Support a HUD APG

Although agencies are required, and OMB guidance directs agencies, to 

identify relevant internal and external contributors to their APGs, OMB’s 

review process does not systematically check whether agencies have 

identified all relevant contributors. According to OMB staff, they take a 

risk-based approach, using a tool called the Agency Data Completion 

Report, to ensure that agencies have provided complete information 

about their APGs for updates to Performance.gov. For each APG, the 

report shows whether the agency has provided certain categories of 

information, including contributors the agency identified for the goal. 

However, the report only indicates if an agency has identified contributors 

and how many. It does not indicate if these contributors were internal or 

external to the agency, nor does it ensure that all relevant contributors 

were identified. In addition, while staff from OMB resource management 

offices and the PIC conduct more in-depth reviews of the content for 

agencies’ APG updates, these reviews lack a systematic approach to 

identify comprehensively all relevant federal agencies, programs, and 

activities.
 

Page 21 GAO-13-174 Agency Priority Goals

The Department of Commerce (Commerce) and State both have exportrelated APGs, and noted on Performance.gov that their APGs contribute 

to the broader CAP goal to double U.S. exports by the end of 2014. 

However, our analysis indicates that 27 additional APGs appear to 

support at least one of the 14 interim CAP goals, but agencies did not 

describe this connection. In part, this could be a result of OMB’s 

guidance, which does not state the requirement for agencies to show the 

alignment between their performance goals—including their APGs—and 

the CAP goals. Instead the guidance directs agencies to refer to 

Performance.gov, where the quarterly updates for the CAP goals will 

describe how the agency’s goals contribute to the CAP goal. While in a 

few instances CAP goals identified contributing APGs, this alignment was 

not also provided in the corresponding APG information on the site. For 

example, in the quarterly update published in December 2012, the export 

CAP goal identified the export-related APGs of Commerce and State—as 

well as that of USDA—as supporting the CAP goal’s strategies. Unlike 

Commerce and State, USDA did not describe how its export-related APG 

supports the broader export CAP goal. According to OMB staff, as the 

information presented on Performance.gov and its functionality is 

expanded and enhanced, they expect to cross-reference related pieces of 

information, which they stated would include the connections between 

APGs and any related CAP goals.

We have reported that communicating the relationship between individual 

agency goals and outcomes that cut across federal agencies provides an 

opportunity to clearly relate and address the contributions of alternative 

federal strategies.27

Without OMB guidance directing agencies to describe how their 

performance goals—including APGs—support any relevant CAP goals, 

agencies may not understand the importance of examining how their 

efforts contribute to broader federal outcomes and planning for those 

contributions. Similarly, although we did not analyze whether agencies 

included all relevant internal and external contributors for their APGs, our 

In addition, as mentioned above, it is important for 

agencies to identify areas in which they should be coordinating efforts to 

meet crosscutting goals, and we have reported that strategic plans and 

performance plans can be tools for doing so.

 

27GAO, Results-Oriented Government: GPRA Has Established a Solid Foundation for 

Achieving Greater Results, GAO-04-38 (Washington, D.C.: Mar. 10, 2004). 

Most Agencies Did Not State 

Whether Their Priority Goals 

Support Any CAP Goals
 

Page 22 GAO-13-174 Agency Priority Goals

work on potential areas of fragmentation, overlap, and duplication helped 

identify several examples where agencies did not list relevant external 

contributors. In addition, OMB’s review process does not systematically 

check whether agencies have identified all relevant contributors. This 

raises questions as to whether larger issues exist with the completeness 

of agencies’ listings of APG contributors. More importantly, without 

complete information related to both of these requirements, it is unclear 

whether agencies have properly planned to coordinate their efforts. As we 

noted earlier, uncoordinated program efforts can waste scarce funds, 

confuse and frustrate program customers, and limit the overall 

effectiveness of the federal effort.

As noted earlier, agencies are to define a target level of performance to 

be achieved within a 2-year timeframe for each APG. GPRAMA requires 

agencies to establish a set of performance measures (called performance 

indicators in the act), which are used to assess progress toward each 

goal, at least annually.28 The act also requires agencies to review and 

report on progress toward their APGs on at least a quarterly basis. One 

way agencies can gauge progress this frequently is through the 

development of interim quarterly performance targets—that is, targets for 

each quarter that falls within the 2-year period.29

The Senate committee report that accompanied the bill that ultimately 

was enacted states that the quarterly performance review requirement for 

APGs is intended to increase the use of performance information to 

improve performance and results.

The act requires these 

interim targets for performance measures when more frequent updates of 

actual performance would provide data of significant value to the federal 

government, Congress, or program partners at a reasonable level of 

administrative burden.

30

 

2831 U.S.C. § 1115(b)(6). This requirement applies to all agency performance goals, of 

which APGs are a subset. 

Our past work has shown that 

although agencies collect a significant amount of performance 

information, they have not consistently used that information to improve 

2931 U.S.C. § 1120(b)(1)(D). 

30Committee on Homeland Security and Governmental Affairs, GPRA Modernization Act 

of 2010, S. Rep. No. 111-372, at 11 (2010).

Agencies Generally 

Identified Performance 

Measures for Their Priority 

Goals, but Many Measures

Did Not Have Related

Targets for Measuring 

Interim Progress
 

Page 23 GAO-13-174 Agency Priority Goals

management and results.31 We have previously identified practices for 

enhancing agency use of performance information, one of which is to 

communicate performance information, including performance against 

targets, frequently and effectively.32 Frequent, regular communication can 

help managers to inform staff and other stakeholders of their commitment 

to achieve the agency’s goals and to keep these goals in mind as they 

pursue their day-to-day activities. Frequently reporting progress toward 

achieving performance targets also allows managers to review the 

information in time to make improvements.33

In the December 2012 update to Performance.gov, agencies identified 

241 performance measures for gauging progress toward 91 of the 102 

APGs. For the 11 APGs without performance measures, the agencies 

stated that the goals are more appropriately measured by milestones. 

Although OMB’s guidance strongly encourages agencies to use 

quantitative measures, it allows agencies the flexibility to develop 

qualitative goal statements that are supported by milestones to assess 

progress. All 24 agencies have at least one APG with an accompanying 

performance measure.

Without related targets, 

agencies may be unable to demonstrate to key stakeholders, including 

Congress, program partners, and the public, that they are tracking 

progress frequently enough to address any performance issues related to 

their APGs as they arise.

The frequency with which agencies collect performance information for 

the measures varies, as illustrated in table 1. Agencies collect and report 

results on a majority of the measures (166 out of 241, or 69 percent) on at 

least a quarterly basis. Measuring and reporting results this frequently 

represents substantial progress in agencies’ ability to use performance 

information in a timelier manner to pinpoint and act on improvement 

opportunities. Previously, GPRA required agencies to report their 

performance on an annual basis.

 

31GAO, Government Performance: Lessons Learned for the Next Administration on Using 

Performance Information to Improve Results, GAO-08-1026T (Washington, D.C.: Jul. 24, 

2008).

32GAO, Managing for Results: Enhancing the use of Performance Information for 

Management Decision Making, GAO-05-927 (Washington, D.C.: Sep. 9, 2005). 

33GAO-13-228. 
 

Page 24 GAO-13-174 Agency Priority Goals

Table 1: Number of APG Performance Measures by Frequency of Measurement

Frequency of measure Number of performance measures

Monthly 13

Quarterly 153

Semi-annually 8 

Annually 67

Source: GAO analysis of data from Performance.gov.

Figure 10 illustrates one of the two measures the Department of Health 

and Human Services (HHS) identified for its APG to increase the number 

of health centers certified as Patient Centered Medical Homes. The 

measure is the percent of health centers with at least one site recognized 

as a Patient Centered Medical Home. HHS provided interim performance 

targets for each quarter of the goal period, beginning with an interim 

target of 4 percent in the first quarter of fiscal year 2012, with subsequent 

targets increasing toward the final target of 25 percent by the fourth 

quarter of fiscal year 2013. In addition, HHS reported its progress toward 

those interim targets on a quarterly basis.
 

Page 25 GAO-13-174 Agency Priority Goals

Figure 10: HHS APG Description on Performance.gov Identifies a Performance Measure, Interim Performance Targets, and 

Reported Progress toward those Interim Targets

Note: PCMH is Patient Centered Medical Home.
 

Page 26 GAO-13-174 Agency Priority Goals

In other cases, agencies did not provide interim targets to show the level 

of performance expected for each underlying measure. For a majority of 

their measures (136 or 56 percent), agencies provided interim targets that 

align with their measures (e.g. quarterly targets for quarterly measures for 

each quarter during the 2-year period of the goal). For example, similar to 

the HHS example above, for 90 measures agencies provided quarterly 

targets to be achieved through the end of the goal period (fourth quarter 

of fiscal year 2013) for each measure. But for 77 measures (32 percent), 

agencies provided interim targets that align with their measures for only a 

portion of the 2-year timeframe. Finally, for 28 measures (12 percent), 

agencies did not provide interim targets that align with their measures for 

any portion of the 2-year timeframe.

As previously stated, GPRAMA requires agencies to develop interim

quarterly performance targets for their measures if more frequent updates 

of actual performance would provide data of significant value to the 

federal government, Congress, or program partners at a reasonable level 

of administrative burden. While OMB’s 2012 A-11 guidance provides a 

definition of “reasonable administrative burden,” it does not define what 

constitutes “data of significant value.” Therefore it may be unclear to 

agencies when it would be appropriate to develop these targets. 

Furthermore, the guidance does not mention the interim quarterly 

performance target requirement. OMB staff told us that they expect 

agencies to provide such targets, and that they have communicated this 

expectation to agencies. OMB staff shared with us the user guide they 

developed for agencies to input data for publication on Performance.gov. 

According to the guide, indicators should include a target for each 

reporting period.

The act requires each APG to have clearly defined quarterly milestones—

scheduled events signifying the completion of a major deliverable or a set 

of related deliverables or a phase of work.34

 

3431 U.S.C. §§ 1120(b)(1)(E) and 1115(h)(6).

Similar to performance 

measures, OMB’s guidance states that milestones will follow fiscal year 

quarters and notes that agencies may choose monthly milestones if 

preferred. In addition, a draft guide developed by the PIC describes 

characteristics of a good milestone, such as articulating concrete actions 

to be taken and being time-bound.

Agencies Did Not Provide 

Milestones with Scheduled 

Completion Dates for 

Many Priority Goals
 

Page 27 GAO-13-174 Agency Priority Goals

Milestones can help agencies demonstrate that they have clear and fully 

developed strategies and are tracking progress to accomplish their goals. 

Such strategies, as identified in our past work, should (1) identify specific 

actions agencies are taking or plan to take to carry out their missions, (2) 

outline planned accomplishments, and (3) provide a schedule for their 

completion.

35 Milestones can help show the connection between 

agencies’ day-to-day activities and their goals. In addition, by describing 

the strategies to be used to achieve results, including clearly defined 

milestones, and the resources to be applied to those strategies, agencies 

can provide information that would help key stakeholders, including 

Congress, better understand the relationship between resources and 

results.36

For 63 of the 102 APGs, agencies identified on Performance.gov clearlydefined milestones for both the near term (presented as “Next Steps,” 

with a scheduled completion date in the next fiscal quarter) and longer 

term (presented as “Future Actions,” covering the remainder of the goal 

period). Figure 11 provides an illustrative example of an APG with both 

near-term and longer-term milestones. For its goal to improve awareness 

of VA services and benefits by increasing the timeliness and relevance of 

online information available to veterans, service members, and eligible 

beneficiaries, VA provided milestones scheduled for completion in the 

second quarter of fiscal year 2013 (near term) and the fourth quarter of 

fiscal year 2013 (the end of the goal period).

Without clearly defined milestones, agencies may have difficulty 

demonstrating that they have properly planned the actions needed, and 

are tracking progress, to accomplish their APGs.

 

35GAO, Agencies’ Annual Performance Plans Under the Results Act: An Assessment 

Guide to Facilitate Congressional Decisionmaking, GAO/GGD/AIMD-10.1.18 

(Washington, D.C.: February 1998). 

36S. Rep. No. 111-372, at 6 (2010). 
 

Page 28 GAO-13-174 Agency Priority Goals

Figure 11: VA’s Presentation of Milestone Information in the March 2013 Quarterly Performance Update on Performance.gov
 

Page 29 GAO-13-174 Agency Priority Goals

Agencies did not always identify the quarterly milestones they planned to 

accomplish in order to achieve their APGs during the 2-year goal period. 

Furthermore, the presentation of information about milestones on 

Performance.gov does not always convey the time frames for expected 

action. For the remaining 39 goals, agencies did not provide specific 

completion dates in discussions of near-term or longer-term plans (or in 

some cases both) for accomplishing the goal. As figure 12 illustrates, the 

Small Business Administration (SBA) provided planned actions it intends 

to take in the near term and longer term to help accomplish its APG to 

process disaster applications efficiently. However, it is unclear when SBA 

intends to complete these actions.
 

Page 30 GAO-13-174 Agency Priority Goals

Figure 12: Excerpt of SBA’s Presentation of Planned Actions in the March 2013 Quarterly Performance Update on 

Performance.gov

Note: ODA is the Office of Disaster Assistance.
 

Page 31 GAO-13-174 Agency Priority Goals

OMB’s 2012 A-11 guidance does not adequately reflect that clearlydefined milestones should have scheduled completion dates and be 

publicly reported.37 The guidance states that APGs must have quarterly 

milestones to track progress, and it outlines the time frames that nearterm and longer-term milestones should cover. However, the guidance 

does not state that agencies should provide specific completion dates for 

their milestones. In addition, contrary to GPRAMA, the guidance also 

states that agencies’ presentations of near-term milestones in the 

quarterly updates on Performance.gov are optional. When we asked 

OMB staff about this, they agreed that the designation of near-term 

milestones as optional for the quarterly updates was an error in A-11 

guidance; it should have been required. They told us they intend to 

correct this error in the 2013 A-11 guidance. OMB staff further stated that 

OMB has communicated to agencies that near-term milestones are to be 

included in quarterly updates to Performance.gov in other ways. For 

example, the Performance.gov user guide states that “agencies will 

summarize how they plan to improve progress...and will include key 

milestones planned” for the near term, as part of the “Next Steps” portion 

of the APG information. Without clear and consistent guidance about 

developing and publishing milestones with clear completion dates, 

agencies may continue to omit key information about the actions they 

plan to undertake to accomplish their goals.

Only 1 of the 24 agencies that developed APGs described how those 

goals reflect input from congressional consultations. GPRAMA states that 

APGs are to reflect the highest priorities of the agency as determined by 

the head of the agency and informed by consultations with Congress. 

Agencies are to consult with their relevant appropriations, authorization, 

and oversight committees when developing or making adjustments to 

their strategic plans, including their APGs, at least once every 2 years. 

Regarding this requirement, OMB’s guidance highlights that agencies 

should specifically consult with Congress on priority goal issue areas, and 

suggests agencies could start discussions of their next set of priority 

goals in the context of providing Congress an update on progress on the 

current APGs.

 

3731 U.S.C. § 1122(b)(3)(B).

Most Agencies Did Not 

Describe How Their 

Priority Goals Reflect 

Congressional Input
 

Page 32 GAO-13-174 Agency Priority Goals

The act also requires agencies to describe how input provided during 

congressional consultations was incorporated for each agency priority 

goal on Performance.gov.38

In the December 2012 update to Performance.gov, agencies provided 

information about how they engaged stakeholders during their goal 

development processes. Although 19 agencies stated that they included 

Congress as part of their stakeholder engagement, only SBA provided 

information about the input it received on its APGs from those 

consultations, as shown in figure 13.

In addition, agencies are to similarly describe 

in their strategic plans how input from congressional consultations was 

incorporated into their goals. Without this information, it will be difficult to 

know whether an agency’s goals reflect congressional input, and 

therefore if the goals will provide useful information for congressional 

decision making.

 

3831 U.S.C. § 1122(b)(1). 
 

Page 33 GAO-13-174 Agency Priority Goals

Figure 13: SBA’s Description of Congressional Consultation on APGs
 

Page 34 GAO-13-174 Agency Priority Goals

Two agencies, DOD and DOT, broadly mentioned that congressional 

input on agency goals was incorporated as appropriate. Education took a 

different approach and provided information about how it engaged 

stakeholders, including Congress in several instances, for each of its 

APGs. However, none of these agencies provided specific information on 

the input that was received or how it was incorporated.

Several agencies also provided broad descriptions of their consultations 

in their strategic plans. For example, VA states in its plan that in 

November 2011 it initiated the process for consulting with Congress 

regarding the development of its agency priority goals and the VA 

strategic plan. Additionally, in the SSA strategic plan, the agency 

mentioned developing its plan in consultation with employees, 

stakeholders, advisory groups, and Congress. However, in none of these 

instances did agencies provide any further details about how these 

consultations influenced their strategic plans, including their APGs.

OMB’s 2011 guidance, which covered the development of APGs for 2012 

to 2013, stated that agencies should consult with Congress on priority 

goal issue areas, prior to submitting draft goals to OMB.39

However, without such information, it is unclear that agencies have 

adequately engaged Congress and appropriately incorporated 

congressional feedback into their APGs. The consultation process was 

established by GPRA in 1993 so that agencies could take congressional 

views into account as appropriate. But as noted in the Senate committee 

report that accompanied the bill that ultimately became GPRAMA, little 

evidence existed that agencies had formally or significantly considered 

the input of key stakeholders when developing goals. The requirement for 

OMB staff told 

us that agencies formed a working group on consultations and OMB staff 

worked with agencies on how to do the consultations well. However, OMB 

staff also told us that agencies were generally not comfortable publishing 

the input they received from Congress during their consultation for a 

variety of reasons, such as a reluctance to characterize competing or 

conflicting congressional interests.

 

39OMB’s 2012 guidance elaborated on this requirement, directing agencies to obtain both 

majority and minority views from the appropriate authorizing, appropriations and oversight 

committees.
 

Page 35 GAO-13-174 Agency Priority Goals

agencies to describe how congressional input was incorporated into their 

goals was intended to strengthen the consultation process.40

Our past work has noted the importance of considering Congress a 

partner in shaping agency goals.41 Successful consultations can create a 

basic understanding among stakeholders of the competing demands that 

confront most agencies, the limited resources available to them, and how 

those demands and resources require careful and continuous balancing. 

We have also reported that agency consultations with Congress on the 

identification of priority goals presents an opportunity to develop such an 

understanding, especially given Congress’s role in setting national 

priorities and allocating the resources to achieve them.42 Although 

constructive communication across the branches of government can 

prove difficult, it is essential for sustaining federal performance 

improvement efforts. Consultations provide an important opportunity for 

Congress and the executive branch to work together to ensure that 

agency missions are focused; goals are specific, results-oriented, and 

address congressional concerns about performance; and strategies and 

funding expectations are appropriate and reasonable.

Our prior audit work and in some instances that of relevant agency 

inspectors general provide additional perspective on the capacity of DHS, 

DOT, HUD, OPM, and VA to achieve their APGs. Our comments on each 

of these goals can be found in Appendixes II (DHS), III (HUD), IV (DOT), 

V (VA), and VI (OPM). Given the breadth of issues dealt with by these 

goals, our comments for each goal cover a range of topics.

Despite this variation, several goals suggested that agencies continue to 

grapple with a common challenge from our past work related to 

measuring progress toward their goals and ensuring that the related 

performance data are accurate. For example, related to both HUD’s and 

VA’s APGs to assist in housing and reducing the number of homeless 

veterans, we have previously reported that HUD and VA lack key data on 

 

40S. Rep. No. 111-372, at 5. 

41GAO-11-617T. 

42GAO, Managing for Results: A Guide for Using the GPRA Modernization Act to Help 

Inform Congressional Decision Making, GAO-12-621SP (Washington: D.C.: Jun. 15, 

2012).

Past Audit Work 

Provides Perspective 

on Selected Agencies’ 

Capacities to Achieve 

Their Priority Goals
 

Page 36 GAO-13-174 Agency Priority Goals

the population of homeless women veterans, including their 

characteristics and needs. This hampers VA’s ability to plan services 

effectively. In December 2011, we recommended that HUD and VA 

should collaborate to ensure appropriate data are collected and use these 

data to strategically plan for services. VA concurred with this 

recommendation and, in April 2013, stated that it had taken additional 

actions to inform policy and operational decisions about homeless and atrisk women veterans. For example, VA stated that it worked with HUD to 

ensure that gender specific data were collected during the 2013 Point in 

Time count of homeless persons. In another example related to DOT’s 

APG to reduce roadway fatalities, our past work has indicated that the 

quality of state traffic safety data systems varied across the six data 

systems maintained by states. In April 2010, we recommended that the 

National Highway Traffic Safety Administration (NHTSA) take steps to 

ensure that traffic records assessments provide an in-depth evaluation 

that is complete and consistent in addressing quality across all state 

traffic safety data systems. In response, NHTSA has taken a number of 

steps intended to improve the quality of the assessments and the data 

systems, and as of spring 2013, these efforts continue.

Many of the meaningful results that the federal government seeks to 

achieve cannot be realized without effective coordination and 

collaboration both within and across agencies. Recognizing this, 

Congress and the executive branch established a new crosscutting and 

integrated approach for focusing on results and improving government 

performance with the passage and enactment of GPRAMA. The act’s 

requirements related to the development of APGs, along with more 

frequent reviewing and reporting of progress towards them, have the 

potential to address crosscutting and other federal performance 

management challenges our past work has identified.

OMB and the PIC provided significant support to agencies during their 

development of APGs. For example, in 2011 and 2012, OMB developed 

and provided to agencies detailed guidance and memorandums to 

explain GPRAMA’s requirements and OMB’s expectations for APGs. In 

addition, the PIC formed the Goal Setting Working Group to assist 

agencies in setting their 2012 to 2013 APGs, and developed draft guides 

related to selecting APGs and developing milestones. Given these past 

efforts, both OMB and the PIC will have an important role moving forward 

to help ensure that agencies fully develop their APGs.

