CONGRESSIONALLY 

CHARTERED 

ORGANIZATIONS

Key Principles for 

Leveraging Nonfederal 

Resources

Report to Congressional Committees

June 2013

GAO-13-549

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-549, a report to 

Congressional Committees

June 2013

CONGRESSIONALLY CHARTERED 

ORGANIZATIONS 

Key Principles for Leveraging Nonfederal Resources

Why GAO Did This Study

Through congressional charters, 

Congress has created independent 

organizations which receive support 

from federal and nonfederal sources. 

These organizations, known as CCOs,

are authorized to receive and retain 

financial and nonfinancial resources 

from nonfederal partners to help meet 

their core mission and goals. In 2012, 

GAO was directed to study CCOs. To 

determine whether selected CCOs 

offer lessons learned to facilitate the 

leveraging of nonfederal resources, 

GAO studied (1) factors, if any, that 

facilitated selected CCOs’ ability to 

partner with the nonfederal sector and 

(2) key principles to better leverage 

resources through nonfederal partners.

To do this, GAO reviewed relevant 

federal laws, regulations, and policies; 

analyzed relevant legal authorities, 

agency documents, and prior GAO 

reports; conducted site visits to the four

CCOs; and reviewed literature on 

partnerships. GAO compiled key 

principles, discussed and validated

them with subject matter specialists

and the four CCOs, and incorporated 

their feedback, as appropriate. 

What GAO Recommends

To provide more complete information 

about CCOs’ fiscal position and 

strategies for leveraging resources 

from and strengthening relationships 

with nonfederal partners, 

congressional committees should 

consider requiring that the CCOs under 

their jurisdiction report on their total 

nonfederal funds—including a 

breakdown of the amounts and uses—

in their annual budget requests. All of 

the CCOs GAO studied generally

agreed with the report’s findings and 

provided technical comments, which 

GAO incorporated, as appropriate.

What GAO Found

Four factors facilitated the ability of the U.S. Holocaust Memorial Museum, 

National Gallery of Art, Presidio Trust, and Smithsonian Institution to leverage 

nonfederal resources: (1) unique legal authorities and management flexibilities; 

(2) benefits received from these congressionally chartered organizations’ (CCO) 

federal status; (3) governing boards that provided management and oversight;

and (4) informal networks that enabled CCOs to share lessons. A critical 

flexibility is the ability to accept gifts and solicit private donations, but the CCOs 

in this study are not required to, and did not always provide, a complete picture of 

nonfederal resources to Congress. The federal budget process is the primary 

means by which the President and Congress select among competing demands 

for federal funds; as such, it is essential that budget information be 

comprehensive and clear. While Congress does not direct the CCOs’ use of 

nonfederal funds, consistent and timely information about CCOs’ total resources

could provide important context for understanding both the relative tradeoffs 

among funding decisions and the implications of such decisions. 

GAO compiled six key principles to guide CCOs’ management decisions about 

leveraging resources through nonfederal partners. 

1. Make partnering decisions in line with mission. Organizations that leverage 

partnering arrangements have clear, well-articulated missions; strategic goals to 

achieve them; and a defined process for assessing whether partnering 

arrangements complement their missions and goals.

2. Ensure top leadership support for partnering arrangements. Top leadership 

support is critical to successfully pursuing and engaging partners. The tone at the 

top—management's philosophy and operating style—sets the stage for how the 

organization will make management decisions related to partnering. 

3. Assess and manage risks. Partnering decisions should reflect both the likely 

risk and the organization’s tolerance for risk in partnering. Incorporating risk 

assessment and risk management practices into partnering decisions can help 

ensure that the organization recognizes and is prepared to manage explicit risks 

(e.g., financial and physical) and implicit risks (e.g., reputational). 

4. Select complementary partners and appropriate projects. Partners should 

bring complementary resources, skills, and financial capacities to the 

relationship. A systematic approach helps to identify projects that are well-suited 

for partnering opportunities and helps to achieve an organization’s mission.

5. Manage partnering arrangements. Partnering arrangements are relationships 

that should be managed actively. Formalizing collaborations between the 

partners, including documenting dispute resolution processes, can enable 

productive partner interactions. Further, it is important to have the staff with the 

right skills and experience to manage these opportunities.

6. Evaluate partnering arrangements. Information about how well existing 

partnering arrangements leverage nonfederal resources could inform decisions 

about continuing arrangements or entering into new ones. Gathering this 

information also presents an opportunity to evaluate progress toward a project’s 

intended goals.

View GAO-13-549. For more information, 

contact Susan J. Irving, Director for Federal 

Budget Analysis, at (202) 512-6806 or 

irvings@gao.gov. 
Page i GAO-13-549 Congressionally Chartered Organizations

Letter 1 

Background 4

Four Factors Facilitate CCOs’ Ability to Leverage Nonfederal 

Resources, but Information on These Resources Provided to 

Congress in Budget Requests Varies by CCO 9

Six Key Principles Helped CCOs Leverage Resources through 

Nonfederal Partners 16

Conclusions 33

Matter for Congressional Consideration 34

Agency Comments and Our Evaluation 34

Appendix I Selected Examples of How Congressionally Chartered 

Organizations Leveraged Nonfederal Resources 36

Appendix II Comments from the National Gallery of Art 38

Appendix III GAO Contacts and Staff Acknowledgments 40

Tables

Table 1: Attributes of Four Selected Congressionally Chartered 

Organizations (CCO), Fiscal Year 2012 (Dollars in Millions) 5

Table 2: Key Principles and Elements Helpful for Congressionally 

Chartered Organizations to Leverage Resources 17

Contents 

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Page 1 GAO-13-549 Congressionally Chartered Organizations

441 G St. N.W.

Washington, DC 20548

June 7, 2013

The Honorable Jack Reed

Chairman

The Honorable Lisa Murkowski

Ranking Member

Subcommittee on Interior, Environment, and Related Agencies

Committee on Appropriations

United States Senate

The Honorable Michael K. Simpson

Chairman

The Honorable Jim Moran

Ranking Member

Subcommittee on Interior, Environment, and Related Agencies

Committee on Appropriations

House of Representatives

Through congressional charters, Congress has created independent 

organizations which receive support from both federal and nonfederal 

resources. These congressionally chartered organizations (CCO) are 

authorized to receive and retain financial and nonfinancial resources from 

nonfederal partners to help meet their core mission and goals.1,2

Congress has chartered organizations for diverse purposes, but CCOs 

generally have missions and goals dedicated to promoting a public 

purpose to which private individuals and nonfederal partners are drawn. 

CCOs have been described as being perceived to be better suited than 

Nonfederal financial resources generally take the form of private 

donations while nonfinancial resources may include specialized skills, 

artifacts and exhibitions, or infrastructure that CCOs leverage to meet 

their management and operational duties.

 

1 Nonfederal partners include nonprofit organizations, research institutions, for-profit 

businesses, international entities (such as national museums and private arts 

organizations), and individuals. CCOs work with these partners to further research goals, 

enhance programmatic offerings, strengthen internal operations, raise private funds, and 

generate business revenues.

2 Generally, if an agency does not have statutory authority to accept donations of money, 

it must turn the money in to the Treasury as miscellaneous receipts. 

 
 

Page 2 GAO-13-549 Congressionally Chartered Organizations

typical government agencies to handle certain issues and deliver services 

by partnering activities with nonfederal entities to produce public value 

greater than what the federal government can accomplish alone. We 

have previously reported that many of the meaningful results that the 

federal government seeks to achieve require the coordinated efforts of 

more than one federal agency, level of government, or sector.3

The report accompanying the Fiscal Year 2012 Interior, Environment, and 

Related Agencies Appropriations Bill directed us to study CCOs. This 

study addresses whether CCOs under the subcommittees’ jurisdiction 

offer examples and lessons learned from leveraging partners that enable 

the government to share costs with the private sector. To do this, we (1) 

determined factors, if any, that facilitated selected CCOs’ ability to partner 

with the nonfederal sector and (2) compiled key principles to better 

leverage resources through nonfederal partners.

For the purposes of this report, we define CCOs as entities that (1) were 

created by Congress; (2) have the authority to receive appropriations 

directly and not just through another federal agency; (3) have the 

authority to receive nonfederal funds; (4) are subject to congressional 

oversight; and (5) are managed or advised by a board or commission that 

includes government officials, presidential or congressional appointees, 

or both. Based on this definition, we identified nine CCOs in the 

committees’ fiscal year 2012 appropriation.4

To study how CCOs leveraged resources of nonfederal partners, we 

selected a nongeneralizable sample of four CCOs within the committees’ 

jurisdiction. The four selected CCOs represent a range of organization 

 

3 See GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012); and 

Results Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration Among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

4 Pub. L. No. 112-74, div E. 125 Stat.786 (Dec. 23, 2011).The nine CCOs we identified, 

which provide a wide range of services and receive a varying amount of federal 

appropriations, are the: Dwight D. Eisenhower Memorial Commission ($42 million federal 

appropriations in fiscal year 2012), Institute of American Indian and Alaska Native Culture 

and Arts Development ($9 million), John F. Kennedy Center for the Performing Arts ($37 

million), National Foundation on the Arts and the Humanities ($292 million), National 

Gallery of Art ($128 million), Holocaust Memorial Museum ($51 million), Presidio Trust 

($12 million), Smithsonian Institution ($810 million), and Woodrow Wilson International 

Center for Scholars ($11 million).
 