Conclusions 
 

Page 37 GAO-13-174 Agency Priority Goals

Agencies have implemented key provisions related to their APGs. 

However, they have not always provided information about coordination 

and collaboration for crosscutting efforts. Agencies also did not always 

identify external contributors to their APGs. OMB’s review process for 

publishing APG information on Performance.gov checks to make sure 

agencies have identified at least one contributor, but it does not verify that 

agencies have identified all appropriate contributors. In addition, most

agencies did not describe how their APGs contribute to CAP goals. 

OMB’s guidance does not adequately reflect that agencies should 

describe this linkage. Revised guidance could help ensure that agencies 

are aware of this requirement and provide information accordingly. 

Further, without providing information about external contributors or how 

APGs contribute to CAP goals, it is unclear whether agencies have 

adequately planned to address performance that spans multiple 

organizations, thereby putting these efforts at risk for duplication, overlap, 

and fragmentation and potentially wasting scarce funds and limiting the 

effectiveness of federal efforts.

The requirement for agencies to review progress made toward their APGs 

on a quarterly basis is intended to increase agencies’ use of the 

significant amount of performance information they collect. This, in turn, 

can help agencies to improve their performance and results in a more 

timely manner—a challenge our work has previously highlighted. 

Agencies generally developed performance measures, and collect 

information more frequently than in the past. This shows promise for their 

ability to use this information to support more timely decision making, 

especially when improvements are needed. However, agencies did not 

always identify related interim performance targets. This could be 

because OMB’s A-11 guidance does not mention the interim quarterly 

performance target requirement or define when it would provide data of 

significant value and therefore be required, although other OMB guidance 

directs agencies to develop these targets. By revising its guidance 

documents to consistently include this information, OMB could help 

ensure that agencies are meeting its expectation (and the requirement) 

that agencies identify interim performance targets for their APGs when 

doing so would provide data of significant value. Without clear targets, 

which enable a comparison of results against planned performance, it is 

unclear if agency managers have the information they need to determine 

if they are making sufficient progress toward each APG—a practice our 

past work has shown can actually lead to increased use of information 

and improved results. In addition, by not providing targets, key 

stakeholders have little assurance that an agency is actively managing its 
 

Page 38 GAO-13-174 Agency Priority Goals

performance to make progress towards its APGs on a quarterly basis, 

thereby limiting oversight and accountability opportunities.

GPRAMA requires agencies to develop clearly defined quarterly 

milestones for their APGs, which can help demonstrate that agencies 

have identified concrete actions needed to accomplish their goals and 

when those actions should be taken. However, agencies did not 

consistently publish milestones with scheduled completion dates, thereby 

missing an opportunity to assure the public and key stakeholders that 

they have appropriate strategies in place to achieve their APGs. Although 

OMB’s 2012 A-11 guidance directs agencies to develop quarterly 

milestones for their APGs and outlines near-term and longer-term 

timeframes those milestones should cover, the guidance does not state 

that agencies should provide specific completion dates for their 

milestones. In addition, the guidance does not adequately reflect that 

GPRAMA requires these milestones to be published on Performance.gov 

due to an error. Although OMB has provided additional direction to 

agencies about publishing milestones, revising its A-11 guidance to 

correct the error would ensure that its direction to agencies is consistent 

and clear.

Agencies should consult with Congress as a partner in developing their 

goals, in part to ensure that the resulting performance information is 

useful for congressional and executive branch decision making. Agencies’ 

consultations with Congress on their APGs provide opportunities for both 

parties to gain a better understanding of the competing demands that 

both confront and how those demands and limited resources require 

careful and continuous balancing. However, most agencies did not 

provide information about how they incorporated any views or 

suggestions obtained through congressional consultations when 

developing their goals. This lack of information leaves it unclear as to 

whether agencies made serious attempts to engage with Congress on 

identifying the agencies’ highest priorities for improved performance.
 

Page 39 GAO-13-174 Agency Priority Goals

To ensure that agencies fully develop their APGs, we make the following 

seven recommendations to the Director of OMB.

To ensure that agencies can (1) compare actual results to planned 

performance on a more frequent basis, as appropriate, and (2) 

demonstrate how they plan to accomplish their goals as well as contribute 

to the accomplishment of broader federal efforts, we recommend the 

Director of OMB revise relevant guidance documents to

• provide a definition of what constitutes “data of significant value;” 

• direct agencies to develop and publish on Performance.gov interim 

quarterly performance targets for their APG performance measures 

when the above definition applies;

• direct agencies to provide and publish on Performance.gov

completion dates, both in the near term and longer term, for their 

milestones; and

• direct agencies to describe in their performance plans how the 

agency’s performance goals—including APGs—contribute to any of 

the CAP goals.

When such revisions are made, we recommend the Director of OMB work 

with the PIC to test and implement these provisions.

In addition, as OMB works with agencies to enhance Performance.gov to 

include additional information about APGs, we recommend that the 

Director of OMB ensure that agencies adhere to OMB’s guidance for 

website updates by providing

• complete information about the organizations, program activities, 

regulations, tax expenditures, policies, and other activities—both 

within and external to the agency—that contribute to each APG; and

• a description of how input from congressional consultations was 

incorporated into each APG. 

We provided a draft of this report for review and comment to the Director 

of OMB and the five agencies covered by our in-depth review of APGs 

(DHS, DOT, HUD, VA, and OPM). All six agencies provided technical 

comments, which we incorporated as appropriate. 

In oral comments, staff from OMB’s Office of Performance and Personnel 

Management agreed with the recommendations in our report. 

Recommendations for 

Executive Action

Agency Comments

and Our Evaluation
 

Page 40 GAO-13-174 Agency Priority Goals

In its written comments, reproduced in appendix VII, VA concurred with 

the conclusions of our report and provided additional information about its 

strategic plan, and related performance measurement efforts, to reduce 

its backlog of compensation claims. However, as VA acknowledges in its 

comments, the plan does not provide individual performance goals and 

metrics for all initiatives, which we believe are necessary for VA to ensure

it is spending its limited resources on proven methods to speed up 

disability claims and appeals processes.

We also sought comments from relevant agencies covered by the 

illustrative examples used in this report. We received such comments 

from Commerce, NSF, SBA, State, and USAID, and incorporated them as 

appropriate.

We are sending copies of this report to the Acting Director of OMB and 

the heads of the 24 agencies that developed APGs as well as interested 

congressional committees and other interested parties. This report will 

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

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

me at (202) 512-6806, or mihmj@gao.gov. Specific questions about our 

comments on the sample of APGs contained in appendixes II through VI 

may be directed to the contact listed for each goal. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of our report. Key contributors to this report are listed in 

appendix VIII. 

J. Christopher Mihm

Managing Director, Strategic Issues
Appendix I: Objectives, Scope & Methodology

Page 41 GAO-13-174 Agency Priority Goals

The GPRA Modernization Act of 2010 (GPRAMA) requires us to review 

the act’s implementation at several critical junctures, and this report is 

part of a series of reviews planned around the requirement. Our specific 

objectives for this report were to (1) examine the extent to which agencies 

have implemented selected planning and reporting requirements and 

leading practices related to agency priority goals (APG); and (2) comment 

on the priority goals of several selected agencies based on our prior work 

and that of relevant agency inspectors general (IGs) and identify our 

relevant open recommendations and matters for congressional 

consideration.

To address both objectives, we reviewed information about the APGs 

published on Performance.gov in February 2012 and updated in 

December 2012,1

In addition, for the first objective, we reviewed and assessed the 

implementation of selected planning and reporting requirements for 102 

of the 103 APGs developed by the 24 agencies selected by OMB and that 

were released concurrently with the President’s fiscal year 2013 budget 

on Performance.gov.

as well as the updated strategic plans and performance 

plans agencies published in 2012 to reflect GPRAMA requirements. To 

assess the reliability of information presented on Performance.gov we 

reviewed relevant documentation and interviewed Office of Management 

and Budget (OMB) staff about data quality control procedures. We 

determined that the data were sufficiently reliable for the purposes of this 

report.

2

 

1

However, for the figures throughout this report that reflect illustrative examples from 

Performance.gov, we used the most recent information, as of March 2013. 

The key GPRAMA planning and reporting 

requirements we used to assess implementation included whether the 

goal: (1) supports a federal government priority goal (also known as 

cross-agency priority or CAP goals); (2) contributes to agency strategic 

goals; (3) reflects input from congressional consultations; (4) identifies the 

federal organizations, program activities, regulations, policies, and other 

activities—both within and external to the agency—that contribute to the 

APG; (5) has a clearly identified agency official as the goal leader; (6) has 

targets for a 2-year timeframe; (7) has interim quarterly targets; and (8) 

2

The Department of Defense has published limited information about its APG to improve 

cybersecurity due to its sensitive nature. According to Performance.gov, progress updates 

on this goal will be internal to the government. Because we used publicly available 

information, we excluded this goal from our implementation assessment. 

Appendix I: Objectives, Scope & 

Methodology 
Appendix I: Objectives, Scope & Methodology

Page 42 GAO-13-174 Agency Priority Goals

has clearly defined quarterly milestones. In addition to the requirements 

of GPRAMA, our assessment of the extent of implementation was also 

informed by the Senate committee report accompanying GPRAMA, 

relevant OMB guidance, and our past work on how to effectively 

implement GPRA.

To address the second objective, we selected 5 of the 24 agencies that 

developed APGs—the Departments of Homeland Security (DHS), 

Housing and Urban Development (HUD), Transportation (DOT), and

Veterans Affairs (VA), and the Office of Personnel Management (OPM)—

based on several factors, including the number and variety of types of 

federal programs involved in achieving the goals, such as direct service, 

grant, and regulatory programs, and whether the APGs were related to 

any of the CAP goals. We then reviewed the work that we and relevant 

IGs have conducted over a number of years related to each of the 21 

APGs developed by the 5 agencies. Because the 21 APGs are a nongeneralizable sample of all APGs, our views on those APGs cannot be 

generalized to the entire universe but provided insights about each of the 

21 APGs, as well as a theme common to several APGs. We also updated 

the status of related key open recommendations and matters for 

congressional consideration

We conducted our performance audit from July 2012 to April 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 43 GAO-13-174 Agency Priority Goals

Based on our past work, as well as that of the DHS IG, we commented on 

each of DHS’s three priority goals for 2012 to 2013:

1. Ensure resilience to disasters by strengthening disaster preparedness 

and response capabilities. By September 30, 2013, every state will 

have a current, DHS-certified threat, hazard, identification and risk 

assessment (THIRA).1

2. Improve the efficiency of the process to detain and remove criminal 

aliens from the United States. By September 30, 2013, reduce the 

average length of stay in immigration detention of all convicted 

criminal aliens prior to their removal from the country by 5 percent. 

3. Strengthen aviation security counterterrorism capabilities by using 

intelligence driven information and risk-based decisions. By 

September 30, 2013, the Transportation Security Administration will 

expand the use of risk-based security initiatives to double the number 

of passengers going through expedited screening at airports, thereby 

enhancing the passenger experience.

For each goal, we also identify our related past reports and provide an 

update on the status of any open recommendations and matters for 

congressional consideration that we previously made related to the goal. 

We also identify a GAO contact for our work related to each goal.

Ensure resilience to disasters by strengthening disaster preparedness 

and response capabilities. By September 30, 2013, every state will have 

a current, DHS-certified threat, hazard, identification, and risk 

assessment. 

Our past work has identified a number of challenges DHS faces in 

achieving its goal of strengthening disaster preparedness and response 

capabilities including challenges associated with efforts to measure 

national preparedness capabilities and assess the impact of 

preparedness grant funding. These efforts involve the Federal Emergency 

Management Agency’s (FEMA) preparedness grants.

 

1

According to DHS, the THIRA is a comprehensive approach to assess the various threats 

and hazards facing a community and the vulnerability of the community to those hazards 

as well as to estimate the consequences of those threats and hazards through a step-bystep process. 

Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Goal Statement

GAO Comments
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 44 GAO-13-174 Agency Priority Goals

FEMA provides state and local governments with funding in the form 

of grants to enhance the capacity of state and local emergency 

responders to prevent where possible, respond to, and recover from 

natural disasters and terrorism incidents involving chemical, biological, 

radiological, nuclear, or explosive devices, or cyber attacks. States and 

urban areas are required to conduct a THIRA as a condition of receiving 

preparedness grant funding under programs including the State 

Homeland Security Program, Emergency Management Performance 

Grant Program and Urban Area Security Initiative grant program.2

We reported in March 2012 that, while the THIRA concept was first 

introduced as part of FEMA’s fiscal year 2011 grant guidance, grantees 

had not yet received guidance on how to conduct the THIRA process. In 

April 2012, FEMA issued guidance to its grantees intended to provide a 

comprehensive approach for identifying and assessing risks and 

associated impacts.3 The THIRA guide describes a step-by-step process 

to assess the various threats and hazards facing a community and the 

vulnerability of the community to those hazards as well as to estimate the 

consequences of those threats and hazards. The THIRAs are to provide 

FEMA with data that can be analyzed to identify national funding priorities 

and a set of capability targets. At the state and urban area level, officials 

are to use the capability targets in the THIRA to prepare annual State 

Preparedness Reports (SPR).4

 

2

The State Homeland Security Program supports the implementation of state homeland 

security strategies to address the identified planning, organization, equipment, training, 

and exercise needs to prevent, protect against, mitigate, respond to, and recover from 

acts of terrorism and other catastrophic events. Urban Area Security Initiative program 

funds address the unique planning, organization, equipment, training, and exercise needs 

of high-threat, high-density urban areas, and assists them in building an enhanced and 

sustainable capacity to prevent, protect against, mitigate, respond to, and recover from 

acts of terrorism. The Emergency Management Preparedness Grants Program provides 

grants to states to assist state, local, tribal and territorial governments in preparing for all 

hazards.

In October 2012, FEMA officials reported 

that they planned to use the THIRAs and SPRs to identify capability gaps 

based on capability-specific performance objectives. According to FEMA 

officials, as of March 2013, some state and local urban areas had not yet 

3

Department of Homeland Security, Federal Emergency Management Agency, Threat and 

Hazard Identification and Risk Assessment Guide Comprehensive Preparedness Guide 

(CPG) 201 First Edition, (Washington, D.C., April 2012.)

4

State Preparedness Reports are statewide survey-based self-assessments of capability 

levels and requirements submitted by all 56 U.S. states and territories. 
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 45 GAO-13-174 Agency Priority Goals

completed their THIRAs. FEMA granted 6-month extensions to the 

December 31, 2012, deadline for five states and three local urban areas 

affected by Hurricane Sandy in late October 2012.

In March 2011, we suggested that Congress may wish to consider limiting 

preparedness grant funding to maintaining existing capabilities (as 

determined by FEMA) until FEMA completes a national preparedness 

assessment of capability gaps at each level of government based on 

tiered, capability-specific performance objectives to enable prioritization of 

grant funding. In April 2011, Congress passed the Continuing 

Appropriations Act that reduced funding for FEMA preparedness grants 

by $875 million from the amount requested in the President’s fiscal year 

2011 budget.5 In December 2011, Congress passed the Consolidated 

Appropriations Act for fiscal year 2012 that reduced funding for FEMA 

preparedness grants by $1.28 billion from the amount requested in the 

President’s fiscal year 2012 budget.6

In March 2011, we also suggested that FEMA should complete a national 

preparedness assessment of capability gaps at each level based on 

tiered, capability-specific performance objectives to enable prioritization of 

grant funding, and FEMA could identify the potential costs for establishing 

and maintaining those capabilities at each level and determine what 

capabilities federal agencies should provide. In June 2012, the DHS OIG 

reported that FEMA did not have a system in place to determine the 

extent that Homeland Security Grant Program funds enhanced the states’ 

capabilities to prevent, deter, respond to, and recover from terrorist 

attacks, major disasters, and other emergencies before awarding more 

funds to the states. As of March 2013, FEMA has not yet completed a 

national preparedness assessment of capability gaps at each level. 

According to FEMA officials, the urban area, state, territorial, and tribal 

nation THIRAs that were due December 31, 2012 will serve as the basis 

for assessing national preparedness capabilities and gaps. FEMA will 

coordinate the review and analysis by a THIRA Analysis and Review 

Team. The team has begun meetings to discuss the common themes and 

findings and develop an initial proposed list of priorities for building and 

sustaining the core capabilities and update the proposed list of priorities 

 

5 Pub. L. No. 112-10, § 1632, 125 Stat. 38, 143 (2011).

6 Pub. L. No. 112-74, 125 Stat. 786, at 960-62 (2011).

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 46 GAO-13-174 Agency Priority Goals

as needed. These actions are part of the overall process for THIRA 

analysis and review, which FEMA officials said will help them develop 

guidance for developing capabilities to meet national priorities.

In July 2009, we recommended that the FEMA Administrator should 

develop and implement measures to assess how regional collaboration 

efforts funded by Urban Area Security Initiative grants build preparedness 

capabilities. FEMA contracted the National Academy of Public 

Administration to provide recommendations for quantifiable performance 

measures to assess the effectiveness of the State Homeland Security 

Program and Urban Area Security Initiative grants.7

FEMA indentified the “percent of high priority core planning capabilities 

rated as proficient by states and territories” as a measure of the agency’s 

progress in achieving its priority goal. This measure reports the percent of 

high priority core capabilities related to planning that states and territories 

rate as proficient. According to FEMA, this information is gathered from 

the SPRs (annual self-assessments by states and territories of their levels 

of preparedness.) However, as we reported in October 2010, FEMA 

officials stated, while the SPRs had enabled FEMA to gather data on the 

progress, capabilities, and accomplishments of a state’s, the District of 

Columbia’s, or a territory’s preparedness program, these reports include 

self-reported data that may be subject to interpretation by the reporting 

organizations in each state and not be readily comparable to other states’ 

data. The officials also stated that they had taken steps to address these 

limitations, for example by creating a web-based survey tool to provide a 

The National 

Academy of Public Administration issued its report in October 2011 and 

FEMA released the report in April 2012. The report recommends that 

FEMA conduct an assessment of collaborative approaches, in 

coordination with local jurisdictions, states, regions, and urban areas, and 

use the results to develop a scoring system for future quantitative or 

qualitative performance measures on collaboration. As of March 2013, 

FEMA has not yet taken action in response to this recommendation. 

However, according to FEMA officials, the THIRA process, along with 

planned coordination meetings with urban area, state, tribal, and territorial 

officials will likely result in data that they can use to develop collaborationrelated performance metrics.

 

7

The National Academy of Public Administration is a non-profit, independent organization 

that conducts research and analysis for federal, state and local governments. 
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 47 GAO-13-174 Agency Priority Goals

more standardized way of collecting state preparedness information that 

will help them validate the information by comparing it across states. 

However, since April 2009, FEMA has made limited progress in 

assessing preparedness and capabilities and has not yet developed 

national preparedness capability requirements based on established 

metrics to provide a framework for these assessments, as we reported in 

March 2012.

National Preparedness: FEMA Has Made Progress in Improving Grant 

Management and Assessing Capabilities, but Challenges Remain. GAO13-456T. Washington, D.C.: March 19, 2013.

Managing Preparedness Grants and Assessing National Capabilities: 

Continuing Challenges Impede FEMA’s Progress. GAO-12-526T. 

Washington, D.C.: March 20, 2012.

Follow-up on 2011 Report: Status of Actions Taken to Reduce 

Duplication, Overlap, and Fragmentation, Save Tax Dollars, and Enhance 

Revenue. GAO-12-453SP. Washington, D.C.: February 28, 2012.

Government Operations: Opportunities to Reduce Potential Duplication in 

Government Programs, Save Tax Dollars, and Enhance Revenue. 

GAO-11-318SP. Washington, D.C.: March 1, 2011.

FEMA Has Made Limited Progress in Efforts to Develop and Implement a 

System to Assess National Preparedness Capabilities. GAO-11-51R. 

Washington, D.C.: October 29, 2010.

Urban Area Security Initiative: FEMA Lacks Measures to Assess How 

Regional Collaboration Efforts Build Preparedness Capabilities. 

GAO-09-651. Washington, D.C.: July 2, 2009.

National Preparedness: FEMA Has Made Progress, but Needs to 

Complete and Integrate Planning, Exercise, and Assessment Efforts. 

GAO-09-369. Washington, D.C.: April 30, 2009.

Stephen L. Caldwell, Director, Homeland Security and Justice Issues, 

caldwells@gao.gov, (202) 512-8777.

Selected GAO Reports

GAO Contact
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 48 GAO-13-174 Agency Priority Goals

Improve the efficiency of the process to detain and remove criminal aliens 

from the United States. By September 30, 2013, reduce the average 

length of stay in immigration detention of all convicted criminal aliens prior 

to their removal from the country by 5 percent. 

Our past work does not provide a basis to assess DHS’s ability to 

improve the efficiency of the process to detain and remove criminal aliens 

from the United States. DHS has reported progress toward achieving this 

priority goal since fiscal year 2010. The DHS annual performance report 

for fiscal years 2011 to 2013—which also serves as the agency’s annual 

performance plan—showed that the agency reduced the length of stay in 

detention of all convicted criminal aliens prior to removal from the United 

States from 37 days in fiscal year 2010 to 34.7 days in fiscal year 2011. 