Page 3 GAO-13-549 Congressionally Chartered Organizations

types and services, and leverage nonappropriated funds to different 

extents. They are the U.S. Holocaust Memorial Museum, the National 

Gallery of Art, the Presidio Trust, and the Smithsonian Institution.

To conduct our work, we visited these four CCOs to observe partnering 

efforts and to meet with officials responsible for those activities.5

To help put the experiences of these four CCOs in context, we also 

looked to our body of work on the Valles Caldera Trust for additional 

lessons learned.

We 

analyzed relevant documentation related to CCOs’ partnering activities, 

such as legal authorities, strategic and annual plans, bylaws and policies, 

budget documents, and reports to Congress. We reviewed relevant 

federal laws, regulations, and policies and analyzed relevant legal 

authorities. We also reviewed our past work and reports from the 

Congressional Research Service and the National Academy of Public 

Administration. At the four CCOs, we interviewed cognizant officials and 

board members about how they leveraged resources through nonfederal 

partners and what factors facilitated those partnering efforts. We spoke 

with officials that were involved in partnering arrangements, as identified 

by each CCO. To develop themes and examples from our documentary 

and testimonial evidence, we analyzed information from relevant 

documents and responses to our interview questions to identify and 

confirm common patterns. We did not independently verify the quality of 

the CCOs’ partnering efforts nor interview their partners.

6 Congress created the Valles Caldera Trust in 2000 and 

modeled its governance structure after the Presidio Trust. We reviewed 

our prior work and have included information collected during routine 

agency follow-up on open recommendations conducted in February 2013 

to ensure we had the most current information about the Valles Caldera 

Trust’s experience.7

 

5 The CCOs we studied partnered with the nonfederal sector—including other museums, 

businesses, academics, foreign entities, and individuals—on activities such as exhibitions, 

food and gift sales, media, and programming.

6 GAO, Valles Caldera: Trust Has Made Some Progress, but Needs to Do More to Meet 

Statutory Goals, GAO-06-98 (Washington, D.C.: Nov. 16, 2005); and Valles Caldera: The 

Trust Has Made Progress but Faces Significant Challenges to Achieve Goals of the 

Preservation Act, GAO-10-84 (Washington, D.C.: Oct. 30, 2009). 

7 We did not conduct new audit work on the Valles Caldera Trust for this study.
 

Page 4 GAO-13-549 Congressionally Chartered Organizations

To compile key principles that CCOs follow to better leverage resources 

through nonfederal partners, we conducted a literature review of reports 

and academic papers on public-private partnerships and partnering 

arrangements. We identified six principles. We incorporated into the 

principles lessons learned and good practices from the four CCOs we 

visited. We discussed and validated these principles with federal and 

academic researchers who study partnerships; these subject matter 

specialists generally agreed with these principles and provided 

comments, which we incorporated as appropriate. We also compared 

these six principles with key issues that we have identified when 

organizations work collaboratively.8

We conducted this performance audit from April 2012 to June 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.

Finally, we sought feedback on the 

principles from the four CCOs we visited. CCO officials agreed with the 

six principles we compiled and provided specific comments on elements 

of these principles, which we incorporated as appropriate.

CCOs are congressionally created entities that are in part privately 

funded but operate under some level of government oversight, generally 

through the appointment of their leadership, management oversight, or 

additional regulation.9

 

8 See 

The missions of these entities vary substantially, 

GAO-06-15 and GAO-12-1022. 

9 There are many types of CCOs, including nonprofit organizations. There are about 90 

nonprofit organizations that were incorporated first under state law and later granted a 

charter from Congress. These nonprofits, known as “Title 36 organizations” include the 

Girl Scouts of America and the National Academy of Public Administration. These 

organizations are not agencies of the United States and their charters do not assign the 

corporate bodies any governmental attributes, such as guaranteeing their debt explicitly or 

implicitly. Title 36 organizations view a charter as a statement of congressional support for 

the nonprofit organization’s mission. The four CCOs we studied are not considered Title 

36 organizations.

Background 
 

Page 5 GAO-13-549 Congressionally Chartered Organizations

but individually they are narrowly defined. Table 1 provides attributes of 

the four CCOs selected for our review.10

Table 1: Attributes of Four Selected Congressionally Chartered Organizations (CCO), Fiscal Year 2012 (Dollars in Millions) 

Year 

congressionally 

chartered Net assets

Federal and 

nonfederal 

revenues

Federal 

appropriations 

to CCO a

Smithsonian Institution: 

Museum and research complex headquartered in 

Washington, D.C. 

1846 $3,039 $583 $810

National Gallery of Art: 

Museum of American and European art in Washington, D.C. 

1937 $988 $144 $128 b

U.S. Holocaust Memorial Museum:

Living memorial to the Holocaust in Washington, D.C.