This represents a decline of over 6 percent compared to the priority goal 

target to reduce the length of stay by 5 percent. DHS attributed this 

decrease in part to expanded detention capacity in locations where 

detainee transfers occur most often, as the need to transfer a detainee 

from a facility in one location to another location increased the average 

length of stay by approximately 14 days. The DHS strategic plan for fiscal 

years 2012 to 2016 shows planned targets to maintain the same number 

of days (35) in fiscal years 2012, 2013, and 2016. Similarly, the DHS 

annual performance report for fiscal years 2011 to 2013 shows the same 

planned target of less than or equal to 35 days for both fiscal year 2012 

and fiscal year 2013. DHS reported that it continues to focus on the 

development of a detention system that has the right number and type of 

facilities in the right locations to align with enforcement and removal 

activities. DHS reported making improvements in prior years, but noted 

that various challenges, such as case backlogs, could inhibit success in 

achieving further improvements in length of stay requirements. For 

example, maintaining the average length of stay for criminal aliens at, or 

slightly below, 35 days in the long term may require the hiring of 

additional immigration judges, according to DHS.

We currently have no open recommendations or matters for 

congressional consideration related to this priority goal.

We currently have no reports related to this priority goal.

Goal Statement

GAO Comments

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 49 GAO-13-174 Agency Priority Goals

Rebecca Gambler, Director, Homeland Security and Justice Issues, 

gamblerr@gao.gov, (202) 512-6912.

Strengthen aviation security counterterrorism capabilities by using 

intelligence driven information and risk-based decisions. By September

30, 2013, the Transportation Security Administration (TSA) will expand 

the use of risk-based security initiatives to double the number of 

passengers going through expedited screening at airports, thereby 

enhancing the passenger experience.

TSA’s goal is stated in broad terms; consequently, quantitatively 

measuring progress toward meeting the goal of strengthening aviation 

security counterterrorism capabilities will be a challenge. Further, the 

stated performance measure, with its focus on expedited passenger 

screening, will not allow TSA to assess its progress in using intelligence 

driven information and risk-based decisions to meet this goal in other 

related areas, such as in screening checked baggage or air cargo. TSA, 

as a component of DHS, relies upon multiple layers of security to deter, 

detect, and disrupt persons posing a potential risk to aviation security. 

These layers focus on screening millions of passengers and pieces of 

carry-on and checked baggage, as well as tons of air cargo, on a daily 

basis. Our past work has analyzed TSA’s progress in implementing these 

security measures and identified challenges it has encountered in 

implementing cost-effective aviation security programs and measuring 

performance.

To help achieve its priority goal of strengthening aviation security 

counterterrorism capabilities by using intelligence driven information and 

risk-based decisions, TSA officials stated that the agency will, among 

other steps, expand the use of its new “TSA Pre✓TM” program to double

the number of passengers going through expedited screening at airports 

by September 30, 2013. TSA introduced TSA Pre✓TM in October 2011, 

and plans on expanding it to 40 airports by March 2013. Based on current 

participation, frequent flyers of five airlines as well as individuals enrolled 

in other departmental trusted traveler programs—where passengers are 

pre-vetted and deemed a trusted traveler—are eligible to be screened on 

an expedited basis. This program is intended to allow TSA to focus its 

resources on higher risk travelers. Agency officials have reported that 

with the deployment of this program and other risk-based security 

initiatives, such as modifying screening procedures for passengers 75 

GAO Contact

Goal Statement

GAO Comments
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 50 GAO-13-174 Agency Priority Goals

and over and active duty service members, TSA has achieved its stated 

goal of doubling the number of passengers going through expedited 

screening. According to TSA, by the end of calendar year 2013, TSA will 

provide expedited screening to 25 percent of the individuals currently 

processed through security screening. Achieving this target will mean that 

approximately 450,000 of the 1.8 million passengers who travel on 

average each day from the nation’s airports will undergo some form of 

expedited screening. However, since this goal is focused on passenger 

screening, it will not allow TSA to assess its progress in using intelligence 

driven information and risk-based decisions in other areas to achieve the 

broader outcome of strengthening aviation security counterterrorism 

capabilities, such as in screening checked baggage or air cargo. We plan 

to initiate a review of TSA’s progress in implementing TSA Pre✓TM in 

2013.

In our past work, we found that TSA has taken steps to implement 

aviation security mechanisms that are more intelligence-driven and riskbased. For example, TSA implemented the Secure Flight program to 

allow it to focus resources on high risk passengers by vetting passengers’ 

names, dates of birth, and other information against terrorist watch lists.8

In May 2009, we reported that TSA had made significant progress in 

developing the Secure Flight program but also noted that it faced 

challenges in identifying passengers who might use false identifying 

information. We also assessed TSA’s efforts to implement a behavior 

detection program that seeks to selectively identify potentially high-risk 

passengers for additional screening. Our May 2010 report found that 

while TSA has taken actions to validate the science underlying the 

program and improve performance measurement, among other actions, 

more work remains to ensure the program’s effectiveness, such as 

developing comprehensive program performance measures. In March 

2012, we reported that questions related to the program will remain until 

TSA demonstrates that using behavior detection techniques can help 

secure the aviation system against terrorist threats. TSA plans to or is 

currently implementing a number of other behavior based programs that 

we plan to report on in 2013.

 

8

See 49 U.S.C. § 44903(j)(2)(C). 
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 51 GAO-13-174 Agency Priority Goals

In November 2012, we recommended that TSA take steps to improve its

oversight of air passenger screening complaint processes, by establishing 

(1) consistent policies for receiving complaints and informing passengers 

about complaint processes, (2) a process to systematically analyze 

information on complaints, and (3) a focal point to coordinate these 

efforts. In its comments on this report, DHS concurred with the 

recommendations and stated that TSA is taking steps to implement them.

In May 2012, we recommended that to help DHS address challenges in 

meeting the air cargo screening mandate as it applies to air cargo carried 

on passenger flights inbound to the United States,9

In July 2011, we recommended that TSA develop a plan to deploy 

explosives detection systems (EDS) that meet the most recent 

explosives-detection requirements and ensure that new machines, as well 

as machines deployed in airports, will be operated at the levels 

established in those requirements. This plan should include the estimated 

costs for new machines and upgrading deployed machines, and the time 

frames for procuring and deploying new machines. In commenting on this 

report, DHS concurred with the recommendation. As of March 2013, TSA 

has a plan in place to evaluate and implement the most recent certified 

algorithms on the existing fleet of deployed EDSs. However, our 

recommendation calls for a plan to deploy new EDSs as well as to 

upgrade existing EDSs in airports to meet the 2010 EDS explosives 

detection requirements. Our recommendation was intended to ensure that 

all EDSs operating in airports meet the most recent requirements, which 

are currently the 2010 requirements. Consequently, we continue to 

believe that a plan is needed that describes the approach that TSA will 

mitigate potential air 

cargo security vulnerabilities, and enhance overall efforts to screen and 

secure inbound air cargo, the Secretary of Homeland Security should 

direct the Administrator of TSA to assess the costs and benefits of 

requiring all-cargo carriers to report data on the amount of inbound air 

cargo screening being conducted. In comments on the May 2012 report, 

DHS concurred with the recommendation and stated that TSA was 

working on developing a system that will provide the capability for allcargo carriers to report data on screened high-risk inbound air cargo 

shipments. In April 2013, TSA reported that once this system becomes 

fully operational, these data will be available for each all-cargo carrier. 

 

9

See 49 U.S.C. § 44901(g). 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 52 GAO-13-174 Agency Priority Goals

use to deploy EDSs that meet the most recent explosives detection 

requirements and ensure that all deployed machines will be operated at 

the levels established in the latest requirements.

In May 2010, we recommended that TSA perform a cost benefit analysis 

of TSA’s behavior detection program known as the Screening of 

Passengers by Observation Techniques (SPOT), including a comparison 

of the program with other security screening programs, such as random 

screening, or other already existing security measures. In commenting on 

this report, DHS concurred with the recommendation and TSA completed 

the analysis in December 2012. We are evaluating the cost-benefit 

analysis as part of ongoing work that we will report on in 2013.

In May 2010, we recommended that TSA take steps to better measure 

the effectiveness of the SPOT program and evaluate the performance of 

TSA’s behavior detection officers, who implement the program at TSAregulated airports. We also recommended that TSA establish a plan that 

includes objectives, milestones, and time frames to develop outcomeoriented performance measures to help refine the current methods used 

by behavior detection officers for identifying individuals who may pose a 

risk to the aviation system. In commenting on this report, DHS concurred 

with the recommendation and completed its plan in November 2012. We 

are evaluating the plan as part of ongoing work that we will report on in 

2013.

Air Passenger Screening: Transportation Security Administration Could 

Improve Complaint Processes. GAO-13-43. Washington, D.C.: November 

15, 2012.

Aviation Security: Actions Needed to Address Challenges and Potential 

Vulnerabilities Related to Securing Inbound Air Cargo. GAO-12-632. 

Washington, D.C.: May 10, 2012.

Aviation Security: TSA Has Enhanced Its Explosives Detection 

Requirements for Checked Baggage, but Additional Screening Actions 

Are Needed. GAO-11-740. Washington, D.C.: July 11, 2011.

Aviation Security: Efforts to Validate TSA’s Passenger Screening 

Behavior Detection Program Underway, but Opportunities Exist to 

Strengthen Validation and Address Operational Challenges. GAO-10-763. 

Washington, D.C.: May 20, 2010.

Selected GAO Reports
Appendix II: Comments on the Department of 

Homeland Security’s Priority Goals

Page 53 GAO-13-174 Agency Priority Goals

Aviation Security: TSA Has Completed Key Activities Associated with 

Implementing Secure Flight, but Additional Actions Are Needed to 

Mitigate Risks. GAO-09-292. Washington, D.C.: May 13, 2009.

Stephen M. Lord, Director, Homeland Security and Justice Issues, 

lords@gao.gov, (202) 512-4379.

GAO Contact
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 54 GAO-13-174 Agency Priority Goals

Based on our past work, as well as that of the HUD IG, we commented on 

each of HUD’s six priority goals for 2012 to 2013:

1. Improve program effectiveness by awarding funds fairly and quickly. 

By September 30, 2013, HUD will improve internal processes to 

ensure that HUD can obligate 90 percent of Notice of Funding 

Availability (NOFA) programs within 180 calendar days from budget 

passage, ensuring that America’s neediest families have the shelter 

and services they need, when they need them. The timely obligation 

and subsequent disbursement of funds will positively impact the 

agency’s ability to achieve all of its priority goals. 

2. Increase the energy efficiency and health of the nation’s housing 

stock. By September 30, 2013, HUD will enable a total of 159,000 

cost effective energy efficient or healthy housing units, as part of a 

joint HUD-Department of Energy (DOE) goal of 520,000 in 2012 to 

2013 and a total goal of 1.2 million units from 2010 through 2013.

3. Preserve affordable rental housing. By September 30, 2013, preserve 

affordable rental housing by continuing to serve 5.4 million families 

and serve an additional 61,000 families through HUD’s affordable 

rental housing programs.

4. Prevent foreclosures. By September 30, 2013, assist 700,000 

homeowners who are at risk of losing their homes due to foreclosure.

5. Reduce vacancy rates. By September 30, 2013 reduce the average 

residential vacancy rate in 70 percent of the neighborhoods hardest 

hit by the foreclosure crisis relative to comparable areas. Hardest hit 

neighborhoods are defined as Neighborhood Stabilization Program 

(NSP) 2 Neighborhood Investment Clusters (NIC).1

6. Reducing homelessness. By September 30 2013, in partnership with 

the VA, reduce the number of homeless veterans to 35,000 by serving 

 

1

NSP provides grants to states and local governments, and other organizations to try to 

reduce the number of foreclosed and abandoned properties and restore depressed local 

housing markets. The first phase of this program, NSP 1, was authorized by the Housing 

and Economic Recovery Act of 2008, Pub. L. No. 110-289, 122 Stat. 2654 (2008), which 

provided $3.92 billion in grant funds. The American Recovery and Reinvestment Act of 

2009, Pub. L. No. 111-5, 123 Stat. 115 (2009) provided an additional $2 billion in NSP 

funds (referred to as NSP 2) and changed several aspects of the program. Later, the Wall 

Street Reform and Consumer Protection Act, Pub. L. No. 111-203, 124 Stat. 1376 (2010) 

(Dodd-Frank Act), provided an additional $1 billion in funding for the program (referred to 

as NSP 3). NICs are geographic areas with a concentration of properties to which NSP 

funds have been applied. 

Appendix III: Comments on the Department 

of Housing and Urban Development’s Priority 

Goals
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

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Page 55 GAO-13-174 Agency Priority Goals

35,500 additional homeless veterans. HUD is also committed to 

making progress towards reducing family and chronic homelessness 

and is working towards milestones to allow for tracking of these 

populations.

For each goal, we also identify our related past reports and provide an 

update on the status of any open recommendations and matters for 

congressional consideration that we previously made related to the goal. 

We also identify a GAO contact for our work related to each goal.

Improve program effectiveness by awarding funds fairly and quickly. By 

September 30, 2013, HUD will improve internal processes to ensure that 

HUD can obligate 90 percent of NOFA programs within 180 calendar 

days from budget passage, ensuring that America’s neediest families 

have the shelter and services they need, when they need them. The 

timely obligation and subsequent disbursement of funds will positively 

impact the agency’s ability to achieve all of its priority goals.

Although we have not conducted an in-depth analysis of HUD’s NOFA 

processes, our recent work and a recent bid protest decision highlight 

some of the challenges HUD has faced when trying to award funds 

quickly and the importance of using appropriate processes to award 

funds. In our bimonthly reviews of selected states’ and localities’ use of 

funds made available under the American Recovery and Reinvestment 

Act of 2009 (Recovery Act), we commented on the NOFA process HUD 

used to award nearly $1 billion in public housing capital funds to public 

housing agencies based on competition for priority investments, including 

investments that leveraged private sector funding or financing for 

renovations and energy conservation retrofit investments. In September

2009, we reported that HUD had received almost 1,800 applications for 

the funds and that its review process had been slower than expected. 

According to HUD officials, this was due to the number of applications 

with lengthy narratives needing review. Further, HUD officials stated that 

their staff were reviewing these applications while carrying out their 

ongoing responsibilities related to managing the public housing capital 

fund program. Despite these challenges, we reported in December 2009 

that HUD had met the Recovery Act requirement to obligate all of the 

funds to public housing agencies by September 30, 2009. Specifically, 

HUD accepted applications from June 22 to August 18, 2009, and 

according to a HUD official, 746 housing agencies submitted 1,817 

applications for these competitive grants. In September 2009, HUD 

Goal Statement

GAO Comments 
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 56 GAO-13-174 Agency Priority Goals

awarded 396 competitive grants to housing agencies that successfully 

addressed the NOFA requirements. 

In addition, a recent bid protest decision highlights the importance of 

using appropriate processes to award funds regardless of the time 

involved. On August 15, 2012, we concluded that HUD’s use of a NOFA 

that resulted in the issuance of a cooperative agreement to obtain 

services for the administration of Project-Based Section 8 Housing 

Assistance Payment contracts was improper because the “principal 

purpose” of the NOFA was to obtain contract administration services for 

HUD’s direct benefit and use, which should be acquired under a 

procurement instrument that results in the award of a contract. 

In our August 15, 2012, bid protest decision, we recommended that HUD 

cancel the NOFA and solicit the contract administration services for the 

Project-Based Section 8 rental assistance program through a 

procurement instrument that would result in the award of contracts. In its 

response, HUD informed us of its intention to proceed with the NOFA and 

of its plan to make awards. However, as a result of litigation filed in the 

Court of Federal Claims that sought to enjoin it from proceeding with the 

NOFA, HUD announced its agreement not to make the awards until the 

court rules on the matter. As of March 2013, the court had not yet issued 

its decision. 

Assisted Housing Services Corporation; North Tampa Housing 

Development Corporation; The Jefferson County Assisted Housing 

Corporation; National Housing Compliance; Southwest Housing 

Compliance Corporation; CMS Contract Management Services and the 

Housing Authority of the City of Bremerton; Massachusetts Housing 

Finance Agency. B-406738 et al. August 15, 2012.

Recovery Act: Status of States’ and Localities’ Use of Funds and Efforts 

to Ensure Accountability. GAO-10-231. Washington, D.C.: December 10, 

2009.

Recovery Act: Funds Continue to Provide Fiscal Relief to States and 

Localities, While Accountability and Reporting Challenges Need to Be 

Fully Addressed. GAO-09-1016. Washington, D.C.: September 23, 2009.

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 57 GAO-13-174 Agency Priority Goals

Mathew J. Scirè, Director, Financial Markets and Community Investment, 

sciremj@gao.gov, (202) 512-8678.

Increase the energy efficiency and health of the nation’s housing stock. 

By September 30, 2013, HUD will enable a total of 159,000 cost effective 

energy efficient or healthy housing units, as part of a joint HUD-DOE goal 

of 520,000 in 2012 to 2013 and a total goal of 1.2 million units from 2010 

through 2013. 

Energy-efficient green building practices can increase up-front costs but 

also may provide long-term financial, environmental, and health benefits. 

In prior work, we credit HUD for using accepted energy-efficient green 

building standards developed by others, such as the Environmental 

Protection Agency’s (EPA) Energy Star program and the Enterprise 

Green Communities, as criteria for measuring progress toward its goal.

2

For example, in October 2008, we found that while HUD’s public housing 

office had shown leadership and initiative in partnering to develop a 

benchmarking tool that could be used to identify properties with high 

levels of utility consumption, HUD’s multifamily assisted housing had no 

such tool. In the absence of such a tool, HUD cannot target certain 

multifamily properties for green building improvements, which could result 

in benefits that include reduced resource consumption. In April 2013, 

HUD officials told us that they were collaborating with other federal 

agencies and industry partners to develop such a tool for its multifamily 

portfolio. 

These standards are generally recognized as effective measures of 

increased energy efficiency. However, our prior work also found that HUD 

could do more to promote energy efficiency.

Our October 2008 report also identifies ways that HUD could better meet 

its priority goal for cost-effective energy-efficient measures, particularly for 

water conservation. HUD officials we interviewed identified water 

conservation savings as significant and among the biggest potential 

 

2

Enterprise Green Communities has been identified as a national green building standard 

designed specifically for low-income housing developments. The program is administered 

by Enterprise Community Partners, a nonprofit organization that provides expertise for 

affordable housing and sustainable communities. 

GAO Contact

Goal Statement

GAO Comments
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 58 GAO-13-174 Agency Priority Goals

opportunities for financial savings, but HUD had provided few incentive 

points for water conservation or indoor air quality measures in its 

competitive grant programs. Since our report, a number of HUD programs 

have added water savings devices to requirements for new construction 

and rehabilitation projects. In addition, the Interagency Rental Policy 

Working Group, which includes HUD, USDA, and Treasury, has adopted 

requirements for water saving products and energy star appliances for 

rehabilitation projects. 

As stated above, HUD’s priority goal is a portion of a larger HUD-DOE 

joint goal. DOE’s weatherization assistance program is one of the largest 

residential energy-efficiency programs in the nation and some DOE 

weatherization grantees also received HUD assistance. HUD officials told 

us that DOE grantees do not report which weatherization recipients 

received HUD assistance and HUD grantees are not required to report to 

HUD whether they received weatherization assistance. Consequently, 

double counting could occur, although HUD indicated that the likelihood 

of such double-counting is small. In October 2012, HUD officials told us 

that they were planning to use the results of a DOE evaluation of its 

weatherization program to identify any double counting and, if necessary, 

revise the overall HUD-DOE totals reported previously for 2009 and 2010. 

In April 2013, HUD officials told us that the data collection portion of 

DOE’s evaluation was complete and they were awaiting the results from 

DOE. 

We recommended in October 2008 that HUD ensure the completion of 

the regulation that would require the use of energy-efficient products and 

appliances for public housing as directed by the Energy Policy Act of 

2005. HUD included the statutory requirement in a proposed rule 

published in February 2011, but as of March 2013, HUD had not 

published the final rule. 

We also recommended in October 2008 that HUD work with DOE to 

expeditiously implement energy-efficiency updates to the HUD 

manufactured housing code. Although manufactured housing is not part 

of HUD’s agency priority goal, we believe that energy-efficiency efforts in 

this area are directly related to the goal. Manufactured housing is an area 

in which HUD has significant influence because it has been responsible 

for establishing manufactured building code requirements since 1974. We 

found that HUD had not made significant energy efficiency updates to 

code for this program since 1994. HUD officials told us that pursuant to 

the requirements of the Energy Independence and Security Act of 2007 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 59 GAO-13-174 Agency Priority Goals

which moved responsibility for promulgating manufactured energy 

efficiency standards to DOE, they intended to wait to make energyefficiency updates to the code because they were concerned about 

overlapping agency responsibilities between DOE and HUD. We 

concluded in October 2008 that waiting to take action could result in years 

more of some manufactured homes being built without improved energy 

standards. HUD has worked with DOE in developing more stringent 

energy standards for manufactured homes. For example, in February 

2010, DOE published an advance notice of proposed rulemaking on 

energy efficient standards for manufactured homes pursuant to the 2007 

Act and HUD officials told us that they met with DOE on the proposal. 

Until the rule is finalized, HUD and DOE will continue to miss an 

opportunity to improve the energy efficiency of manufactured housing 

units. 

Additionally, in October 2008 we recommended that HUD work with 

DOE’s Oak Ridge National Laboratory and EPA to develop a utility 

benchmarking tool for multifamily properties. We pointed out that HUD’s 

public housing office had shown leadership and initiative in partnering to 

develop a utility benchmarking tool that could be used to identify 

multifamily properties with high levels of utility consumption, and that 

HUD’s multifamily assisted housing could benefit from a similar tool that 

would allow properties to be targeted for green building improvements. In 

October 2012, HUD officials told us that Oak Ridge’s data tool is now out 

of date. They added that HUD was actively working with DOE, EPA, 

Fannie Mae, and industry representatives on a strategy to develop 

common data inputs and reporting standards for multifamily properties 

that could lead to a multifamily benchmarking tool. In April 2013, HUD 

officials told us that they are working to develop a multifamily energy star 

benchmark that will provide information on building performance on a 

portfolio basis. However, it is not clear when HUD intends to complete its 

energy start benchmark. Until such a tool is in place and HUD is able to 

benchmark utility costs in its multifamily portfolio, HUD will continue to 

miss opportunities to target less-efficient multifamily properties for green 

building improvements, and reduce resource consumption and utility 

expenses for itself and its funding recipients. 

In November 2011 we recommended that DOE, HUD, and EPA lead an 

effort to collaborate with other agencies to identify performance 

information, such as shared goals and common performance measures, 

for green building initiatives for the nonfederal sector. About one-third of 

the 94 initiatives we identified have goals and performance measures 

specific to green building and about two-thirds do not; therefore the 
Appendix III: Comments on the Department of 

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Goals

Page 60 GAO-13-174 Agency Priority Goals

results of most initiatives and their related investments in green building 

are unknown. DOE, HUD, and EPA generally agreed with the 

recommendation. In November 2012, HUD officials stated that they had 

met with EPA and DOE representatives to review our recommendation. 

The agencies generally agreed that initiatives that show potential for 

collaboration would be best served through existing interagency 

partnerships. HUD stated that the agencies might explore a higher level 

of centralized collaboration for the long term, but such efforts would 

require additional legislative or executive authority to implement. 

In October 2012, we found that key standards for manufactured homes 

provide a lower margin of safety against a carbon monoxide exposure 

incident than those for site built homes. We found that HUD’s ventilation 

standards establish standards for airflow, not air quality, and 

recommended that HUD test the performance of its installed ventilation 

systems and reassess its ventilation standards. Measuring the actual 

airflow achieved by installed ventilation systems would not only permit 

HUD to know whether its standards are being met, but also permit HUD 

to better understand the potential impact ventilation systems may have on 

indoor air quality and the overall health of the homes. HUD generally 

agreed with both recommendations and stated that it would bring them 

before the Manufactured Housing Consensus Committee, which is 

responsible for recommending proposed rules to HUD, for consideration. 

Manufactured Housing Standards: Testing and Performance Evaluation 

Could Better Ensure Safe Indoor Air Quality. GAO-13-52. Washington, 

D.C.: October 24, 2012.

2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue. 

GAO-12-342SP. Washington, D.C.: February 28, 2012.

Green Building: Federal Initiatives for the Nonfederal Sector Could 

Benefit from More Interagency Collaboration. GAO-12-79. Washington, 

D.C.: November 2, 2011.

Green Affordable Housing: HUD Has Made Progress in Promoting Green 

Building, but Expanding Efforts Could Help Reduce Energy Costs and 

Benefit Tenants. GAO-09-46. Washington D.C.: October 7, 2008.

Selected GAO Reports
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 61 GAO-13-174 Agency Priority Goals

William B. Shear, Director, Financial Markets and Community Investment, 

shearw@gao.gov, (202) 512-8678.

Frank Rusco, Director, Natural Resources and Environment, 

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

Preserve affordable rental housing. By September 30, 2013, preserve 

affordable rental housing by continuing to serve 5.4 million families and 

serve an additional 61,000 families through HUD’s affordable rental 

housing programs. 

HUD’s efforts to achieve this goal involve several HUD programs 

including the housing choice voucher, public housing, and project-based 

programs, which are HUD’s key programs for delivering rental 

assistance.3

HUD has implemented recommendations we made in April 2007 to help 

enhance HUD’s ability to keep project-based property owners in the 

program. Specifically, we found that although HUD offered several 

incentives to keep property owners in the program, some property 

owners, managers, and industry representatives cited concerns with 

certain HUD policies and practices, especially the one-to-one 

replacement policy (which prohibited reductions in the total number of 

program units in a property when a contract was renewed), and the 

reimbursement process for operating costs in high cost areas. In 2011, 

HUD modified this policy and revised the way it calculates reimbursement 

for operating costs. We also found that between 2001 and 2005 owners 

renewed 92 percent of contracts and 95 percent of units covered by these 

contracts. Property owners, managers, and industry representatives with 

whom we spoke as part of our April 2007 report indicated that market 

Our past work on these programs has identified a number of 

factors that could impact HUD’s ability to meet this goal including the 

department’s ability to keep property owners in the project-based program 

and serve additional households. 

 

3

Vouchers assist households in paying rent for units of their choice in the private market, 

while public housing and project-based programs assist households by subsidizing the 

rents of specifically designated units. These programs generally serve low-income 

households—those with incomes that are 80 percent or less of their local area median 

incomes.

GAO Contacts

Goal Statement

GAO Comments
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 62 GAO-13-174 Agency Priority Goals

conditions were the primary factors in owners’ decisions to leave or 

remain in the program. Similarly, HUD has implemented a 

recommendation we made in November 2005 to address late housing 

assistance payments to landlords, which may encourage owners to 

participate in HUD’s project-based program. Specifically, in 2007 HUD 

made improvements to its data, including verifying information on contract 

renewal dates and project costs, which should help the department more 

reliably determine the timing and amount of funding needed by the 

landlords, thereby improving the timeliness of its payments. 

Our work has also identified certain factors that could enhance HUD’s 

ability to meet its goal to preserve affordable rental housing. For instance, 

our March 2012 report on the housing choice voucher program identified 

potential areas that, if implemented, could help HUD reach more renter 

households. Specifically, excess reserves in the voucher program could 

be used to serve additional families, if authorized by Congress. In 

addition, certain rent reform options (that is, changes to the calculation of 

households’ payment toward rent) may allow HUD to serve more people. 

For example, if implemented, rent reform could reduce the federal cost 

burden—in some cases, quite considerably—or if Congress chose to 

reinvest cost savings in the program, allow the program to serve between 

1,400 to 287,000 additional households, depending on which rent reform 

option was implemented. 

We also noted that HUD could do more to ensure that certain housing 

agencies continue to serve households. Specifically, our April 2012 report 

found that HUD may not be able to systematically ensure that agencies 

participating in the Moving to Work (MTW) demonstration program are 

meeting the requirement to serve substantially the same number of 

households through their rental assistance programs that they would 

have been able to serve prior to participation.

4

 

4

The MTW program, among other purposes, is intended to give participating state and 

local housing agencies flexibility to design and test innovative strategies for providing 

housing assistance and achieving cost-effectiveness. 

As a result, the program 

may affect HUD’s ability to meet its goal of preserving affordable rental 

housing. We found that, contrary to internal control guidance, HUD did

not have a process in place to systematically review compliance with 

several program requirements, including the requirement to serve 

substantially the same number of households. We concluded that 

because Congress is considering expanding the program to many more 
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 63 GAO-13-174 Agency Priority Goals

housing agencies, the absence of information needed to conduct 

compliance reviews is significant. We further stated that without more 

complete knowledge of the extent to which agencies are adhering to 

program requirements, it is difficult for Congress to know whether an 

expanded MTW will benefit additional agencies and the residents they 

serve. 

More broadly, as part of our work on overlap, fragmentation, and 

duplication in federal programs, we reported in August 2012, that 

although selected HUD, USDA, and the Department of the Treasury 

(Treasury) rental housing programs had overlapping purposes, the 

agencies’ products, areas served, and delivery methods differed. 

Specifically, we found that although HUD is the only agency that has a 

specific priority goal to preserve affordable rental housing, seven of the 

nine selected HUD, USDA, and Treasury programs we reviewed have the 

shared purpose of financing the development of new rental units or 

preserving existing units through refinancing or rehabilitation. However, 

we found that five of these programs differ in terms of tenant and 

geographic eligibility. Additionally, we found that HUD and USDA 

administer project-based rental assistance programs, which provide rental 

subsidies to property owners that provide housing to low-income 

households. We reported that although HUD serves more households in 

rural areas, a large share of units with USDA’s rental assistance were in 

rural ZIP codes, while a smaller share of units with HUD rental assistance 

were in these areas. In addition, we also found that all three agencies 

have been working to consolidate and align requirements in rental 

housing programs through the Rental Policy Working Group.

5

 

5

In July 2010 the White House’s Domestic Policy Council established the interagency 

Rental Policy Working Group. The working group consists of the White House Domestic 

Policy Council, National Economic Council, OMB, HUD, USDA, and Treasury. The 

purpose of the working group is to better align rental requirements across programs, and 

thereby increase the effectiveness of federal rental policy and improve participant 

outcomes. 

We 

concluded that although its efforts have been consistent with many key 

collaborative practices, the group has not taken full advantage of 

opportunities to reinforce agency accountability for collaborative efforts 

through the agencies’ annual and strategic plans, or expanded its guiding 

principles to evaluate areas requiring statutory action to generate savings 

and efficiencies. 
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Goals

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In August 2012, we recommended that to further improve HUD, USDA, 

and Treasury’s efforts through the Rental Policy Working Group to 

consolidate and align certain requirements in multifamily housing 

programs, the Rental Working Group should take steps to document 

collaborative efforts in strategic and annual plans to help reinforce agency 

accountability for these efforts. HUD and USDA agreed with the 

recommendation. 

In April 2012, we recommended that the Secretary of the Department of 

Housing and Urban Development develop and implement a systematic 

process for assessing compliance with statutory requirements. In 

response to this recommendation, HUD stated that the agency had 

conducted an extensive effort that allowed it to monitor compliance with 

the requirement for agencies to continue assisting substantially the same 

total number of households that they would have been able to serve prior 

to participating in the MTW program. HUD further stated that it was 

testing implementation of the process and planned to formalize the 

process through the publication of a notice. On January 10, 2013, HUD 

issued a notice that describes a compliance effort that, according to HUD, 

will ensure that MTW agencies continue to meet the statutory obligation 

to serve substantially the same number of families as if they had not 

participated in the MTW demonstration.

6

In March 2012, we recommended that the HUD Secretary provide 

information to Congress on (1) housing agencies’ estimated amount of 

excess subsidy reserves and (2) HUD’s criteria for how it will redistribute 

excess reserves among housing agencies so that they can serve more 

households. In taking these steps, the Secretary should determine a level 

of subsidy reserves housing agencies should retain on an ongoing basis 

to effectively manage their voucher programs. HUD neither agreed nor 

disagreed with our recommendation. HUD noted that it currently provides 

quarterly reports to the Congressional Budget Office on subsidy reserve 

levels. However, these quarterly reports do not include information on the 

estimated amount of agencies’ subsidy reserves that exceed prudent 

levels. HUD did not comment on its efforts to provide information to 

Congress on the criteria for how it will redistribute excess reserves among 

According to the notice, HUD will 

use a numerical indicator to make annual determinations of compliance. 

 

6

See HUD, Notice PIH 2013-02 (HA), Baseline Methodology for Moving to Work Public 

Housing Agencies (Jan. 10, 2013). 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 65 GAO-13-174 Agency Priority Goals

agencies so it can serve more households. In March 2013, HUD officials 

told us that, upon request, they provide information to HUD’s 

Appropriations Committee on subsidy reserves levels, including those 

balances above certain minimum reserve levels. We will continue 

monitoring the agency’s progress in implementing our recommendations.

Housing Assistance: Opportunities Exist to Increase Collaboration and 

Consider Consolidation. GAO-12-554. Washington D.C.: August 16, 

2012.

Moving to Work Demonstration: Opportunities Exist to Improve 

Information and Monitoring. GAO-12-490. Washington D.C.: April 19, 

2012.

Housing Choice Vouchers: Options Exist to Increase Program 

Efficiencies. GAO-12-300. Washington D.C.: March 19, 2012.

Project-Based Rental Assistance: HUD Should Update Its Policies and 

Procedures to Keep Pace with the Changing Housing Market. 

GAO-07-290. Washington D.C.: April 11, 2007.

Project-Based Rental Assistance: HUD Should Streamline Its Processes 

to Ensure Timely Housing Assistance Payments. GAO-06-57. 

Washington D.C.: November 15, 2005.

Daniel Garcia-Diaz, Director, Financial Markets and Community 

Investment, garciadiazd@gao.gov, (202) 512-8678.

Prevent foreclosures. By September 30, 2013, assist 700,000 

homeowners who are at risk of losing their homes due to foreclosure.

HUD’s efforts to achieve this goal involve the Federal Housing 

Administration’s (FHA) early delinquency interventions and loss mitigation 

programs. However, our past work raised questions about whether FHA 

has collected and analyzed data to assess the effectiveness of these 

efforts in preventing redefaults. Further, the HUD IG raised questions 

about the extent to which certain efforts were conducted in accordance 

with program requirements. 

Selected GAO Reports

GAO Contacts

Goal Statement

GAO Comments:
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 66 GAO-13-174 Agency Priority Goals

In June 2012, we reported that millions of borrowers faced an elevated 

risk of foreclosure and that various indicators showed that the housing 

market remained weak. In particular, we noted that the serious 

delinquency rate for FHA loans increased in the second half of 2011, 

counter to trends in the broader market. We reported that FHA had been 

working with loan servicers to identify best practices for reaching 

borrowers and had reporting requirements for servicers throughout the 

delinquency process. However, we found that although FHA had begun to 

calculate redefault rates for specific home retention actions, it had not 

used this information to assess the effectiveness of its foreclosure 

mitigation efforts. Doing so is particularly important because FHA loan

modifications typically do not reduce borrower’s monthly payments to the 

levels that our analysis indicated result in more sustainable modifications. 

We also found that FHA had not assessed the impact of loan and 

borrower characteristics on the performance of its foreclosure mitigation 

efforts. In some cases, FHA did not have the data needed to conduct 

these analyses. 

In a September 2012 report, the HUD IG estimated that 11,693 

preforeclosure sales completed during the 12-month period it reviewed 

did not meet HUD’s requirements for participation and recommended that 

HUD strengthen controls over the preforeclosure sale program.

7

HUD has previously reported performance that exceeds its target for 

preventing foreclosures for fiscal years 2012 and 2013. During the period 

covering fiscal years 2010 and 2011, HUD reported assisting 902,431 

homeowners that were in danger of losing their homes to foreclosure—

496,197 through FHA early delinquency interventions and 406,234 

through FHA loss mitigation programs. For fiscal years 2012 and 2013, 

HUD anticipates meeting its foreclosure prevention goal by reaching 

500,000 homeowners with early delinquency interventions and an 

additional 200,000 through loss mitigation programs. Through the end of 

fiscal year 2012, HUD reported that it was more than halfway to meeting 

Preforeclosure sales are one type of FHA loss mitigation action included 

in HUD’s calculation of borrowers assisted. Including ineligible 

preforeclosure sales in the calculation of borrowers assisted could 

overstate foreclosure prevention efforts. 

 

7

HUD Office of Inspector General, FHA Paid Claims for Approximately 11,693 

Preforeclosure Sales that Did Not Meet FHA Requirements, 2012-KC-004 (Kansas City, 

KS: Sep. 18, 2012). 
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Housing and Urban Development’s Priority 

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its goal, having reached 290,216 homeowners with early delinquency 

interventions and 154,933 homeowners through loss mitigation programs. 

In June 2012, we recommended that FHA conduct periodic analyses of 

the effectiveness and the long-term costs and benefits of its loss 

mitigation strategies and actions. These analyses should consider (1) the 

redefault rates associated with each type of home retention action and (2) 

the impact that loan and borrower characteristics have on the 

performance of different home retention actions. FHA should use the 

results from these analyses to reevaluate its loss mitigation approach and 

provide additional guidance to servicers to effectively target foreclosure 

mitigation actions. If FHA does not maintain data needed to consider this 

information, it should require servicers to provide the data. In an August 

2012 response to our recommendations, HUD noted that it was 

performing a complete review of the structure of its home-retention 

assistance. HUD is also undertaking an analysis of borrower and loan 

data with the goal of proactively directing servicers as to which assistance 

actions should be targeted to particular borrowers. In November 2012, 

FHA issued Mortgagee Letter 2012-22, which contained changes to the 

requirements for servicers to follow when assessing borrowers for FHA 

loss mitigation home-retention options. We requested and plan to assess 

the analysis HUD completed as the basis for this change in FHA’s loss 

mitigation strategies to determine whether it fully responds to our 

recommendation. 

Foreclosure Mitigation: Agencies Could Improve Effectiveness of Federal 

Efforts with Additional Data Collection and Analysis, GAO-12-296. 

Washington, D.C.: June 28, 2012.

Mathew J. Scirè, Director, Financial Markets and Community Investment, 

sciremj@gao.gov, (202) 512-8678.

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports

GAO Contact
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 68 GAO-13-174 Agency Priority Goals

Reduce vacancy rates. By September 30, 2013 reduce the average 

residential vacancy rate in 70 percent of the neighborhoods hardest hit by 

the foreclosure crisis relative to comparable areas. Hardest hit 

neighborhoods are defined as Neighborhood Stabilization Program (NSP) 

2 Neighborhood Investment Clusters (NIC). 

HUD will apply the results of the second phase of its Neighborhood 

Stabilization Program (NSP 2), funded under the American Recovery and 

Reinvestment Act, towards achieving this agency priority goal.

8 The 

agency considers NSP, which provides grants to government and other 

entities to try to reduce the number of foreclosed and abandoned 

properties, its primary tool for mitigating the effects of foreclosures on 

neighborhoods.

9

 

8

On Performance.gov, HUD also lists the efforts of FHA’s Office of Single Family Housing 

and the National Community Stabilization Trust to facilitate the acquisition of certain 

foreclosed properties by Neighborhood Stabilization Program grantees as contributing to 

this agency priority goal. The National Community Stabilization Trust was formed through 

collaboration between Enterprise Community Partners, the Housing Partnership Network, 

the Local Initiatives Support Corporation, National Council of La Raza, National Urban 

League, and NeighborWorks America. 

As we reported in November 2011, high foreclosure 

rates have contributed to increased vacancies, which can impose 

additional costs and challenges on communities, including increased 

public safety costs and lower tax revenues. While we have not directly 

assessed HUD’s capacity to achieve this agency priority goal, our prior 

work evaluating NSP indicates that through this program, HUD has the 

potential to reduce vacancies in areas receiving NSP funding. In 

December 2010, we examined HUD’s implementation of the first phase of 

NSP and grantees’ compliance with program requirements in using their 

funds to mitigate the impacts of foreclosures, which can include increased 

vacancies. We found that HUD and grantees had taken actions to try to 

9

The Neighborhood Stabilization Program (NSP) provides grants to states and local 

governments, and other organizations to try to reduce the number of foreclosed and 

abandoned properties and restore depressed local housing markets. The first phase of 

this program, NSP 1, was authorized by the Housing and Economic Recovery Act of 2008, 

Pub. L. No. 110-289, 122 Stat. 2654 (2008), which provided $3.92 billion in grant funds. 

The American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, 123 Stat. 115 

(2009) provided an additional $2 billion in NSP funds (referred to as NSP 2) and changed 

several aspects of the program. Later, the Wall Street Reform and Consumer Protection 

Act, Pub. L. No. 111-203, 124 Stat. 1376 (2010) (Dodd-Frank Act), provided an additional 

$1 billion in funding for the program (referred to as NSP 3). NICs are geographic areas 

with a concentration of properties to which NSP funds have been applied. 

Goal Statement

GAO Comments
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 69 GAO-13-174 Agency Priority Goals

ensure program compliance. While three phases of NSP were authorized 

by different pieces of legislation, all three rounds of NSP generally follow 

the same requirements. Therefore our previous findings are applicable to 

NSP 2, the contributing program to this agency priority goal. 

Through its NSP technical assistance program, HUD has hired The 

Reinvestment Fund (TRF) to conduct analyses of NSP investments 

across the United States.

10 HUD is using aspects of this analysis to 

measure progress toward meeting this agency priority goal. As part of its 

quarterly studies, TRF is conducting analysis of trends in vacancy rates 

within NICs versus comparable areas (or neighborhoods).

11 NICs are 

geographic areas with a concentration of properties to which NSP funds 

have been applied. On the Performance.gov website, HUD uses “NIC” to 

refer to those areas to which NSP 2 funds have been applied. For both 

the first and second quarter of 2012, HUD reported that about 78 percent 

of NICs had lower vacancy rates than at least one comparable area—

outperforming the agency priority goal’s target of 70 percent.

12

We have not assessed the reliability of TRF’s studies. However, in its 

analysis, TRF uses data from HUD’s Disaster Recovery Grant Reporting 

(DRGR) system, the information system used by all NSP grantees to 

report on their activities and results. In December 2010, we reported that 

inconsistencies in the manner in which grantees entered data into DRGR 

could complicate the analysis of program outputs and result in over

counting and under counting of program outputs. We recommended that 

HUD take several actions to improve the consistency of the data collected 

from NSP grantees. In October 2012, HUD addressed these 

recommendations by issuing detailed guidance. For the purposes of 

 

10The American Recovery and Reinvestment Act of 2009 authorized the NSP technical 

assistance program. In August 2009, HUD awarded $50 million in technical assistance 

grants to providers to help train NSP grantees as well as measure outcomes from the use 

of public funds, among other goals. The Reinvestment Fund is a subcontractor for one of 

HUD’s NSP technical assistance providers. 

11Comparable markets are at least 0.125 miles away from any Neighborhood Investment 

Cluster and that have similar characteristics in terms of housing prices, homeownership 

rates, and risks of foreclosures (as estimated by HUD). They may include one property 

that has received NSP funding. 

12In order to compare vacancy rate changes, The Reinvestment Fund used vacancy rates 

in the first half of 2011 and compared them to the vacancy rates in the first half of 2008. 

The vacancy rate data was provided to HUD via an agreement with the U.S. Postal 

Service. 
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 70 GAO-13-174 Agency Priority Goals

measuring progress towards this goal, TRF uses property address 

information from DRGR for units that received NSP 2 funding. Quarterly, 

HUD standardizes and removes duplicate address information from 

DRGR to try to prevent any double counting of properties in TRF’s 

analyses. 

We currently have no open recommendations or matters for 

congressional consideration related to this priority goal.

Vacant Properties: Growing Number Increases Communities’ Costs and 

Challenges. GAO-12-34. Washington, D.C.: November 4, 2011.