1980 $328 $74 $51 c

Presidio Trust: 

Urban national park in San Francisco, CA

1996 $285 $100 $12

Source: Fiscal year 2012 CCO financial statements, fiscal year 2012 CCO performance and accountability reports, fiscal year 2013 

CCO congressional budget requests; the Presidio Trust’s detailed budget from fiscal year 2011 to 2017; and the Holocaust Memorial 

Museum mission statement and its Chief Financial Officer.

a

Included in this figure are funds received from other federal agencies, such as through government 

grants, or government contracts. This does not include appropriations to the four CCOs.

b

According to its Treasurer, the National Gallery of Art does not typically receive funds from other 

federal agencies. However, in fiscal year 2012, it received less than $5,000 for the disposal of surplus 

equipment from the General Services Administration.

c

The Holocaust Memorial Museum did not receive funds from any federal agencies.

The Smithsonian Institution was established with funds from James 

Smithson, a British scientist who, on his death in 1829, left his estate to 

the United States to found “at Washington, under the name of the 

Smithsonian Institution, an establishment for the increase and diffusion of 

knowledge.” The Smithsonian Institution opened to the public in 1855, 

and has since become the world’s largest museum and research complex 

with 19 museums, the National Zoo, and nine research facilities in 

Washington, D.C., 7 states, and Panama. There were 30.3 million visitors 

to the institution’s museums and zoo in 2012.

 

10 Although the four CCOs we studied received nonappropriated funds, they are different 

from nonappropriated fund instrumentalities (NAFI). NAFIs are entities or activities that do 

not receive appropriations. NAFIs raise their own operating funds through product sales, 

member fees, and so forth. Absent statutory provisions to the contrary, the United States 

assumes none of the financial obligations of a NAFI.
 

Page 6 GAO-13-549 Congressionally Chartered Organizations

The National Gallery of Art was created in 1937 for the American people 

by Congress, accepting the gift of financier and art collector Andrew W. 

Mellon, who wished that his private art collection be the basis of a 

national art museum. Funds for the construction of the original building 

were provided by the A. W. Mellon Educational and Charitable Trust. The 

President accepted the completed building and the Mellon collection on 

behalf of the American people in 1941. There were 4.2 million visits to the 

museum in fiscal year 2012.

In 1979, the newly-formed President’s Commission on the Holocaust 

recommended that a living memorial be established to honor the victims 

and survivors of the Holocaust and to ensure that the lessons of the 

Holocaust would be taught in perpetuity. The Holocaust Memorial 

Museum was chartered in 1980 and opened to the public in 1993. The 

museum is situated on federal land on the national mall and was built 

entirely with private funds. There were 1.6 million visitors to the museum 

in fiscal year 2012.11

Spain established the Presidio of San Francisco as its northern most 

military outpost in the New World in 1776. The U.S. Army took control of 

the military base in 1847 and later transformed it into part of the nation’s 

coastal defense system. The Presidio served as an active military 

installation until 1994, when it was transferred to the National Park 

Service. In 1996, Congress created the Presidio Trust and mandated that 

it preserve the site’s natural, cultural, scenic, and recreational resources. 

Congress assigned 80 percent of the park’s 1,500 acres to the Presidio 

Trust; the National Park Service continues to manage the remaining 20 

percent (coastal areas). Congress directed that the Presidio Trust attain 

financial self-sufficiency 15 years after the first meeting of the Trust’s 

board of directors. The Presidio Trust achieved this goal and, since 

October 1, 2012, has sustained itself through a combination of 

philanthropic sources and rental income from residential and commercial 

buildings on its grounds. An estimated 4 million people visited the park in 

2012.

 

11 We recently reported on the Holocaust Memorial Council, which has overall governance 

responsibility for the Holocaust Memorial Museum, including policy guidance, strategic 

direction, and fiduciary responsibility. See GAO, Characteristics of Presidential 

Appointments that do not Require Senate Confirmation, GAO-13-299R (Washington, D.C.: 

Mar. 1, 2013).
 

Page 7 GAO-13-549 Congressionally Chartered Organizations

Congress created the Valles Caldera Trust in 2000 to preserve a unique 

volcanic parcel of land in New Mexico. Modeled after the Presidio Trust, 

the Valles Caldera Trust was considered a 20-year public-private land 

management experiment. The Valles Caldera Preservation Act authorized 

the Secretary of Agriculture to purchase about 89,000 acres, known as 

the Baca Ranch.12 The act charged the Valles Caldera Trust with 

managing the land to achieve a number of goals, including becoming 

financially self-sustaining by the end of fiscal year 2015. We found in 

2009 that while the Valles Caldera Trust had taken steps to establish and 

implement a number of programs and activities to position it to achieve 

the Preservation Act’s goals, it was at least 5 years behind the schedule it 

set to achieve in meeting those goals. We also found that its biggest selfidentified challenge was to achieve financial self-sustainability.13 As such, 

we recommended that the Chairman of the Board and Executive Director 

work with the relevant congressional committees to seek legislative 

remedies, as appropriate, for the legal challenges confronting the Valles 

Caldera Trust, such as prohibition from entering into long-term leases or 

acquiring property. When we followed up on our recommendations in 

February 2013, we found that New Mexico’s Senators had reintroduced 

legislation that would transfer ownership of the Valles Caldera National 

Preserve to the National Park Service. Because this would, in effect, 

eliminate the legal challenges we cited, as well as the goal of selfsufficiency for the Valles Caldera Trust, we have closed this 

recommendation as being implemented.14

Congress has given these CCOs a unique structure and range of 

authorities. For example, they are managed by boards of directors whose 

membership make-up is designated by statute. CCOs’ personnel and 

procurement flexibilities allow them to achieve public goals by leveraging 

 

12 Pub. L. No. 106-248, title I, § 104, 114 Stat. 598 (Jul. 25, 2000).

13 See GAO-06-98 and GAO-10-84. 

14 In 2011, a bill was introduced to transfer jurisdiction of the Valles Caldera to the 

National Park Service. However, Congress did not pass that bill. On Feb. 12, 2013, a new 

bill was introduced for the same purpose (see S. 285).
 

Page 8 GAO-13-549 Congressionally Chartered Organizations

nonfederal resources and increasing their capacity to respond more 

nimbly to the needs of the organization and attract and retain talent.15

The four CCOs we studied partnered with nonfederal entities ranging 

from nonprofit organizations and research institutes to for-profit 

businesses, international entities,16 and individuals. These partnering 

arrangements aimed to generate business revenues, further research 

goals, enhance programmatic offerings, strengthen internal operations, 

and raise private funds. These efforts are consistent with our previous 

work on collaborative efforts, which recognized that the federal 

government must identify ways to deliver results more efficiently and in a 

way that is consistent with its multiple demands and limited resources. 

Further, we found that the federal government could work together with 

the nonfederal sector to generate more public value than could be 

produced when agencies act alone.17 See appendix 1 for detailed 

examples of how the four CCOs we studied worked with nonfederal 

partners.

 

15 We have previously reported that agencies enjoying these types of flexibilities need to 

manage them with care as there may be an increased risk of reduced accountability, 

transparency, and the lack of safeguards to build fair, credible, and transparent human 

capital systems. See for example GAO, Department of Homeland Security: Further Action 

Needed to Improve Management of Special Acquisition Authority, GAO-12-557

(Washington, D.C.: May 8, 2012); and Human Capital: Observations on Final DHS Human 

Capital Regulations, GAO-05-391T (Washington, D.C.: Mar. 2, 2005).

16 CCOs partnered with international entities, such as national museums, private 

organizations, and individuals living outside the United States.

17 GAO-06-15. 
 

Page 9 GAO-13-549 Congressionally Chartered Organizations

Officials from the CCOs we studied cited four factors that facilitate their 

ability to leverage nonfederal resources: (1) unique authorities that 

provided legal flexibilities; (2) benefits received from being part of the 

federal government; (3) governing boards that provided management and 

oversight; and (4) informal networks that enabled CCOs to share lessons. 

Critical among the authorities mentioned above is the ability to accept 

gifts and solicit private donations, but the CCOs we studied are not 

required to, and did not always provide, a complete picture of their 

nonfederal resources to Congress.

A critical factor that facilitates CCOs’ ability to leverage nonfederal 

resources are unique legal authorities exempting them from certain 

federal regulations on (1) soliciting and accepting private funds and (2) 

using those funds to hire staff and procure goods. Officials from all four 

CCOs we studied said that these authorities and flexibilities allowed them 

to act more nimbly and to adapt more readily to the needs of their 

organization.

• Authority to solicit and accept private funds. The four CCOs we 

studied have the statutory authority to solicit and accept private gifts 

and donations. They are also able to retain and use these funds 

without fiscal year limitation or further congressional approval. This 

authority provides CCOs with additional financial resources beyond 

directly appropriated federal funds. Officials from the Smithsonian 

Institution told us that their donors value the institution’s flexibility to 

retain and use nonfederal funds to carry out its mission. Further, they 

noted that donors view their contributions as an addition to, not 

replacement for, federal funding. CCOs used private funds, for 

example, to build new buildings and expand their collections. An 

Four Factors 

Facilitate CCOs’ 

Ability to Leverage 

Nonfederal 

Resources, but 

Information on These 

Resources Provided 

to Congress in Budget 

Requests Varies by 

CCO

Legal Authorities, Federal 

Status, Governing Boards, 

and Informal Networks, 

Enable CCOs to Leverage 

Nonfederal Resources

Legal Authorities 
 

Page 10 GAO-13-549 Congressionally Chartered Organizations

official also explained that these authorities allow CCOs to accept 

gratis services from volunteers. Officials from all four CCOs we 

studied told us that this authority was critical to helping ensure they 

have appropriate resources to meet their organization’s mission and 

goals. Further, all four of the CCOs we studied are tax exempt under 

section 501(c)(3) of the Internal Revenue Code. The status as a 

charitable organization can facilitate fundraising efforts because 

donors are potentially eligible for tax benefits based on their 

donations. Officials told us that this status is critical to their ability to 

raise private funds. 