Neighborhood Stabilization Program: HUD and Grantees Are Taking 

Actions to Ensure Program Compliance but Data on Program Outputs 

Could be Improved. GAO-11-48. Washington, D.C.: December 17, 2010.

Mathew J. Scirè, Director, Financial Markets and Community Investment, 

sciremj@gao.gov, (202) 512-8678.

Reducing homelessness. By September 30 2013, in partnership with the 

VA, reduce the number of homeless veterans to 35,000 by serving 35,500 

additional homeless veterans. HUD is also committed to making progress 

towards reducing family and chronic homelessness and is working 

towards milestones to allow for tracking of these populations. 

HUD notes that several programs are expected to contribute to the 

achievement of its priority goal to reduce homelessness, including the 

HUD Veterans Affairs Supportive Housing (HUD-VASH) program, HUD 

homeless assistance programs, and the Homelessness Prevention and 

Rapid Re-Housing Program.

13

 

13The Homelessness Prevention and Rapid Re-Housing Program was funded under the 

American Recovery and Reinvestment Act of 2009. Program grantees had to expend 100 

percent of their funds 3 years after the date HUD signed the grantee’s grant agreement in 

2009. 

Our past work has identified a number of 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports

GAO Contact

Goal Statement

GAO Comments
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 71 GAO-13-174 Agency Priority Goals

issues related to these programs. For example, our June 2012 report on 

the HUD-VASH program—a collaborative initiative between HUD and VA 

that targets the most vulnerable, most needy, and chronically homeless 

veterans—states that the program has moved veterans out of 

homelessness. Specifically, according to VA, as of March 2012, nearly 

31,200 veterans lived in HUD-VASH supported housing, which represents 

about 83 percent of the vouchers authorized under the program.

14

Our May 2012 report on the fragmentation, overlap, and duplication 

among federal homelessness programs also identified issues related to 

the programs that are expected to contribute to the achievement of this 

priority goal. For example, our report noted HUD was one of eight federal 

agencies that administered 26 targeted homelessness programs in fiscal 

year 2011, suggesting fragmentation and some overlap among these 

programs.

In 

addition, our December 2011 report on homeless women veterans notes 

that although HUD collects data on homeless women and on homeless 

veterans, the department does not collect detailed information on 

homeless women veterans and neither HUD nor VA captures data on the 

overall population of homeless women veterans. Further, our report 

states that HUD and VA lack data on the characteristics and needs of 

these women on a national, state, and local level. Finally, our report notes 

that absent more complete data on homeless women veterans, VA does 

not have the information needed to plan services effectively, allocate 

grants to providers, and track progress toward its overall goal of ending 

veteran homelessness. 

15

 

14More recent data reported by VA shows that over 39,200 veterans lived in HUD-VASH 

supported housing as of November 28, 2012, about 82 percent of the vouchers supported 

under the program at the time. 

More specifically, HUD not only administers programs that 

fund housing assistance, but also provides funding for mental health care, 

substance abuse treatment, and employment services. Similarly, HHS 

and VA administer programs that provide housing and employment 

assistance. Fragmentation and overlap can lead to inefficient use of 

resources. Some local service providers told us that managing multiple 

applications and reporting requirements was burdensome, difficult, and 

costly. Moreover, according to providers, persons experiencing 

15The Departments of Education, HHS, Labor, Justice, VA, FEMA, and the General 

Services Administration also administered targeted homelessness programs in fiscal year 

2011—those that exclusively assisted persons who were homeless or at risk for 

homelessness. 
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 72 GAO-13-174 Agency Priority Goals

homelessness have difficulties navigating services that are fragmented 

across agencies. Further, our report states that limited information exists 

about the efficiency or effectiveness of targeted homelessness programs 

because evaluations have not been conducted recently—including for the 

six programs HUD administers. Finally, our report states that the U.S. 

Interagency Council on Homelessness (Interagency Council) strategic 

plan to prevent and end homelessness has served as a useful and 

necessary first step in increasing agency coordination and focusing 

attention on ending homelessness; however, the plan lacks key 

characteristics desirable in a national strategy.

16 For example, the plan 

does not list priorities or milestones and does not discuss resource needs 

or assign clear roles and responsibilities to federal partners. 

In May 2012, we recommended that the Interagency Council and the 

Office of Management and Budget, in conjunction with the Secretaries of 

HHS, HUD, Labor, and VA, should consider examining inefficiencies that 

may result from overlap and fragmentation in their programs for persons 

experiencing homelessness. VA agreed with this recommendation. HHS, 

HUD, Labor, and the Interagency Council did not explicitly agree or 

disagree. We also recommended that to help prioritize, clarify, and refine 

efforts to improve coordination across agencies, and improve the 

efficiency and effectiveness of federal homelessness programs, the 

Interagency Council, in consultation with its member agencies, should 

incorporate additional elements into updates to the national strategic plan 

or other planning and implementation documents to help set priorities, 

measure results, and ensure accountability. According to the Interagency 

Council, its fiscal year 2013 report will focus on updates and progress 

made on the national strategic plan’s objectives. The Interagency 

Council’s national strategic plan broadly describes the federal approach 

to preventing and ending homelessness; however, until the key member 

agencies fully implement their plans, including setting priorities, 

measuring progress and results, and holding federal and nonfederal 

partners accountable, they are at risk of not reaching their goal of ending 

 

16The members of the Interagency Council are from the Departments of Agriculture, 

Commerce, Defense, Education, Energy, Health and Human Services, Homeland 

Security, Housing and Urban Development, Interior, Justice, Labor, Transportation, and 

Veterans Affairs; Corporation for National and Community Service; General Services 

Administration; Office of Management and Budget; Social Security Administration; U.S. 

Postal Service; and the White House Office of Faith-Based and Community Initiatives 

(now known as the White House Office of Faith-Based and Neighborhood Partnerships. 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix III: Comments on the Department of 

Housing and Urban Development’s Priority 

Goals

Page 73 GAO-13-174 Agency Priority Goals

veteran and chronic homelessness by 2015, and ending homelessness 

among children, youth, and families by 2020. 

In December 2011, we recommended that in order to help achieve the 

goal of ending homelessness among veterans, the Secretaries of HUD 

and VA should collaborate to ensure appropriate data are collected on 

homeless women veterans, including those with children and those with 

disabilities, and use these data to strategically plan for services. In 

concurring with this recommendation, VA stated it had several initiatives 

already planned or under way to gather information on those homeless 

women veterans who are in contact with VA, including the development of 

a more streamlined and comprehensive data collection system. In April

2013, VA stated that it had taken additional actions to inform policy and 

operational decisions about homeless and at-risk women veterans. For 

example, VA stated that in 2013 it worked with HUD to ensure that 

gender specific data were collected during the 2013 Point in Time count 

of homeless persons. VA added that the results of the 2013 Point in Time

count will be included in the Annual Homeless Assessment Report to 

Congress which will be published later in 2013 and will be used by the 

department to strategically plan and implement services for all homeless 

and at-risk veterans, including women veterans. In addition, VA stated 

that in 2012 it revised the Community Homelessness Assessment, Local 

Education and Networking Groups survey to capture gender specific data 

for homeless veterans to better identify the needs of women veterans and 

influence service provision.

17

Veteran Homelessness: VA and HUD Are Working to Improve Data on 

Supportive Housing Program. GAO-12-726. Washington, D.C.: June 26, 

2012.

Homelessness: Fragmentation and Overlap in Programs Highlight the 

Need to Identify, Assess, and Reduce Inefficiencies. GAO-12-491. 

Washington, D.C.: May 10, 2012.

 

17According to VA, the purpose of the Community Homelessness Assessment, Local 

Education and Networking Groups survey is to enhance the continuum of services for

homeless veterans provided by local VA health care facilities and the surrounding 

community service agencies, which helps VA work closely with local communities to 

identify needed services and then deliver the full spectrum of needed services to help 

homeless veterans reach their potential. 

Selected GAO Reports
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Housing and Urban Development’s Priority 

Goals

Page 74 GAO-13-174 Agency Priority Goals

Homeless Women Veterans: Actions Needed to Ensure Safe and 

Appropriate Housing. GAO-12-182. Washington, D.C.: December 23, 

2011.

Homelessness: A Common Vocabulary Could Help Agencies Collaborate 

and Collect More Consistent Data. GAO-10-702. Washington, D.C.: June 

30, 2010.

Alicia Puente Cackley, Director, Financial Markets and Community 

Investment, cackleya@gao.gov, (202)512-8678.

GAO Contact
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 75 GAO-13-174 Agency Priority Goals

Based on our past work, as well as that of the DOT IG, we commented on 

each of DOT’s four priority goals for 2012 to 2013:

1. Air traffic control systems can improve the efficiency of airspace. By 

September 30, 2013, replace a 40-year-old computer system serving 

20 air traffic control centers with a modern, automated system that 

tracks and displays information on high altitude planes.

2. Advance the development of passenger rail in the United States. By 

September 30, 2013, initiate construction on all 7 high speed rail 

corridors and 36 individual high speed rail projects.

3. Reduce risk of aviation accidents. By September 30, 2013, reduce 

aviation fatalities by addressing risk factors both on the ground and in 

the air. Commercial aviation (i.e. airlines): Reduce fatalities to no 

more than 7.4 per 100 million people on board. General aviation (i.e. 

private planes): Reduce fatal accident rate per 100,000 flight hours to 

no more than 1.06.

4. Reduce the rate of roadway fatalities. Reduce the rate of roadway 

fatalities from 1.26 in 2008 to 1.03 per 100 million vehicle miles 

traveled by December 31, 2013.

For each goal, we also identify our related past reports and provide an 

update on the status of any open recommendations and matters for 

congressional consideration that we previously made related to the goal. 

We also identify a GAO contact for our work related to each goal.

Air traffic control systems can improve the efficiency of airspace. By 

September 30, 2013, replace a 40-year-old computer system serving 20 

air traffic control centers with a modern, automated system that tracks 

and displays information on high altitude planes.

The priority goal refers to the Federal Aviation Administration’s (FAA) 

replacement of the existing en route air traffic control automation system 

used in its en route air traffic control centers (centers) with a new system 

architecture, the En Route Automation Modernization system (ERAM). 

While our previous work has shown that FAA has experienced delays in 

deploying ERAM, FAA has since made progress toward achieving this 

goal. As we reported in September 2012, FAA has experienced delays in 

deploying ERAM, which affected overall acquisition and maintenance 

costs as well as time frames for other programs. Specifically, the ERAM 

program is almost 4 years behind its original schedule and about $330 

Appendix IV: Comments on the Department 

of Transportation’s Priority Goals

Goal Statement

GAO Comments
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 76 GAO-13-174 Agency Priority Goals

million, or about 15 percent, over its original budget because of the 

following factors:

• unanticipated risks associated with operational complexities at the 

field sites,

• insufficient testing to identify software issues before deployment at the 

field sites,

• insufficient communication between the program office and field sites, 

and

• insufficient stakeholder (e.g., air traffic controller) involvement during 

system development and deployment.

The delays added an estimated $18 million per year to the costs of 

maintaining the system that ERAM was meant to replace.

Since new budget and schedule baselines for the ERAM program were 

established in June 2011, according to FAA reports, the program has 

made progress toward its goal of initial operating capability of ERAM by 

September 30, 2013. As of March 2013, FAA had achieved initial 

operating capability at 16 out of 20 centers and expects to achieve this 

goal. In September 2012, the DOT IG reported that FAA’s use of initial 

operating capability for tracking progress with ERAM gave FAA decision

makers a false sense of confidence in the maturity of the system when in 

reality, much work and time still remained in implementing the system.

For example, after FAA declared its first two sites as achieving initial 

operating capability, these sites experienced multiple failures after the 

milestone was achieved and went through a measured transition from 

limited operations to eventual continuous operations. In response to the 

DOT IG’s recommendation to better define key milestones to reflect 

progress, FAA is planning to establish criteria for entrance and exit at the 

various key milestones, including initial operating capability. FAA also 

plans to have all 20 centers operationally ready by August 2014.

As we reported in September 2012, looking more broadly, ERAM is 

considered to be the backbone that will support the Next Generation Air 

Transportation System (NextGen)—a new air traffic management system 

that will replace the current radar-based system and is expected to 

enhance the safety and capacity of the air transport system—and delays 

with ERAM’s deployment illustrate challenges FAA faces in implementing 

NextGen. For example, delays in ERAM affected the implementation of 

two other key NextGen acquisitions—Data Communications and System 

Wide Information Management. In part because of ERAM’s delay, FAA 

pushed the Data Communications program’s start date from September 
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Transportation’s Priority Goals

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2011 to May 2012, revised the original plan for the first System Wide 

Information Management segment, and delayed the start date for another 

segment from 2010 to July 2012. The implementation of NextGen—both 

in the midterm (through 2020) and in the long term (beyond 2020)—will 

be affected by how well FAA manages these and other program 

interdependencies.

To address past issues with cost estimate and schedule accuracy, such 

as those with ERAM, in February 2012, we recommended that when 

appropriate for major acquisition programs based on a program’s cost, 

schedule, complexity, and risk, FAA

• conduct an assessment of major acquisition programs to ensure they 

meet all of the established best practices for cost estimates and 

schedules contained in our guidance;

• require a fully integrated master schedule for each major acquisition 

program, including those that are NextGen components; and

• conduct independent cost estimates and schedule risk analysis.

As of March 2013, FAA has taken steps to implement these 

recommendations. For example, according to FAA officials, FAA’s 

Acquisition Executive Board now considers whether an independent cost 

estimate or schedules risk analysis is advisable as parts of its program 

review. FAA is also developing an Integrated Master Schedule for the 

entire NextGen initiative that is, in part, intended to show how changes in 

program schedules affect other programs and the timelines for the 

NextGen initiative as a whole. To further strengthen schedule integration, 

FAA plans to continue populating the integrated master schedule and 

then begin integrating this tool with other FAA planning tools, including 

the National Airspace System Enterprise Architecture and NextGen 

Implementation Plan, in December 2013.

Next Generation Air Transportation System: FAA Faces Implementation 

Challenges. GAO-12-1011T. September 12, 2012. 

Air Traffic Control Modernization: Management Challenges Associated 

with Program Costs and Schedules Could Hinder NextGen 

Implementation. GAO-12-223. February 16, 2012. 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 78 GAO-13-174 Agency Priority Goals

NextGen Air Transportation System: FAA’s Metrics Can Be Used to 

Report on Status of Individual Programs, but Not of Overall NextGen 

Implementation or Outcomes. GAO-10-629. July 27, 2010. 

Gerald L. Dillingham, Ph.D., Director, Physical Infrastructure Issues, 

dillinghamg@gao.gov, (202) 512-2834.

Advance the development of passenger rail in the United States. By 

September 30, 2013, initiate construction on 7 high speed rail corridors 

and 36 individual high speed rail projects.

While our past work does not cover activities related to construction of 

high speed rail projects, we and the DOT IG have reported on planning 

and other weaknesses with the Federal Railroad Administration’s (FRA) 

High Speed Intercity Passenger Rail (HSIPR) program related to FRA’s 

capacity to achieve this APG. The federal government had not historically 

had a strong leadership role in intercity passenger rail but this changed in 

2009 when the HSIPR program was authorized.1 The program provides 

grants to states and other entities to develop high speed intercity 

passenger rail corridors and projects.2 As of January 2013, FRA had 

awarded grants for 150 high speed intercity passenger rail projects. Of 

these projects, FRA had obligated about $9.2 billion for 9 corridor 

programs and 57 individual high speed rail projects as of December 

2012.3

 

1

The Passenger Rail Investment and Improvement Act of 2008 authorized funds for three 

different federal programs: the high speed rail corridor program, intercity passenger rail 

congestion, and capital assistance for intercity passenger rail service. In February 2009, 

the American Recovery and Reinvestment Act of 2009 appropriated $8 billion for these 

three intercity passenger rail programs, and, in June 2009, FRA launched the HSIPR 

program The Department of Transportation (DOT)’s fiscal year 2010 appropriation also 

included $2.5 billion for high speed rail, intercity passenger rail and congestion projects. 

The term “high speed rail” is defined as intercity passenger rail service that is reasonably 

expected to reach speeds of at least 110 miles per hour. 49 U.S.C. § 26106(b)(4). 

According to FRA, by this same date, states and other project 

2

Pursuant to the Passenger Rail Investment and Improvement Act of 2008, applicant 

eligibility varies among the three programs, but includes states, a group of states, an 

interstate compact, Amtrak, and public agencies established by one or more states that 

have responsibility for intercity passenger rail, or high speed rail. 

3

FRA had also obligated $700 million for procurement of new equipment, planning 

studies, and engineering/environmental analyses.

GAO Contact

Goal Statement

GAO Comments
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 79 GAO-13-174 Agency Priority Goals

sponsors had begun construction on 5 of the high speed rail corridors and

33 of the individual high speed rail projects. By the end of fiscal year 

2013, FRA’s goal is to begin construction on a total of 7 corridor and 36 

individual high speed rail projects.

The fundamental weaknesses of the HSIPR program include not having 

well-defined goals, a clear strategic vision, and performance measures to 

track program progress. In March 2009, before the HSIPR program was 

established, we reported that several principles could help guide the 

potential federal role in high speed rail. These principles included, among 

other things, creating well-defined goals based on identified areas of 

national interest, incorporating performance and accountability for results 

into funding decisions, and employing the best analytical tools and 

approaches to emphasize return on investment. Similarly, in June 2010, 

we reported that FRA’s strategic vision for high speed rail, as outlined in 

the agency’s April 2009 Vision for High-Speed Rail in America,

4 did not 

define the goals, stakeholder roles, or objectives for federal involvement 

in high speed intercity passenger rail and that the agency’s preliminary 

national rail plan did not include recommendations for future action.

Further, although states would be among primary HSIPR grant recipients, 

many did not have rail plans that would establish strategies and priorities 

for rail investments or identify the public benefits of such investments. 

Many of these weaknesses continue. For example, in September 2012 

the DOT IG reported that FRA’s HSIPR goals lacked the thoroughness 

needed to ensure that grant managers and decision makers, including 

Congress, could understand them, and that FRA generally lacked 

performance measures needed to assess the program’s progress in 

achieving its goals as well as complete monitoring mechanisms.

5

 

4

Federal Railroad Administration, Vision for High-Speed Rail in America, The High-Speed 

Rail Strategic Plan (April 2009) 

According to DOT, FRA has taken action to address some of the issues 

reported by the DOT IG, including developing a standardized mechanism 

for collecting and tracking HSIPR grantee performance and compliance 

metrics, and developing a comprehensive grants management training 

curriculum. 

5

Inspector General, U.S. Department of Transportation, Completing a Grants 

Management Framework Can Enhance FRA’s Administration of the HSIPR Program, CR2012-178, (Washington, D.C. September 11, 2012).
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There are also weaknesses in how the HSIPR program is administered 

starting with how HSIPR grants are awarded. In March 2011 we reported 

that, although FRA had applied its established criteria during the eligibility 

and technical reviews of the HSIPR grant applications, we could not verify 

whether it applied its final selection criteria because the documented 

rationales for selecting projects were typically vague.6 We concluded that 

without a record that provided insight into why decisions were made, FRA 

invited skepticism about the overall fairness of its decision making. Other 

program weaknesses include the lack of guidance issued to HSIPR 

applicants and FRA’s grants administration framework. In March 2009 we 

recommended the Secretary of Transportation develop guidance and 

methods for ensuring reliability of ridership and other forecasts used to 

determine the viability of high speed rail projects. In March 2012, the DOT 

IG also reported that FRA had established only minimal requirements and 

guidance on the information HSIPR grant applicants must provide to FRA 

on project viability which did not provide enough detail to minimize bias 

and ensure accuracy in project viability assessments.7 In addition, in 

September 2012, the DOT IG reported that FRA had issued the policies 

and procedures for HSIPR grants management several years after the 

program had been established and that insufficient staffing and training 

undermined FRA’s efforts to effectively administer and ensure the 

accountability of HSIPR grant funds once they are awarded.8

Aside from program weaknesses, we have found that implementing high 

speed rail projects is difficult. This difficulty could affect achievement of 

program goals. Our March 2009 report identified some of the challenges 

in developing and financing high speed rail projects, including securing 

FRA’s 

Grants Management Manual was not issued until April 2012, almost 3 

years after the HSIPR program was authorized. FRA’s monitoring plan, 

which will, among other things, guide performance and compliance 

monitoring for the HSIPR program, was not finalized until March 2012.

 

6

The selection criteria included such things as the region or location of the project, the 

degree of innovation demonstrated (e.g., the project pursued new technology where the 

public return on investment was favorable), and if a project emphasized partnerships 

when they spanned multiple states.

7

Inspector General, U.S. Department of Transportation, FRA Needs to Expand Its 

Guidance on High Speed Rail Project Viability Assessments, CR-2012-083 (Washington, 

D.C.: Mar. 28, 2012).

8

CR-2012-178.
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the up-front investments for such projects and sustaining public and 

political support and stakeholder consensus. We concluded that whether 

any high speed rail proposals are eventually built hinges on addressing 

the funding, public support, and other challenges facing these projects.

In March 2011, we recommended that FRA create additional records to 

document the substantive reasons behind award decisions in future 

HSIPR funding rounds to better ensure accountability for its use of federal 

funds. As of November 2012, FRA had enhanced its grant management 

manual with more explicit requirements for documenting the rationale 

behind its funding selections.

In March 2009, we recommended, among other things, that the Secretary 

of Transportation develop guidance and methods to improve the reliability 

and accuracy of ridership, cost, and other forecasts for these systems. As 

of November 2012, FRA said it is implementing this recommendation in 

conjunction with stakeholders, partners, and researchers, through an 

iterative process of developing methods and guidance, using them, and 

then refining them. FRA is also working with a research panel of the 

Transportation Research Board to develop a handbook that will provide 

tools to decision makers in such areas as ridership forecasting and 

service characteristics (e.g., frequency of service). FRA said it expects 

implementing this recommendation will require from 5 to 10 years.

In September 2012, DOT’s IG recommended that before awarding, 

obligating, and disbursing additional grant funds, FRA should take several 

actions to establish a comprehensive grants management program with 

clear program goals and mechanisms to track grantee performance 

toward those goals. In response to the IG’s recommendations, FRA 

officials concurred with each recommendation and said they would

implement reports, tools and training programs to meet the IG’s 

recommendations starting in late 2012.

Intercity Passenger Rail: Recording Clearer Reasons for Awards 

Decisions Would Improve Otherwise Good Grantmaking Practices. 

GAO-11-283. Washington, D.C.: March 10, 2011.

High Speed Rail: Learning from Service Start-Ups, Prospects for 

Increased Industry Investment, and Federal Oversight. GAO-10-625. 

Washington, D.C.: June 17, 2010.

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 82 GAO-13-174 Agency Priority Goals

High Speed Passenger Rail: Future Development Will Depend on 

Addressing Financial and Other Challenges and Establishing a Clear 

Federal Role. GAO-09-317. Washington, D.C.: March 19, 2009.

Susan Fleming, Director, Physical Infrastructure Issues, 202-512-2834, 

flemings@gao.gov. 

Reduce risk of aviation accidents. By September 30, 2013, reduce 

aviation fatalities by addressing risk factors both on the ground and in the 

air. Commercial aviation (i.e. airlines): Reduce fatalities to no more than 

7.4 per 100 million people on board. General aviation (i.e. private planes): 

Reduce fatal accident rate per 100,000 flight hours to no more than 1.06.

DOT’s FAA has worked toward these goals by partnering with the airline 

industry and other stakeholders through the Commercial Aviation Safety 

Team (CAST),9 improving runway safety, shifting toward a risk-based 

analysis of airborne aviation system information, establishing safety 

management systems (SMS), renewing the General Aviation Joint 

Steering Committee (GAJSC),10 and developing a 5-year strategy for 

reducing general aviation fatalities. DOT reported that from 2009 through 

2011 FAA exceeded its targets for reducing commercial air carrier 

fatalities, well below its 2013 goal.11

As we reported in April 2012, CAST has contributed to reducing 

commercial aviation accidents by analyzing past accidents and incidents 

to identify precursors and contributing factors, and ensuring that efforts to 

For general aviation fatality rates, 

however, FAA has not yet achieved its goal, in part due to challenges we 

have recently discussed.

 

9

CAST is a joint government-industry effort to reduce the commercial aviation fatality risk 

in the United States using an integrated, data-driven strategy. 

10The GAJSC is a joint effort of the FAA, the National Aeronautics and Space 

Administration, the National Transportation Safety Board , and the general aviation 

industry—including the Aircraft Owners and Pilots Association, the Experimental Aircraft 

Association, the General Aviation Manufacturers Association, and the National Business 

Aviation Association. 

11U.S. Department of Transportation, Performance Plan: Fiscal Year 2013 (Washington 

D.C.: February 2012). 

GAO Contact

Goal Statement

GAO Comments
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

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improve safety focus on the most prevalent accident categories. CAST 

has reduced commercial aviation risks by focusing on areas including 

controlled flight into terrain, loss of control, and runway incursions. CAST 

analyzes accident and incident data to identify precipitating conditions 

and causes, and then formulates an intervention strategy designed to 

reduce the likelihood of a recurrence. According to CAST, its work—along 

with new aircraft, regulations, and other activities—reduced the 

commercial aviation fatal accident rate by 83 percent from 1998 to 2008 

and is an important aspect of FAA’s efforts to improve aviation safety by 

sharing and analyzing data. However, as we reported in October 2011, 

for safety at and around airports, including runways, the overall rate of 

runway incursions (the unauthorized presence of an airplane, vehicle, or 

person on the runway) at towered airports has trended steadily upward, 

as has the rate and number of airborne operational errors (errors made 

by air traffic controllers), though it is not clear whether these recent 

increases in operational errors can be attributed to several changes in 

reporting policies and procedures at FAA, or increases in actual incidents.

We reported in September 2012 that FAA is seeking to further enhance 

commercial aviation safety by shifting to a data-driven, risk-based safety 

oversight approach—referred to as SMS. SMS represents a proactive 

approach to safety and is intended to continually monitor all aspects of 

aviation operations and collect appropriate data to identify emerging 

safety problems before they result in death, injury, or significant property 

damage. SMS implementation is required for FAA and several of its 

business lines and the agency is taking steps to require industry 

implementation. Several challenges remain that may affect FAA’s ability 

to effectively implement SMS. FAA is taking steps to address some of 

these, but challenges related to data concerns, its capacity to conduct 

analysis and oversight, and standardization of policies and procedures 

could negatively affect FAA’s efforts to implement SMS in a timely and 

efficient manner and require some skills that agency employees do not 

have. Addressing these challenges is ever more important with air travel 

projected to increase over the next 20 years.

FAA has embarked on several initiatives to meet its goal of reducing the 

fatal general aviation accident rate; however it reported not meeting its 

target fatality rates in any year from 2009 through 2011. As we reported in 

October 2012, FAA reported the general aviation fatality rate exceeded 

the target rate by 7.4 percent for 2011. FAA initiatives to improve aviation 

safety include renewing the GAJSC and implementing the Flight 

Standards Service’s 5-year strategy for reducing general aviation 

fatalities. The GAJSC, a government-industry partnership similar to the 
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 84 GAO-13-174 Agency Priority Goals

CAST approach for commercial aviation, focuses on analyzing general 

aviation accident data to develop effective intervention strategies. We 

believe that the GAJSC has the potential to contribute to a reduction in 

general aviation accidents and fatalities over the long term. However, the 

5-year strategy has shortcomings that jeopardize its potential for success 

because, among other things, the strategy lacks performance measures 

for significant activities. Without a strong performance management 

structure, FAA will not be able to determine the success or failure of the 

significant activities that underlie the strategy. Furthermore, there are 

some limitations in flight activity data and other data that preclude a 

confident assessment of general aviation safety. For example, FAA’s 

survey of general aviation operators, on which the agency bases its 

annual flight-hour estimates, continues to suffer from methodological and 

conceptual limitations, even with FAA’s efforts to improve it.12

In October 2012, we recommended that FAA (1) improve measures of 

general aviation activity by requiring the collection of the number of hours 

that general aviation aircraft fly, (2) set specific general aviation safety 

improvement goals—such as targets for fatal accident reductions—for 

individual industry segments (e.g. personal or corporate operations) using 

a data-driven, risk management approach and (3) determine whether the 

programs and activities underlying the 5-year strategy are successful and 

if additional actions are needed, develop performance measures for each 

significant program and activity underlying the 5-year strategy. In its 

comments to our report, FAA reported that it is working toward 

implementing these recommendations.

In September 2012, we recommended that FAA develop a system to 

assess whether SMS meets its goals and objectives by identifying and 

collecting related data on performance measures. In comments to our 

report, FAA stated that it is currently involved in activities directed towards 

the development of safety performance measurement capabilities, 

including a process and measures for measuring safety performance. 

This activity is expected to be completed by April 2015. 

 

12In October 2012, we reported that the survey has long suffered from low response rates, 

and this shortcoming, combined with limited information about the population, can call into 

question any estimates based on the survey’s results. 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 85 GAO-13-174 Agency Priority Goals

In October 2011, we recommended that FAA develop separate risk-based 

assessment processes, measures, and performance goals for runway 

safety incidents involving commercial and general aviation aircraft, and to 

expand the existing risk-based process for assessing airborne losses of 

separation. In comments to our report, FAA reported that it is working 

toward implementing these recommendations.

General Aviation Safety: Additional FAA Efforts Could Help Identify and 

Mitigate Safety Risks. GAO-13-36. Washington D.C.: October 4, 2012.

Aviation Safety: Additional FAA Efforts Could Enhance Safety Risk 

Management. GAO-12-898. Washington D.C.: September 12, 2012.

Aviation Safety: FAA Is Taking Steps to Improve Data, but Challenges for 

Managing Safety Risks Remain. GAO-12-660T. Washington D.C.: April 

25, 2012.

Aviation Safety: Enhanced Oversight and Improved Availability of RiskBased Data Could Further Improve Safety. GAO-12-24. Washington D.C.: 

October 5, 2011.

Aviation Safety: Improved Data Quality and Analysis Capabilities Are 

Needed as FAA Plans a Risk-Based Approach to Safety Oversight. 

GAO-10-414. Washington D.C.: May 6, 2010.

Gerald L. Dillingham, Ph.D., Director, Physical Infrastructure Issues, 

dillinghamg@gao.gov, (202) 512-2834.

Reduce the rate of roadway fatalities. Reduce the rate of roadway 

fatalities from 1.26 in 2008 to 1.03 per 100 million vehicle miles traveled 

by December 31, 2013.

We have issued a number of reports related to DOT’s efforts to reduce 

highway fatalities that highlight the need for improved performance 

accountability and data. The number of traffic fatalities decreased from 

41,000 in 2000 to fewer than 33,000 in 2010; the fatality rate per 100 

Selected GAO Reports 

GAO Contact

Goal Statement

GAO Comments
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 86 GAO-13-174 Agency Priority Goals

million miles traveled also decreased from 1.53 in 2000 to 1.11 in 2010.

13

On July 6, 2012, President Obama signed into law the Moving Ahead for 

Progress in the 21st Century Act.

To help states reduce traffic fatalities, the National Highway Traffic Safety 

Administration (NHTSA) within DOT provides traffic safety grants to 

states to, among other things, promote and enforce safety belt use and 

impaired driving laws and improve traffic safety data systems. While 

NHTSA has made progress in developing performance measures to help 

NHTSA and states evaluate the effectiveness of traffic safety programs, 

we reported in March 2008 that state performance has generally not been 

tied to receipt of the grants and improvements in state traffic safety data 

are needed to support a more performance-based approach to improving 

traffic safety programs.

14

While states have implemented projects to improve traffic safety data 

systems, such as switching to electronic data reporting and adopting data 

collection forms consistent with national guidelines, enhancements in 

these systems are still needed to support a performance-based approach 

to improving traffic safety. In April 2010, we reported that our analysis of 

traffic records assessments—conducted for states by NHTSA technical 

teams or contractors at least every 5 years—indicated that the quality of 

state traffic safety data systems varied across the six data systems 

The act made the surface 

transportation program framework more performance-based by: (1) 

establishing national performance goals for the federal-aid highway 

program in several areas, including goals for the safety of the nation’s 

highways; and (2) requiring the Secretary of Transportation, in 

consultation with state departments of transportation and others, to 

establish performance measures linked to national goals, including 

measures for serious injuries and fatalities on public roads. Finally, the 

act required states to establish performance targets for those measures 

and report their progress in achieving planned outcomes through the 

statewide transportation plans. These provisions are consistent with a 

performance-based planning framework we recommended to Congress in 

December 2010 and, as they are implemented over the next several 

years, should help NHTSA and states focus their efforts on key actions 

needed to improve traffic safety and reduce highway fatalities.

 

13 U.S. Department of Transportation, DOT HS 811 (Washington, D.C.: 2010).

14 Pub. L. No. 112-141, 126 Stat. 405 (2012).
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

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maintained by states. Assessments include an evaluation of system 

quality based on six performance measures. Across all states, we found 

that vehicle and driver data systems met performance measures 71 

percent and 60 percent of the time, respectively, while roadway, crash, 

citation and adjudication, and injury surveillance data systems met 

performance measures less than 50 percent of the time. States face 

resource and coordination challenges in improving traffic safety data 

systems. For example, custodians of data systems are often located in 

different state agencies, which may make coordination difficult. In 

addition, rural and urban areas may face different challenges in improving 

data systems, such as limited technology options for rural areas or timely 

processing of large volumes of data in urban areas. States we visited 

have used strategies to overcome these challenges, including 

establishing an executive-level traffic records coordinating committee 

(TRCC), in addition to the technical-level committee that states are 

required to establish to qualify for federal traffic safety grant funding. An 

executive-level committee could help states address challenges by 

targeting limited resources and facilitating data sharing.

In April 2010, we recommended that the Secretary of Transportation 

should direct the NHTSA Administrator to (1) ensure that traffic records 

assessments provide an in-depth evaluation that is complete and 

consistent in addressing all performance measures across all state traffic 

safety data systems and (2) study and communicate to Congress the 

value of requiring states to establish an executive-level TRCC in order to 

qualify for traffic safety data system grant funding. 

In response to the first recommendation, NHTSA developed a 

comprehensive approach for assessing the systems and processes that 

govern the collection, management, and analysis of traffic records data. 

Core to this approach is the set of questions for conducting assessments 

published in September 2012 in the Traffic Records Program Assessment 

Advisory. The Advisory includes standards of evidence to guide state 

officials in providing the information necessary to answer each 

assessment question. The assessment now asks a comprehensive, 

uniform set of questions about data quality performance measures across 

all state traffic safety data systems. NHTSA kicked off a pilot program to 

test the new process in Indiana in November 2012. This pilot was 

successfully completed in February 2013. As part of the new assessment 

process, NHTSA will create a database to house data from the new traffic 

records systems, conduct research and identify national trends. NHTSA 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 88 GAO-13-174 Agency Priority Goals

can then inform states about how the ratings for each of their assessment 

questions compares with a national average.

In response to the second recommendation, NHTSA’s study examining 

how executive level and technical level TRCCs coordinate traffic records 

systems management was initiated with the 2012 pilot test of the new 

traffic records assessment process in Indiana. Data collection will 

continue through the fiscal year 2015 assessment cycle at which point 10 

states will have been assessed and the data set will be large enough to 

enable a quality analysis. The data for this study will include the 

information submitted by the states as well as the ratings received on the 

comprehensive, uniform set of assessment questions. Specifically, 

NHTSA plans to examine states’ responses to questions about their 

TRCC management, strategic planning, data integration, and the 

capabilities of the six core traffic records components. Notable practices 

demonstrated by effective TRCC organizations—particularly at the 

executive level—will be highlighted. 

Statewide Transportation Planning: Opportunities Exist to Transition to 

Performance-Based Planning and Federal Oversight. GAO-11-77. 

Washington, D.C.: December 15, 2010.

Traffic Safety Data: State Data System Quality Varies and Limited 

Resources and Coordination Can Inhibit Further Progress. GAO-10-454. 

Washington, D.C.: April 15, 2010.

Traffic Safety Programs: Progress, States’ Challenges, and Issues for 

Reauthorization. GAO-08-990T. Washington, D.C.: July 16, 2008.

Traffic Safety: NHTSA’s Improved Oversight Could Identify Opportunities 

to Strengthen Management and Safety in Some States. GAO-08-788. 

Washington, D.C.: July 14, 2008.

Traffic Safety: Improved Reporting and Performance Measures Would 

Enhance Evaluation of High-Visibility Campaigns. GAO-08-477. 

Washington, D.C.: April 25, 2008.

Traffic Safety: Grants Generally Address Key Safety Issues, Despite 

State Eligibility and Management Difficulties. GAO-08-398. Washington, 

D.C.: March 14, 2008.

Selected GAO Reports
Appendix IV: Comments on the Department of 

Transportation’s Priority Goals

Page 89 GAO-13-174 Agency Priority Goals

Surface Transportation: Restructured Federal Approach Needed for More 

Focused, Performance-Based, and Sustainable Programs. GAO-08-400. 

Washington, D.C.: March 6, 2008.

Phillip R. Herr, Managing Director, Physical Infrastructure Issues, 

herrp@gao.gov, (202) 512-2834.

Susan Fleming, Director, Physical Infrastructure Issues, 

flemings@gao.gov, (202) 512-2834.

GAO Contacts
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 90 GAO-13-174 Agency Priority Goals

Based on our past work, as well as that of the VA IG, we commented on 

each of VA’s three priority goals for 2012 to 2013:

1. Assist in housing 24,400 additional homeless veterans (12,200 per 

year) and reduce the number of homeless veterans to 35,000 in 2013, 

to be measured in the January 2014 Point-In-Time homelessness 

count. By September 2013, working in conjunction with the U.S. 

Interagency Council on Homelessness (Interagency Council) and 

HUD, VA will also assist homeless Veterans in obtaining employment, 

accessing VA services, and securing permanent supportive housing, 

with a long-range goal of eliminating homelessness among Veterans 

by 2015. 

2. Improve accuracy and reduce the amount of time it takes to process 

veterans’ disability benefit claims. By September 30, 2013, reduce the 

veterans’ disability compensation and pension claims backlog to 40 

percent from 60.2 percent while achieving 90 percent rating accuracy, 

up from 83.8 percent, in pursuit of eliminating the Veterans’ claims 

backlog (defined as claims pending more than 125 days) by 2015. 

3. Improve awareness of VA services and benefits by increasing the 

timeliness and relevance of on-line information available to veterans, 

service members and eligible beneficiaries. By September 30, 2013, 

increase the number of registered eBenefits users from 1.0 million to 

2.5 million. 

For each goal, we also identify our related past reports and provide an 

update on the status of any open recommendations and matters for 

congressional consideration that we previously made related to the goal. 

We also identify a GAO contact for our work related to each goal.

Assist in housing 24,400 additional homeless veterans (12,200 per year) 

and reduce the number of homeless veterans to 35,000 in 2013, to be 

measured in the January 2014 Point-In-Time homelessness count. By 

September 2013, working in conjunction with the U.S. Interagency 

Council on Homelessness (Interagency Council) and HUD, VA will also 

assist homeless Veterans in obtaining employment, accessing VA 

services, and securing permanent supportive housing, with a long-range 

goal of eliminating homelessness among veterans by 2015. 

VA notes that several programs are expected to contribute to the 

achievement of its priority goal to reduce homelessness among veterans, 

including the HUD Veterans Affairs Supportive Housing (HUD-VASH) 

Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Goal Statement

GAO Comments
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 91 GAO-13-174 Agency Priority Goals

program, Grant and Per Diem program, Domiciliary Care for Homeless 

Veterans program, and Health Care for Homeless Veterans program. Our 

past work has identified a number of issues related to these programs. 

For example, our June 2012 report on the HUD-VASH program—a 

collaborative initiative between HUD and VA that targets the most 

vulnerable, most needy, and chronically homeless veterans—states that 

the program has moved veterans out of homelessness. Specifically, 

according to VA, as of March 2012, nearly 31,200 veterans lived in HUDVASH supported housing, which represents about 83 percent of the rental 

assistance vouchers authorized under the program.

1

Our May 2012 report on the fragmentation, overlap, and duplication 

among federal homelessness programs also identified issues related to 

the programs that are expected to contribute to the achievement of this 

priority goal. For example, our report noted VA was one of eight federal 

agencies that administered 26 targeted homelessness programs in fiscal 

year 2011, suggesting fragmentation and some overlap among these 

programs.

In addition, our 

December 2011 report on homeless women veterans notes that although 

HUD collects data on homeless women and on homeless veterans, the 

department does not collect detailed data information on homeless 

women veterans and neither HUD nor VA captures data on the overall 

population of homeless women veterans. Further, our report states that 

HUD and VA lack data on the characteristics and needs of these women 

on a national, state, and local level. Finally, our report notes that absent 

more complete data on homeless women veterans, VA does not have the 

information needed to plan services effectively, allocate grants to 

providers, and track progress toward its overall goal of ending veteran 

homelessness. 

2

 

1

More recent data reported by VA shows that over 39,200 veterans lived in HUD-VASH 

supported housing as of November 28, 2012, about 82 percent of the vouchers supported 

under the program at the time. 

More specifically, VA typically operates programs or provides 

funding for supportive services such as health care, substance abuse 

treatment, and employment assistance, but also administers programs 

that provide housing and employment assistance. Similarly, HUD not only 

administers housing assistance, but also provides funding for mental 

2

The Departments of Education, HHS, Labor, Justice, VA, FEMA, and the General 

Services Administration also administered targeted homelessness programs in fiscal year 

2011—those that exclusively assisted persons who were homeless or at risk for 

homelessness. 
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 92 GAO-13-174 Agency Priority Goals

health care, substance abuse treatment, and employment services. 

Fragmentation and overlap can lead to inefficient use of resources. Some 

local service providers told us that managing multiple applications and 

reporting requirements was burdensome, difficult, and costly. Moreover, 

according to providers, persons experiencing homelessness have 

difficulties navigating services that are fragmented across agencies. 

Further, our report states that limited information exists about the 

efficiency or effectiveness of targeted homelessness programs because 

evaluations have not been conducted recently—including for the 13 

programs VA administers or co-administers. Finally, our report states that 

the Interagency Council strategic plan to prevent and end homelessness 

has served as a useful and necessary first step in increasing agency 

coordination and focusing attention on ending homelessness; however, 

the plan lacks key characteristics desirable in a national strategy.

3

In May 2012, we recommended that the Interagency Council and the 

Office of Management and Budget––in conjunction with the Secretaries of 

HHS, HUD, Labor, and VA––should consider examining inefficiencies that 

may result from overlap and fragmentation in their programs for persons 

experiencing homelessness. VA agreed with this recommendation. HHS, 

HUD, Labor, and the Interagency Council did not explicitly agree or 

disagree. We also recommended that to help prioritize, clarify, and refine 

efforts to improve coordination across agencies, and improve the 

efficiency and effectiveness of federal homelessness programs, the 

Interagency Council, in consultation with its member agencies, should 

incorporate additional elements into updates to the national strategic plan 

or other planning and implementation documents to help set priorities, 

measure results, and ensure accountability. According to the Interagency 

Council, its fiscal year 2013 report will focus on updates and progress 

made on the national strategic plan’s objectives. The Interagency 

For 

example, the plan does not list priorities or milestones and does not 

discuss resource needs or assign clear roles and responsibilities to 

federal partners. 