• Hiring and procurement flexibilities. The four CCOs we studied also 

benefit from some exemptions from federal hiring and procurement 

requirements. For example, some CCO staff are not subject to many 

of the civil service laws in Title 5, which govern the hiring of federal 

employees.18 CCO officials told us they use this flexibility to compete 

with the private sector to attract and retain certain staff—such as 

fundraisers and business development managers—whose specialized 

skills and abilities play a key role in attracting and leveraging 

nonfederal funds. Officials also said that the ability to pay these staff 

in accordance with market rates (i.e., above the federal pay scale) 

allowed them to attract and retain highly qualified individuals to serve 

in critical positions.19 In addition to being able to compete with the 

private sector in this manner, CCO officials told us that they are 

authorized to terminate staff when their specialized skills are no 

longer needed. Lastly, CCO officials noted that the general exemption 

from federal procurement laws provides CCOs with the flexibility to 

procure goods and specialized services more quickly and efficiently

than they would otherwise be able to.20

CCO officials reported they implement these managerial flexibilities in a 

way that maximizes financial resources while safeguarding the principles 

 

18 The Presidio Trust has more leeway than the other three CCOs we studied because 

Congress exempted all its employees from civil service laws.

19 While these hiring and procurement flexibilities are not typical of federal agencies, 

Congress has sometimes granted other agencies similar statutory authorities. For 

example, the Department of Homeland Security has greater leeway in recruiting, retaining, 

developing, managing, and compensating employees. See, for example, GAO, Homeland 

Security: DHS’s Actions to Recruit and Retain Staff and Comply with the Vacancies 

Reform Act, GAO-07-758 (Washington, D.C.: July 16, 2007). 

20 The Presidio Trust is still subject to federal contract laws governing working conditions, 

wage rates, and civil rights provisions. 
 

Page 11 GAO-13-549 Congressionally Chartered Organizations

these federal laws are created to uphold. For example, CCO officials told 

us that they develop policies for staff paid with nonfederal funds that 

follow the spirit of federal employment laws, when appropriate. In this 

way, they see this as helping to ensure transparency and accountability 

while still maintaining flexibility. Specifically, the Human Resources 

Director at the Presidio Trust said that its personnel policies reflect 

principles consistent with federal equal employment opportunity 

guidelines. Further, while these flexibilities are critical to their 

organizations, CCO officials said that it is often not immediately apparent 

from their enabling legislation whether a CCO is considered a federal or 

private entity for employment, benefits, insurance, federal torts, copyright 

laws, and administrative procedures, and that making these legal 

determinations can be time consuming.

Some of the most valuable resources of the four CCOs we studied have 

been derived from their federal status. CCO officials told us that this 

status provided them with significant assets and facilitated their ability to 

leverage nonfederal resources. Specifically, the Presidio is located on a 

former military reservation and the Holocaust Memorial Museum, National 

Gallery of Art, and Smithsonian Institution all enjoy exhibition and office 

space on federal land near the National Mall in Washington, D.C. Further, 

some CCOs received private collections and objects that were intended 

to be donated to the people of the United States and available as national 

assets. 

In addition to these physical assets, CCO officials cited intangible benefits 

that are derived from their federal status. For example, officials at the four 

CCOs we studied said that federal status signaled their entity’s 

permanence and therefore helped to secure nonfederal resources. One 

official explained that many private donors and partners are attracted to 

the perceived financial stability that federal ties bring, even in these times 

of shrinking federal budgets. Other officials noted that these nonfederal 

donors’ and partners’ views are tied to the belief that the federal 

government will “be around” and so their gifts will be there for future 

generations. Another official told us that partners and donors see federal 

status as an implicit recognition of the CCO’s credibility, which helps to 

bring in more donations and build relationships with other organizations. 

Officials at the four CCOs we studied also noted that private citizens’ 

willingness to contribute financial and nonfinancial resources to CCOs is 

based, in part, on their belief that these entities contribute to a greater 

public purpose. For example, Presidio Trust officials noted the its public 

mission combined with the assurance of sustained revenue created a 

powerful incentive for private citizens to donate and invest in the park.