 

3

The members of the Interagency Council are from the Departments of Agriculture, 

Commerce, Defense, Education, Energy, Health and Human Services, Homeland 

Security, Housing and Urban Development, Interior, Justice, Labor, Transportation, and 

Veterans Affairs; Corporation for National and Community Service; General Services 

Administration; Office of Management and Budget; Social Security Administration; U.S. 

Postal Service; and the White House Office of Faith-Based and Community Initiatives 

(now known as the White House Office of Faith-Based and Neighborhood Partnerships). 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 93 GAO-13-174 Agency Priority Goals

Council’s national strategic plan broadly describes the federal approach 

to preventing and ending homelessness; however, until the key member 

agencies fully implement their plans, including setting priorities, 

measuring progress and results, and holding federal and nonfederal 

partners accountable, they are at risk of not reaching their goal of ending 

veteran and chronic homelessness by 2015, and ending homelessness 

among children, youth, and families by 2020. 

In December 2011, we recommended that in order to help achieve the 

goal of ending homelessness among veterans, the Secretaries of HUD 

and VA should collaborate to ensure appropriate data are collected on 

homeless women veterans, including those with children and those with 

disabilities, and use these data to strategically plan for services. In 

concurring with this recommendation, VA stated it had several initiatives 

already planned or under way to gather information on those homeless 

women veterans who are in contact with VA, including the development of 

a more streamlined and comprehensive data collection system. In April 

2013, VA stated that it had taken additional actions to inform policy and 

operational decisions about homeless and at-risk women veterans. For 

example, VA stated that in 2013 it worked with HUD to ensure that 

gender specific data were collected during the 2013 Point in Time count 

of homeless persons. VA added that the results of the 2013 Point in Time 

count will be included in the Annual Homeless Assessment Report to 

Congress which will be published later in 2013 and will be used by the 

department to strategically plan and implement services for all homeless 

and at-risk veterans, including women veterans. In addition, VA stated 

that in 2012 it revised the Community Homelessness Assessment, Local 

Education and Networking Groups survey to capture gender specific data 

for homeless veterans to better identify the needs of women veterans and 

influence service provision.

4

 

4

According to VA, the purpose of the Community Homelessness Assessment, Local 

Education and Networking Groups survey is to enhance the continuum of services for 

homeless veterans provided by local VA health care facilities and the surrounding 

community service agencies, which helps VA work closely with local communities to 

identify needed services and then deliver the full spectrum of needed services to help 

homeless veterans reach their potential
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 94 GAO-13-174 Agency Priority Goals

Veteran Homelessness: VA and HUD Are Working to Improve Data on 

Supportive Housing Program. GAO-12-726. Washington, D.C.: June 26, 

2012.

Homelessness: Fragmentation and Overlap in Programs Highlight the 

Need to Identify, Assess, and Reduce Inefficiencies. GAO-12-491. 

Washington, D.C.: May 10, 2012.

Homeless Women Veterans: Actions Needed to Ensure Safe and 

Appropriate Housing. GAO-12-182. Washington, D.C.: December 23, 

2011.

Homelessness: A Common Vocabulary Could Help Agencies Collaborate 

and Collect More Consistent Data. GAO-10-702. Washington, D.C.: June 

30, 2010.

Alicia Puente Cackley, Director, Financial Markets and Community 

Investment, cackleya@gao.gov, (202) 512-8678.

Improve accuracy and reduce the amount of time it takes to process 

veterans’ disability benefit claims. By September 30, 2013, reduce the 

veterans’ disability compensation and pension claims backlog to 40 

percent from 60.2 percent while achieving 90 percent rating accuracy, up 

from 83.8 percent, in pursuit of eliminating the veterans’ claims backlog 

(defined as claims pending more than 125 days) by 2015. 

As we and other organizations have reported over the last decade, VA 

has faced challenges improving the accuracy and timeliness of its 

disability claims process. VA’s disability compensation benefits program 

has been included in our High Risk List, under “Improving and 

Modernizing Federal Disability Programs,” since 2003. Our December 

2012 report on VA claims processing found that VA’s disability claims 

backlog—defined as claims awaiting a decision over 125 days—had more 

than tripled since September 2009. In fact, two-thirds of all disability 

claims awaiting a decision in August 2012 met VA’s backlog definition. 

Moreover, the timeliness of disability claims processing over the last 

several years has worsened: the average length of time to complete a 

claim increased from 161 days in 2009 to 260 days in 2012. The number 

of disability claims received is likely to remain high as VA projects that 1 

million service members will become veterans over the next 5 years, 

Selected GAO Reports

GAO Contact

Goal Statement

GAO Comments
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 95 GAO-13-174 Agency Priority Goals

portending ongoing challenges for VA to meet its goal of processing

claims within 125 days by 2015. 

While our December 2012 report did not look at claims processing 

accuracy, the VA IG established a benefits inspection program in March 

2009 which examines claims processing accuracy at VA regional offices. 

Based on a review of the VA IG’s benefits inspection findings across 21 

VA regional offices in fiscal year 2012, accuracy rates ranged from 40 to 

87 percent per office for a sample of selected types of claims.

5

In December 2012, we reported that the Veterans Benefits Administration 

(VBA) has a number of ongoing initiatives designed to improve claims 

processing and help VA meet its timeliness goals, but the impact of some 

initiatives is uncertain: 

• The Fully Developed Claims program, implemented nationally in June 

2010, provides priority processing to veterans who submit claims with 

all relevant private medical evidence. The average processing time for 

claims involved in the program is 98 days, but veteran participation in 

the program has been low—only 4 percent of all compensation claims 

submitted in 2012—minimizing the impact on VA’s claims backlog. 

• The Claims Organizational Model, which reorganizes claim staff into 

cross-functional teams, processes claims by complexity, and 

redesigns mailroom functions, was piloted in 3 regional offices in 

March 2012 and implemented in all regional offices as of March 2013. 

• VBA developed standard medical forms—called Disability Benefits 

Questionnaires—designed to speed up the claims process by more 

accurately capturing medical evidence needed from medical 

providers. Although VBA tracks the number and completeness of 

questionnaires submitted, VBA is not measuring their impact on 

processing time. 

• In 2010, VBA began to develop the Veterans Benefit Management 

System (VBMS), an initiative to help streamline the claims process 

and reduce processing times. According to VA officials, VBMS is 

intended to convert existing paper-based claims folders into electronic 

claims folders that will allow VBA employees electronic access to 

claims and their support evidence. Once completed, VBMS will allow 

veterans, physicians, and other external parties to submit claims and 

 

5

The VA IG reported on the processing accuracy of claims for temporary100 percent 

disability, traumatic brain injury, and herbicide-related disabilities, among other aspects. 
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 96 GAO-13-174 Agency Priority Goals

supporting evidence electronically. In August 2012, VBA officials told 

us that VBMS was not ready for national deployment, citing delays in 

scanning claims folders into VBMS as well as other software 

performance issues. A recent VA IG report also concluded that VBMS 

has experienced some performance issues and the scanning and 

digitization of claims lacked a detailed plan.6

In our December 2012 report, we stated that without a comprehensive 

plan to strategically manage resources and evaluate the effectiveness of 

each initiative, VBA risks spending limited resources on initiatives that 

may not speed up disability claims processes. In response to our 

December 2012 report, on January 25, 2013, VA published the Strategic 

Plan to Eliminate the Compensation Claims Backlog. 

However, according to 

VA, as of December 2012, 18 regional offices had implemented 

VBMS and all regional offices will implement VBMS by the end of 

calendar year 2013. 

In a December 2012 report, we reviewed the timeliness of VA claims 

processing and recommended that the Secretary of Veterans Affairs 

direct the Veterans Benefits Administration to:

1. Develop improvements for partnering with relevant federal and state 

military officials to reduce the time it takes to gather military service 

records for National Guard and Reserve sources.

2. Develop improvements for partnering with Social Security 

Administration (SSA) officials to reduce the time it takes to gather 

SSA medical records. 

3. Ensure the development of a robust backlog reduction plan for VBA’s 

initiatives that, among other best practice elements, identifies 

implementation risks and strategies to address them and performance 

goals that incorporate the impact of individual initiatives on processing 

timeliness.

VA generally concurred with our recommendations, and has taken steps 

to address the recommendations. For example, VA stated it has recently 

initiated several interagency efforts to improve receipt of military service 

records. According to VA, on December 3, 2012, the joint VBA and DOD 

 

6

VA Office of Inspector General, Review of Transition to a Paperless Claims Processing 

Environment (Washington D.C.: February 4, 2013). 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 97 GAO-13-174 Agency Priority Goals

Disability Claims Reduction Task Force met to begin to evaluate the 

process to request records, among other issues, with the aim of 

improving the timeliness of record exchanges between the two agencies. 

In addition, the National Guard Bureau and the VA recently agreed to 

create a collaboration group that will examine ways to improve the 

timeliness and completeness of the records submitted in support of VA 

benefit claims. Furthermore, VA officials stated that VBA staff are 

currently meeting with SSA on a weekly basis to develop strategies to 

improve the records acquisition process and piloting a tool with four VA 

regional offices to provide VA staff with direct electronic access to SSA 

medical records. We believe these initiatives are heading in the right 

direction in order to improve the timeliness of meeting VA requests for 

SSA medical records and National Guard and Reservists records. 

VA agreed with our recommendation to develop a robust backlog plan for 

VBA’s initiatives, and subsequent to our report, published the Strategic 

Plan to Eliminate the Compensation Claims Backlog, which identifies 

implementation risks as well as tracks overall performance based on a 

number of metrics, including processing timeliness. However, this plan 

does not provide individual performance goals and metrics for all 

initiatives, which are needed to ensure VA is spending its limited 

resources on initiatives that are proven to speed up disability claims and 

appeals processes. 

High-Risk Series: An Update. GAO-13-283. Washington, D.C.: February 

14, 2013.

Veterans’ Disability Benefits: Timely Processing Remains a Daunting 

Challenge. GAO-13-89. Washington, D.C.: December 21, 2012.

VA Disability Compensation: Actions Needed to Address Hurdles Facing 

Program Modernization. GAO-12-846. Washington, D.C.: September 10, 

2012.

Veterans Disability Benefits: Clearer Information for Veterans and 

Additional Performance Measures Could Improve Appeal Process. 

GAO-11-812. Washington, D.C.: September 29, 2011.

Veterans’ Disability Benefits: Further Evaluation of Ongoing Initiatives 

Could Help Identify Effective Approaches for Improving Claims 

Processing. GAO-10-213. Washington, D.C.: January 29, 2010.

Selected GAO Reports
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 98 GAO-13-174 Agency Priority Goals

Daniel Bertoni, Director, Education, Workforce, and Income Security 

Issues, bertonid@gao.gov, 202-512-7215.

Improve awareness of VA services and benefits by increasing the 

timeliness and relevance of on-line information available to veterans, 

service members and eligible beneficiaries. By September 30, 2013, 

increase the number of registered eBenefits users from 1.0 million to 2.5 

million.

While we have not specifically looked at VA’s eBenefits efforts, our past 

work has identified challenges VA has faced in its efforts to increase 

awareness of its services and benefits which could be applicable to its 

ability to achieve this goal.

In February 2011, we reported that VA has a variety of activities to reach 

out to and support veterans and service members who may be eligible for 

VA education benefits, including the posting of information on its Web site 

to support those individuals in the process of applying for education 

benefits. We found that veterans service organizations, school officials, 

and students receiving VA education benefits had positive feedback for a 

recent redesign of the GI Bill web site that highlighted the three main 

steps in applying for Post-9/11 GI Bill benefits. However, we also found 

that VA did not provide links on the GI Bill Web site to consumer-focused 

information generated by other entities. In contrast, the Department of 

Education’s College Navigator site aggregated, for example, information 

on graduation rates, loan default rates, costs of attendance and available 

scholarships. Moreover, we found that little was known about the 

effectiveness of VA’s education outreach and support because VA did not 

have outcome-oriented performance measures for these activities. For 

example, while VA’s education program estimates the number of people 

who view or listen to a particular Post-9/11 GI Bill online, radio, or print 

advertisement, VA had not determined the extent to which its outreach 

campaign has been effective in informing or changing the behavior of 

target audiences. 

In December 2011, we reported that VA and the Department of Defense 

had recently developed the eBenefits web portal to provide veterans with 

customized information on VA benefits and assistance, and how to apply 

for them, but the portal did not include a direct link to information on 

enhanced monthly benefits (which increase recipients’ monthly disability

compensation or pension payments). A few of our focus group 

GAO Contact

Goal Statement

GAO Comments
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

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participants—conducted with veterans and their family representatives—

commented that they had difficulty finding information about enhanced 

monthly benefits on VA’s website. Federal website guidelines recommend 

that navigation procedures to access online information should be simple 

and that links should be properly labeled to help users obtain desired 

results.

In December 2012, we reported on the status of VBA’s recent efforts to 

improve disability claims and appeals processing timeliness. In that 

report, we noted that veterans can learn about the status of their claims in 

several ways, including the use of eBenefits. However, we did not review 

veterans’ actual use of eBenefits. 

In our February 2011 report, to improve VA’s outreach and support for 

eligible service members and veterans, communication with school 

officials, and oversight of its education benefit programs, we 

recommended that the Secretary of Veterans Affairs, among other 

actions, (1) develop outcome-oriented performance measures for 

outreach to service members and veterans who are seeking VA 

education benefits and (2) establish performance measures for the quality 

of information provided by VA’s toll-free hotline and for the timeliness and 

quality of its Right Now Web service. VA concurred with these 

recommendations in commenting upon a draft of the report. With respect 

to the first recommendation, VA reported that it had deployed an early 

communication tool to inform service members and veterans about their 

eligibility for education benefits and, as of April 2013, reported that it was 

in the first phase of capturing data on the frequency of visits to dedicated 

website Uniform Resource Locators. VA anticipated it will be able to 

establish baseline performance measures by the end of July 2013. With 

respect to measuring the quality of VA’s customer service on its toll-free 

hotline and its online Right Now Web service, VA has established 

applicable national performance standards and, in April 2013, VA 

reported that the standards have been issued to its field. We have 

requested to review the performance standards prior to considering this 

recommendation fully implemented, and are awaiting further status 

updates with regard to the implementation of the first recommendation. 

Veterans’ Disability Benefits: Timely Processing Remains a Daunting 

Challenge. GAO-13-89. Washington, D.C.: December 21, 2012.

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports
Appendix V: Comments on the Department of 

Veterans Affairs’ Priority Goals

Page 100 GAO-13-174 Agency Priority Goals

VA Enhanced Monthly Benefits: Recipient Population Is Changing, and 

Awareness Could Be Improved. GAO-12-153. Washington, D.C.: 

December 14, 2011.

VA Education Benefits: Actions Taken, but Outreach and Oversight Could 

Be Improved. GAO-11-256. Washington, D.C.: February 28, 2011.

Daniel Bertoni, Director, Education, Workforce, and Income Security 

Issues, bertonid@gao.gov, 202-512-7215.

GAO Contact
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

Page 101 GAO-13-174 Agency Priority Goals

Based on our past work, we commented on each of OPM’s five priority 

goals for 2012 to 2013:

1. Ensure high quality federal employees. By September 30, 2013, 

increase federal manager satisfaction with applicant quality (as an 

indicator of hiring quality) from 7.7 to 8.3 on a scale of 1 to 10, while 

continually improving timeliness, applicant satisfaction, and other 

hiring process efficiency and quality measures. 

2. Improve performance culture in the Goals-EngagementAccountability-Results (GEAR) pilot agencies to inform the 

development of government-wide policies. By September 30, 2013, 

employee responses to the annual Employee Viewpoint Survey in 

each of the five agencies participating in a performance culture pilot 

project will increase by 5 percent or greater on the results-oriented 

culture index and the conditions for employee engagement index, 

using 2011 survey results as the baseline. 

3. Increase health insurance choices for Americans. By October 1, 2013, 

expand competition within health insurance markets by ensuring 

participation of at least two multi-state health plans in the State 

Affordable Insurance Exchanges. 

4. Maintain speed of national security background investigations. 

Through September 30, 2013, maintain a 40 day or less average 

completion time for the fastest 90 percent of initial national security 

investigations.

5. Reduce federal retirement processing time. By July 31, 2013, 

Retirement Services will have reduced its case inventory so that 90 

percent of all claims will be adjudicated within 60 days.

For each goal, we also identify our related past reports and provide an 

update on the status of any open recommendations and matters for 

congressional consideration that we previously made related to the goal. 

We also identify a GAO contact for our work related to each goal.

Ensure high quality federal employees. By September 30, 2013, increase 

federal manager satisfaction with applicant quality (as an indicator of 

hiring quality) from 7.7 to 8.3 on a scale of 1 to 10, while continually 

improving timeliness, applicant satisfaction, and other hiring process 

efficiency and quality measures.

Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

Goal Statement
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

Page 102 GAO-13-174 Agency Priority Goals

We have not specifically reported on OPM’s ability to ensure high-quality 

federal employees by increasing satisfaction with applicant quality. 

However, our past work has highlighted efforts OPM has undertaken to 

recruit and maintain a high-quality workforce. 

Our past work on OPM’s efforts to improve the federal government’s 

competitiveness in recruiting and maintaining a high-quality workforce has 

shown that in 2005, and again in 2008, OPM issued guidance on the use 

of hiring authorities and flexibilities. As we reported in September 2012, in 

2006 OPM developed the Hiring Toolkit to assist agency officials in 

determining the appropriate hiring flexibilities to use given their specific 

situations, and in 2008 OPM launched an 80-day hiring model to help 

speed up the hiring process. Also in 2008, OPM established standardized 

vacancy announcement templates for common occupations, such as 

contract specialist and accounting technician positions, in which agencies 

can insert summary information concerning their specific jobs prior to 

posting for public announcement. In 2012, OPM issued regulations 

launching the Pathways program in order to make it easier to recruit and 

hire students and recent graduates and allow for noncompetitive 

conversion to permanent positions after meeting certain requirements.1

In January 2010, we reported on the use of recruitment, relocation, and 

retention (3R) incentives at the Food and Drug Administration and the 

oversight provided by Health and Human Services, and how OPM 

provides oversight to agency 3R programs. We found that these 

flexibilities were widely used by agencies, and that retention incentives 

accounted for the majority of these incentive costs. Federal 3R incentives 

are among the human capital flexibilities intended to help federal 

If 

successfully implemented, initiatives such as Pathways could help 

agencies further close critical skills gaps. We narrowed the scope of the 

human capital high-risk area in February 2011 to focus on this challenge 

of closing mission critical skills gaps and although progress has been 

made, the area remains on our recently issued High Risk List in February 

2013.

 

1

77 Fed. Reg. 28194 (May 11, 2012). The Pathways Programs were established by the

President under Exec. Order No. 13562, Recruiting and Hiring Students and Recent 

Graduates, 75 Fed. Reg. 82585 (Dec. 27, 2010). Pathways created two new conduits into 

government service: the Internship Program for students currently in high school, college, 

and other qualifying programs, and the Recent Graduates Program for individuals who, 

within the previous two years, earned an associate, bachelors, masters, professional or 

other qualifying degree or certificate. 

GAO Comments
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

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agencies address human capital challenges and to build and maintain a 

high-performing workforce with essential skills and competencies. 

According to OPM, the 3R incentives are intended to provide agencies 

with discretionary authority to use compensation other than base pay to 

help recruit, relocate, and retain employees in difficult staffing situations. 

Our review of the steps OPM has taken to help ensure that agencies 

have effective oversight of their incentive programs found that while OPM 

provided oversight of such incentives through various mechanisms, 

including guidance and periodic evaluations and accountability reviews, 

there are opportunities for improvement.

In January 2010, we recommended that the Director of OPM require 

agencies to incorporate succession planning efforts into the decision 

process for awarding retention incentives and document this requirement 

for succession planning in their 3R incentive plans. In January 2011, 

OPM issued proposed regulations to add succession planning to the list 

of factors an agency may consider before approving a retention incentive 

for an employee who would be likely to leave the federal service in the 

absence of the incentive. OPM stated that specifically listing this factor in 

the regulations will strengthen the relationship between succession 

planning and retention incentives.2 OPM anticipates publishing the final 

regulations this year. 

High Risk Series: An Update. GAO-13-283. Washington, D.C.: February,

14, 2013.

Human Capital Management: Effectively Implementing Reforms and 

Closing Critical Skills Gaps are Key to Addressing Federal Workforce 

Challenges. GAO-12-1023T. Washington, D.C.: September 19, 2012.

Human Capital: Continued Opportunities Exist for FDA and OPM to 

Improve Oversight of Recruitment, Relocation, and Retention Incentives. 

GAO-10-226. Washington, D.C.: January 22, 2010.

 

2 76 Fed. Reg. 1096 (Jan. 7, 2011).

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

Page 104 GAO-13-174 Agency Priority Goals

Robert Goldenkoff, Director, Strategic Issues, goldenkoffr@gao.gov, 202-

512-2757. 

Yvonne Jones, Director, Strategic Issues, jonesy@gao.gov, 202-512-

2717. 

Improve performance culture in the GEAR pilot agencies to inform the 

development of government-wide policies. By September 30, 2013, 

employee responses to the annual Employee Viewpoint Survey in each of 

the five agencies participating in a performance culture pilot project will 

increase by 5 percent or greater on the results-oriented culture index and 

the conditions for employee engagement index, using 2011 survey results 

as the baseline.

We have not specifically reported on improving the performance culture of 

the five GEAR pilot agencies—OPM, the Departments of Energy, 

Housing and Urban Development, and Veterans Affairs, and the U.S. 