Federal Status
 

Page 12 GAO-13-549 Congressionally Chartered Organizations

Another factor that facilitated CCOs’ ability to leverage nonfederal 

resources is access to the support and expertise of federal agencies, 

specifically the Departments of Justice and State. The Department of 

Justice represents CCOs in lawsuits and other legal matters. Additionally, 

officials from the Holocaust Memorial Museum said that the Department 

of State’s international contacts, expertise in negotiating with entities 

outside of the US, and diplomatic channels have occasionally facilitated 

the museum’s ability to resolve issues with international partners. For 

example, in negotiating agreements with foreign governments to obtain 

Holocaust-era objects and information from state-owned archives, the 

Holocaust Memorial Museum follows a template agreement developed 

and approved by the Department of State, allowing the museum to enter 

into specific types of agreements on its own authority.21

Finally, CCOs also found that the federal government immunity to state 

and local requirements facilitated their ability to leverage nonfederal 

resources. For example, Presidio Trust officials said that having exclusive 

federal jurisdiction enabled them to avoid jurisdictional confusion with 

other government entities. Specifically, these officials said that not having 

to adhere to local zoning laws helped to decrease the time needed to 

rehabilitate the Presidio Trust’s buildings. Further, they noted that the 

Presidio Trust benefited from exemption from certain state and local laws 

such as rent control. Holocaust Memorial Museum officials noted that the 

museum is exempt from having to register with each state attorney 

general for fundraising purposes because of its federal government 

status. One official added that being exempt from 50 different sets of 

fundraising restrictions relieves the museum of a significant administrative 

burden.

A third factor officials reported to be helpful in leveraging nonfederal 

resources is the valuable expertise provided by governing boards. The 

size, appointment, and duties of these boards are specified in law and 

vary among CCOs.22

 

21 According to Holocaust Memorial Museum officials, the Department of State allows the 

museum to enter into archival cooperative agreements on its own and without further 

review by the Department of State unless material changes to the template are required.

The size of these boards varies greatly among the 

22 This is consistent with our recent finding that presidential appointments that do not 

require Senate confirmation vary by establishment, location, length of service, and 

responsibilities. See GAO-13-299R. 

Governing Boards
 

Page 13 GAO-13-549 Congressionally Chartered Organizations

four CCOs we studied: The smallest has 7 members and the largest 65.23

Some of the CCOs we reviewed provided examples of the help they 

received from their governing boards. According to officials, the National 

Gallery of Art’s Board of Trustees plays an active role in fundraising and 

the Presidio Trust Board provides strategic advice on real estate, 

financial, and operational management. Additionally, the Smithsonian 

Board of Regents approves the Smithsonian Institution’s strategic plan, 

budgets, and other key documents. The Board of Regents also evaluates 

the performance of top executives and sets their pay.

Board members include a mix of presidentially appointed members, exofficio members based on a government position; such as the Chief 

Justice of the United States and the Secretary of State; and others 

including private citizens. Some boards have specific expertise and 

residency requirements for their members. For example, members of the 

Presidio Trust Board are required to have extensive knowledge of 

finance, real estate development, planning, and resource conservation or 

have expertise in these areas. Further, at least 3 board members must 

reside in the San Francisco Bay Area. CCO board member term lengths 

are also specified by law.

The importance of a stable board is evident when comparing the Valles 

Caldera experience with that of the other four CCOs we studied. Our 

previous work on the Valles Caldera Trust noted that board member 

turnover contributed to challenges, such as delays in decision making and 

false starts to programs.24

Lastly, some CCOs used informal networks to leverage nonfederal 

resources. Officials at the Smithsonian Institution and the Holocaust 

Memorial Museum meet periodically with their counterparts at other 

related organizations in informal settings to exchange lessons learned, 

seek advice on shared issues, and discuss questions specific to their 

unique legal and financial statuses. For example, the Holocaust Memorial 

In contrast, officials at the Presidio Trust and 

National Gallery of Art said that their boards have provided consistent 

guidance and leadership.

 

23 Specifically, the Presidio Trust Board has 7 members, the National Gallery of Art Board 

of Trustees has 9, the Smithsonian Board of Regents has 17, and the Holocaust Memorial 

Council has 65.

24 See GAO-06-98 and GAO-10-84. 

Informal Networks
 

Page 14 GAO-13-549 Congressionally Chartered Organizations

Museum’s General Counsel said that he has sought advice from legal 

staff at other CCOs when considering whether certain laws and 

regulations apply to the museum. Officials told us they find these 

meetings to be particularly helpful because they provide a network for 

organizations that face similar challenges to learn from each other. The 

Presidio Trust’s Executive Director expressed interest in joining such a 

network. Further, Presidio Trust officials said that it would be useful to 

have a regular forum to exchange information and ideas between 

organizations responsible for former military bases or other public 

landholdings that seek to revitalize their organization through partnering 

arrangements. They noted that it may help to meet twice a year so 

officials could discuss best practices.