Coast Guard.3

In March 2003, we reported that effective performance management 

systems are not merely used for once or twice-yearly individual 

expectation setting and rating processes, but are tools to help the 

organization manage on a day-to-day basis. We identified key practices 

that create a clear linkage—”line of sight”—between individual 

performance and organizational success and, thus, transform agency

cultures to be more results-oriented, customer-focused, and collaborative 

in nature. These key practices are: (1) align individual performance 

expectations with organizational goals; (2) connect performance 

expectations to crosscutting goals; (3) provide and routinely use 

performance information to track organizational priorities; (4) require 

follow-up actions to address organizational priorities; (5) use 

competencies to provide a fuller assessment of performance; (6) link pay 

GEAR is an effort to create high-performing organizations 

that are aligned, accountable, and focused on results. Our past work has 

highlighted steps that OPM and agencies should take to improve their 

performance cultures.

 

3

We have ongoing work looking at GEAR in the five pilot agencies and plan to issue the 

results later in 2013.

GAO Contacts

Goal Statement

GAO Comments
Appendix VI: Comments on the Office of

Personnel Management’s Priority Goals

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to individual and organizational performance; (7) make meaningful 

distinctions in performance; (8) involve employees and stakeholders to 

gain ownership of performance management systems; and (9) maintain 

continuity during transitions.

As the federal government’s human capital leader, OPM must have the 

capacity to effectively assist agencies and to successfully lead and 

implement these important human capital management transformations. 

In January 2007, we reported that to enhance its capacity to do so, OPM 

is working to transform its own organization from less of a rulemaker, 

enforcer, and independent agent to more of a consultant, toolmaker, and 

strategic partner. We recommended that OPM reexamine its agency-wide 

skills and competencies in light of its updated strategic management 

document. OPM implemented this recommendation in 2008 by 

completing an agencywide competency assessment of all mission critical 

occupations. As reform initiatives move forward, it is increasingly 

important for OPM to complete this transformation and clearly 

demonstrate its capacity to lead and implement such reforms.

In November 2008, we reported that effective performance management 

systems that hold executives accountable for results can help provide 

continuity during times of leadership transition, such as changes in 

administrations, by maintaining a consistent focus on organizational 

priorities. OPM has an opportunity to help ensure that agencies are 

making meaningful distinctions in executive performance by 

strengthening its communication with agencies and executives on the 

importance of using a range of rating levels when assessing performance, 

while avoiding forced distributions (the idea of limiting awards to a certain 

number or percentage of employees). Additionally, communicating how 

OPM uses data and other tools in making certification decisions (the 

process of assuring that agencies’ Senior Executive Service (SES) 

performance-based pay systems meet certain criteria before they can 

receive the pay flexibilities) will be important so that agencies can make 

continuous improvements to their systems to support the development of 

a stronger performance culture and the attainment of their missions, 

goals, and objectives. We recommended that OPM strengthen its 

communications with agencies and executives on the importance of 

making meaningful distinctions in performance while avoiding the use of 

forced distributions and that a fully successful rating is valued and 

rewarded. OPM has since implemented that recommendation by 

strengthening its communications and providing additional guidance to 

agencies and executives. We also recommended that OPM and OMB 

should explore opportunities for streamlining the certification process and 
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

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in March 2011, OPM in coordination with OMB established an 

interagency working group to help streamline the appraisal system 

certification process and focus requirements and regulations on a set of 

priority outcomes and management goals. According to OPM, during the 

summer of 2011, OPM led a team of agency representatives – including 

SES members – from 29 agencies and organizations to develop a basic 

SES appraisal system to meet the needs of Executive Branch agencies 

and their SES members. The new basic SES appraisal system designed 

by the 2011 work group was issued by OPM and OMB on January 4, 

2012. Agencies adopting the basic SES appraisal system have access to 

a streamlined system certification process. As of March 29, 2013, 58% of 

agencies with an SES appraisal system have adopted the basic system. 

The Chief Human Capital Officer Council recently formed the Hiring 

Reform Part II Working Group to examine strategies that will sustain and 

build upon the improvements made to the Federal hiring process during 

Hiring Reform Part I

We currently have no open recommendations or matters for 

congressional consideration related to this priority goal.

Results-Oriented Management: Opportunities Exist for Refining the 

Oversight and Implementation of the Senior Executive PerformanceBased Pay System. GAO-09-82. Washington, D.C.: November 21, 2008.

Office of Personnel Management: Key Lessons Learned to Date for 

Strengthening Capacity to Lead and Implement Human Capital Reforms. 

GAO-07-90. Washington, D.C.: January 19, 2007.

Results-Oriented Cultures: Creating a Clear Linkage between Individual 

Performance and Organizational Success. GAO-03-488. Washington, 

D.C: March 14, 2003.

Robert Goldenkoff, Director, Strategic Issues, goldenkoffr@gao.gov, 

(202) 512-2757.

Yvonne Jones, Director, Strategic Issues, jonesy@gao.gov, (202) 512-

2717.

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports

GAO Contact
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

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Increase health insurance choices for Americans. By October 1, 2013, 

expand competition within health insurance markets by ensuring 

participation of at least two multi-state health plans in the State Affordable 

Insurance Exchanges.

Our past work has not specifically focused on the priority goal of ensuring 

the participation of at least two multi-state health plans in each insurance 

exchange. However, we know from prior work that OPM had awarded a 

contract by early 2011 to provide policy and analytical support for this 

effort, and in March of 2012 it had issued a notice of proposed 

rulemaking.

The achievement of this goal will require OPM to contract with multiple 

private health insurance issuers and to coordinate closely with HHS, 

which is partnering with states to assure an operating Affordable 

Insurance Exchange in each state by January 1, 2014. Our work on 

OPM’s role overseeing the Federal Employees Health Benefits Program 

and its role in implementing the high risk pool program under the Patient 

Protection and Affordable Care Act are illustrative of OPM’s experience in 

two activities central to the achievement of this goal.

• Negotiate and contract with health insurance issuers. Through its 

oversight of the Federal Employees Health Benefits Program, OPM 

has long been responsible for selecting, contracting with, and 

regulating hundreds of health insurance issuers that offer health plans 

to millions of federal employees, dependents and retirees, as well as 

negotiating benefits and premium rates, as we reported in December 

2002. OPM will likely leverage this experience and these relationships 

to contract with issuers to offer plans through state exchanges.

• Coordinate and collaborate with other agencies. In July 2011, we 

reported on OPM’s recent collaboration with HHS in implementing the 

new Pre-Existing Condition Insurance Plan (high risk pool) program 

required under the Patient Protection and Affordable Care Act. Under 

an interagency agreement, OPM assists with the administration of the 

program, including reviewing the performance of the health insurance 

issuer chosen to offer health plans within the federal program, and 

overseeing its operations on an ongoing basis.

Goal Statement 

GAO Comments
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

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We currently have no open recommendations or matters for 

congressional consideration related to this priority goal.

Patient Protection and Affordable Care Act: Contracts Awarded and 

Consultants Retained by Federal Departments and Agencies to Assist in 

Implementing the Act. GAO-11-797R. Washington, D.C.: July 14, 2011.

Pre-existing Condition Insurance Plans: Program Features, Early 

Enrollment and Spending Trends, and Federal Oversight Activities. 

GAO-11-662. Washington, D.C.: July 27, 2011.

Federal Employees’ Health Plans: Premium Growth and OPM’s Role in 

Negotiating Benefits. GAO-03-236. Washington, D.C.: December 31, 

2002.

John E. Dicken, Director, Health Care, dickenj@gao.gov, 202-512-7043.

Stanley J. Czerwinski, Director, Strategic Issues, czerwinskis@gao.gov, 

202-512-6520.

Maintain speed of national security background investigations. Through 

September 30, 2013, maintain a 40 day or less average completion time 

for the fastest 90 percent of initial national security investigations.

OPM’s priority goal of maintaining a 40 day or less average completion 

time for the fastest 90 percent of initial national security investigations is 

related to an area we previously designated as high risk. Specifically, in 

January 2005 we first placed DOD’s security clearance program—which 

comprises the vast majority of government-wide clearances—on our High

Risk List because we identified significant delays in completing security 

clearances, which sometimes took up to a year to complete. OPM is 

currently the investigative service provider for the majority of the 

executive branch, including DOD. We removed the high-risk designation 

from DOD’s program in February 2011 due to both high-level attention 

from various executive branch agencies, including DOD, OMB, and the 

Director of National Intelligence and improvement in the timeliness of 

DOD clearances, among other things. For example, we found in January 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports

GAO Contacts

Goal Statement

GAO Comments
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

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2011 that DOD met the congressionally directed Intelligence Reform and 

Terrorism Prevention Act of 20044 goal of 40 days for initial investigations 

throughout fiscal year 2010. This timeliness measure does not include 

data on periodic reinvestigations.5

While OPM conducts background investigations for most of the federal 

government, executive branch agencies conduct other phases in the 

federal government’s personnel security clearance process. For example, 

the requesting agency determines which positions—military, civilian, or 

private-industry contracts—require access to classified information and, 

therefore, which people must apply for and undergo a security clearance 

investigation. OPM, in turn, conducts these investigations using federal 

investigative standards and OPM internal guidance as criteria for 

collecting background information on applicants. Adjudicators from the 

requesting agencies use the information contained in the resulting OPM 

investigative reports and consider federal guidelines to determine whether 

an applicant is eligible for a personnel security clearance.

Timeliness data for investigations is 

OPM’s responsibility as the investigative service provider for DOD. For 

example, the fastest 90 percent of DOD initial clearance investigations 

were processed by OPM in an average of 35 days in fiscal year 2010. In 

addition, in 2010 the Performance Accountability Council (PAC) reported 

that OPM was meeting investigation timeliness goals for many of the 

agencies for which it conducts national security background 

investigations. However, we have not comprehensively reported on the 

timeliness statistics for all of the national security background 

investigations conducted by OPM. Instead, our previous work has 

focused on the timeliness of DOD clearances because DOD’s program 

was on our High Risk List.

During the time while DOD’s security clearance program was on our High

Risk List, the executive branch initiated actions to reform the governmentwide security clearance process, in which OPM had a role as the 

investigative service provider. As part of this government-wide reform 

effort, Executive Order 13467 established a leadership structure by 

 

4

Pub. L. No. 108-458, § 3001, 118 Stat. 3638 (2004) (codified at 50 U.S.C. § 435b).

5

A periodic reinvestigation is the renewal of initial security clearance. A top secret 

clearance requires a periodic reinvestigation every 5 years after the initial clearance is 

granted and a secret clearance requires a periodic reinvestigation every 10 years after the 

initial clearance is granted. 
Appendix VI: Comments on the Office of 

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creating the PAC. The order appointed the Deputy Director for 

Management at OMB as the chair of the council and designated the 

Director of National Intelligence as the Security Executive Agent and the 

Director of OPM as the Suitability Executive Agent. The PAC is 

responsible for holding agencies accountable for the implementation of 

suitability, security, and, as appropriate, contractor employee fitness 

processes and procedures. In turn, the PAC issued a Strategic 

Framework in February 2010, which set forth a mission and strategic 

goals, performance measures, a communications strategy, roles and 

responsibilities, and metrics to measure the quality of security clearance 

investigations and adjudications. Some of the goals and performance 

measures developed by the PAC were aimed at addressing the 

timeliness of initial security clearance investigations. In addition to the 

timeliness of initial investigations and as the result of our work, members 

of Congress and federal agencies have expressed concerns about the 

quality of the background investigations. The leaders of the PAC also 

committed to measuring the quality of investigations by further developing 

quality metrics in a memorandum to Congress on May 31, 2010. While 

OPM’s agency priority goal to measure timeliness is important; it does not 

capture the competing priority of measuring the quality of the 

investigations. Finally, the Intelligence Reform and Terrorism Prevention 

Act required the executive branch to annually report on timeliness of 

background investigations; however, this requirement expired in 2011, so 

there is no mechanism to report the timeliness of the end-to-end 

clearance process—including timeliness of initiation and adjudication 

phases of the process, the timeliness of investigations that took OPM 

longer than 40 days to complete, or other security clearance reformrelated goals—to Congressional oversight committees.

In our May 2009 report, we recommended that the Director of OPM direct 

the Associate Director of OPM’s Federal Investigative Services Division to 

measure the frequency with which its investigative reports meet federal 

investigative standards in order to improve the completeness of future 

investigation documentation. As of March 2013, OPM has not 

implemented the recommendation to measure how frequently 

investigative reports meet federal investigative standards. Instead, OPM 

assesses the quality of investigations based on voluntary reporting from 

customer agencies. Specifically, OPM tracks investigations that are (1) 

returned for rework from the requesting agency; (2) identified as deficient 

using a web-based survey; and (3) identified as deficient through 

adjudicator calls to OPM’s quality hotline. In our past work, we noted that 

the number of investigations returned for rework is not by itself a valid 

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 
Appendix VI: Comments on the Office of 

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indicator of the quality of investigative work because adjudication officials 

said they were reluctant to return incomplete investigations in anticipation 

of delays that would impact timeliness. Further, relying on agencies to 

voluntarily provide information on investigation quality may not reflect the 

quality of OPM’s total investigation workload. One of OPM’s customer 

agencies, DOD developed and implemented a tool known as RAISE to 

monitor the quality of investigations completed by OPM, However, OPM 

does not use DOD’s tool. According to an OPM official, OPM is working 

through the PAC to decide how the executive branch will measure quality 

government-wide. While the PAC considered using DOD’s RAISE tool, 

among others, according to the OPM official, they opted to develop 

another tool that better captures quality. Further, the OPM official stated 

OPM’s intent to implement that tool once it is developed by the PAC, but 

did not provide an estimated timeframe for development and 

implementation. Our prior work noted that in May 2010, leaders of the 

reform effort provided congressional members with metrics assessing 

quality and other aspects of the clearance process.6 According to officials 

from one of the PAC’s working groups, these metrics were communicated 

to executive branch agencies in June 2010. RAISE was one tool the 

reform team members planned to use for measuring quality. 

Personnel Security Clearances: Continuing Leadership and Attention Can 

Enhance Momentum Gained from Reform Effort. GAO-12-815T. 

Washington, D.C.: June 21, 2012.

Background Investigations: Office of Personnel Management Needs to 

Improve Transparency of Its Pricing and Seek Cost Savings. 

GAO-12-197. Washington, D.C.: February 28, 2012.

High-Risk Series: An Update. GAO-11-278. Washington, D.C.: February 

2011.

Personnel Security Clearances: Progress Has Been Made to Improve 

Timeliness but Continued Oversight Is Needed to Sustain Momentum. 

GAO-11-65. Washington, D.C.: November 19, 2010.

 

6

GAO, Personnel Security Clearances: Progress Has Been Made to Improve Timeliness 

but Continued Oversight Is Needed to Sustain Momentum, GAO-11-185T (Washington, 

D.C.: Nov. 16, 2010). 

Selected GAO Reports
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

Page 112 GAO-13-174 Agency Priority Goals

Personnel Security Clearances: An Outcome-Focused Strategy Is 

Needed to Guide Implementation of the Reformed Clearance Process. 

GAO-09-488. Washington, D.C.: May 19, 2009.

DOD Personnel Clearances: Comprehensive Timeliness Reporting, 

Complete Clearance Documentation, and Quality Measures Are Needed 

to Further Improve the Clearance Process. GAO-09-400. Washington, 

D.C.: May 19, 2009.

Brenda S. Farrell, Director, Defense Capabilities and Management, 

farrellb@gao.gov, 202-512-3604. 

Reduce federal retirement processing time. By July 31, 2013, Retirement 

Services will have reduced its case inventory so that 90 percent of all 

claims will be adjudicated within 60 days.

OPM’s efforts to reduce federal retirement processing time have included 

attempts over 2 decades to modernize its retirement processing system 

by automating paper-based processes and replacing antiquated 

information systems. However, these efforts have been unsuccessful due 

to weaknesses in key management practices. Our previous reviews have 

identified weaknesses in project management, risk management, 

organizational change management, system testing, cost estimating, and 

progress reporting. Specifically, in February 2005, we made 

recommendations to address weaknesses in the following areas:

• Project management: OPM had defined major components of its 

retirement modernization effort, such as data conversion of paper files 

and development of electronic processes for capture and storage of 

data. However, it had not identified the dependencies among these 

efforts, increasing the risk that delays in one activity could have 

unforeseen impacts on the progress of others.

• Risk management: OPM did not have a process for identifying and 

tracking project risks and mitigation strategies on a regular basis. 

Thus, OPM lacked a mechanism to address potential problems that 

could adversely impact the cost, schedule, and quality of the 

modernization effort.

• Organizational change management: OPM had not adequately 

prepared its staff for changes to job responsibilities resulting from the 

modernization by developing a detailed transition plan. The absence 

GAO Contact

Goal Statement

GAO Comments
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

Page 113 GAO-13-174 Agency Priority Goals

of such a plan could lead to confusion about roles and responsibilities 

and hinder effective system implementation.

In January 2008, as OPM was on the verge of deploying an automated 

retirement processing system, we reported deficiencies in management 

capabilities, and made recommendations to address them: 

• Testing: The results of tests 1 month prior to the deployment of a 

major system component revealed that it had not performed as 

intended. These defects, along with a compressed testing schedule, 

increased the risk that the retirement processing system would not 

work as intended upon deployment.

• Cost estimating: The cost estimate OPM developed for the 

modernization effort was not fully reliable. This meant that the agency 

did not have a sound basis for formulating budgets or developing a 

program baseline.

• Progress reporting: The baseline against which OPM was measuring 

the progress of the program did not reflect the full scope of the 

program; this increased the risk that variances from planned 

performance would not be detected.

In April 2009, we reported that OPM continued to have deficiencies in its 

cost estimating, progress reporting, and testing practices and we made 

recommendations to address these deficiencies, as well as additional 

weaknesses in the planning and oversight of the modernization effort. 

OPM agreed with these recommendations and began to address them, 

but the agency cancelled its most recent large-scale retirement 

modernization effort in February 2011.

In November 2011, agency officials, including the Chief Information 

Officer, Chief Operating Officer, and Associate Director for Retirement 

Services, told us that OPM does not plan to initiate another large-scale 

effort to modernize the retirement process. Rather, the officials said the 

agency intends to take targeted steps to improve retirement processing. 

More recently, in January 2012, OPM released a new plan to improve 

retirement processing that aims at targeted, incremental improvements 

rather than a large-scale modernization. Under this plan, the agency 

expects to eliminate its retirement processing backlog by July 2013 and 

accurately process 90 percent of its cases within 60 days. To meet this 

goal, OPM reported that it plans to hire and train 76 new staff to address 

retirement claims; establish higher production standards and identify 

potential retirement process improvements; and work with other agencies 

to improve the accuracy and completeness of the data they provide to 

OPM for use in retirement processing. However, as we have previously 
Appendix VI: Comments on the Office of 

Personnel Management’s Priority Goals

Page 114 GAO-13-174 Agency Priority Goals

noted in February 2012, the plan does not address improving or 

eliminating the legacy information systems that currently support 

retirement processing. Although we have not assessed OPM’s actions or 

progress toward fulfilling its January 2012 plan, Performance.gov was 

updated to include information about the agency’s progress in December 

2012. For example, the agency reported that it had met its targets for 

hiring new staff, as well as improving the accuracy and completeness of 

retirement data other agencies provide to OPM.

We currently have no open recommendations or matters for 

congressional consideration related to this priority goal.

OPM Retirement Modernization: Progress Has Been Hindered by 

Longstanding Information Technology Weaknesses. GAO-12-430T. 

Washington, D.C.: February 1, 2012.

OPM Retirement Modernization: Longstanding Information Technology 

Management Weaknesses Need to Be Addressed. GAO-12-226T. 

Washington, D.C.: November 15, 2011.

Office of Personnel Management: Retirement Modernization Planning 

and Management Shortcomings Need to Be Addressed. GAO-09-529. 

Washington, D.C.: April 21, 2009.

Office of Personnel Management: Improvements Needed to Ensure 

Successful Retirement Systems Modernization. GAO-08-345. 

Washington, D.C.: January 31, 2008.

Office of Personnel Management: Retirement Systems Modernization 

Program Faces Numerous Challenges. GAO-05-237. Washington, D.C.: 

February 28, 2005.

Valerie C. Melvin, Director, Information Management and Technology 

Resources Issues, melvinv@gao.gov, (202) 512-6304.

Status of Key Open 

Recommendations and 

Matters for Congressional 

Consideration 

Selected GAO Reports

GAO Contact 
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 115 GAO-13-174 Agency Priority Goals

Appendix VII: Comments from the 

Department of Veterans Affairs

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix. 

Page numbers in draft 

report may differ from 

those in this report.
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 116 GAO-13-174 Agency Priority Goals

See comment 1.

See comment 2.
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 117 GAO-13-174 Agency Priority Goals
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 118 GAO-13-174 Agency Priority Goals

1. Although our report included information about VA’s Strategic Plan to 

Eliminate the Compensation Claims Backlog in a subsequent 

paragraph, we revised the cited paragraph to note that VA, in 

response to our December 2012 report, published the plan on 

January 25, 2013. 

2. We revised the cited paragraph to focus on VA’s Strategic Plan to 

Eliminate the Compensation Claims Backlog. However, as VA 

acknowledges in its comments, the plan does not provide individual 

performance goals and metrics for all initiatives. We continue to 

believe that without performance goals and measures clearly aligned 

with each of its initiatives, VA lacks assurance that it is spending its 

limited resources on proven methods to speed up disability claims and 

appeals processes. 

GAO Comments
Appendix VIII: GAO Contact and Staff 

Acknowledgments

Page 119 GAO-13-174 Agency Priority Goals

J. Christopher Mihm, (202) 512-6806 or mihmj@gao.gov

In addition to the above contact, Elizabeth Curda (Assistant Director) and 

Benjamin T. Licht supervised this review and the development of the 

resulting report. Virginia Chanley, Karin Fangman, Patricia Norris, Daniel 

Ramsey, and Dan Webb made significant contributions to this report. 

Robert Gebhart, Donna Miller, Jessica Nierenberg, and Ulyana 

Panchishin also made key contributions.

Appendix VIII: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff Acknowledgments

(450992)
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