The information about nonfederal funds presented to Congress in annual 

budget requests varies among the CCOs we studied.25 For example, the 

Smithsonian Institution and Holocaust Memorial Museum typically present 

some information about these funds in their annual budget requests to 

Congress, but the type of information differs. For example, the 

Smithsonian Institution summarizes the balance, source, and uses of its 

nonfederal nonappropriated funds. Further, it describes funding 

sources—including those from nonfederal resources—for its museums, 

research centers, and departments.26 In contrast, the Holocaust Memorial 

Museum provides a high-level summary of the uses of its nonfederal 

funds broken down by restricted and nonrestricted donations.27

CCO officials told us that they are not required to report on their 

nonfederal funds and congressional staffers confirmed this. However, 

While the 

National Gallery of Art reported on the nonfederal funds used for special 

exhibitions in its budget requests, it does not include information on 

nonfederal funds used for other purposes, which represents the majority 

of these funds.

 

25 We did not review the Presidio Trust’s budget request because it no longer receives 

federal appropriations as of fiscal year 2013.

26 Specifically, the Smithsonian Institution’s annual budget request presents summary 

information on general trust funds (which include sources from investment income and net 

proceeds from revenue-generating activities and programs), private donations, and 

government grants and contracts.

27 In its fiscal year 2013 budget request, the Holocaust Memorial Museum also reported 

on activities for which its restricted funds were donated. 

Information on Nonfederal 

Resources Provided to 

Congress in Budget 

Requests Varies by CCO
 

Page 15 GAO-13-549 Congressionally Chartered Organizations

federal internal control standards note that financial information is 

needed, among other things, to make operating decisions, monitor 

performance, and allocate resources. These standards further note that 

pertinent information should be identified, captured, and distributed in a 

form and time frame that permits people to perform their duties 

efficiently.28

While Congress does not direct the CCOs’ use of nonfederal funds, the 

lack of consistent information on nonfederal funds inhibits the ability to 

understand how CCOs leverage federal funds to meet their missions. 

Better information on nonfederal funds may also make clearer the donor 

and endowment restrictions on some of those funds and would also 

provide more context about the total financial resources available to 

CCOs. Although some information about nonfederal funds is available in 

the CCOs’ audited financial statements, annual reports, and publicly 

available tax returns, the timing and availability of those reports do not 

align with the typical time frames of congressional budget deliberations.

The federal budget process is the primary means by which 

the President and Congress select among competing demands for federal 

funds; as such, it is essential that budget information be comprehensive 

and clear. Consistent and timely information about CCOs’ complete 

financial picture—including both appropriated and nonfederal funds—

could provide the Congress with important context for understanding both 

the relative tradeoffs among appropriation decisions and the implications 

of such decisions for these entities. 

29

 

28 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1999). 

29 The CCOs we studied have typically released their performance and accountability 

reports and financial statements the following fiscal year. For example, the National 

Gallery of Art issued its fiscal year 2012 performance and accountability report in 

November 2012 and expects to issue its fiscal year 2012 annual report in June 2013. 

However, budget deliberations for any given fiscal year typically occur during the prior 

calendar year. For example, fiscal year 2014 budget deliberations occur during calendar

year 2013. 
 

Page 16 GAO-13-549 Congressionally Chartered Organizations

We compiled six key principles and related key questions that CCOs can 

use to guide management decisions about partnering with the nonfederal 

sector. Each principle has corresponding elements that are intended to 

enhance or facilitate CCOs’ ability to achieve each principle (see table 2). 

As previously discussed, these key principles are grounded in relevant 

literature, including our prior work; the knowledge and experience of 

internal and external subject matter specialists; and the experiences of 

the four CCOs we studied. Incorporated throughout this section are 

examples of how CCOs used elements of these principles to manage 

their partnering arrangements.30 Additionally, many of these practices are 

consistent with the key issues we have identified when agencies or other 

organizations work collaboratively.31 These principles can be tailored to 

suit different types of arrangements, partners, and CCO needs, as 

appropriate. 

 

30 Some of the partnering arrangements we studied were formalized in contracts while 

others were informal. CCOs made decisions about the extent to which they formalized 

these arrangements based on the nature of the program or project, the partner involved, 

whether the partner is located in the U.S. or abroad, and the CCOs’ financial commitment.

31 See GAO-06-15 and GAO-12-1022. 

Six Key Principles 

Helped CCOs 

Leverage Resources 

through Nonfederal 

Partners
 

Page 17 GAO-13-549 Congressionally Chartered Organizations

Table 2: Key Principles and Elements Helpful for Congressionally Chartered Organizations to Leverage Resources 

Principle Elements

Principle 1: Make partnering decisions in line with mission

Organizations that leverage partnering arrangements have clear, well-articulated 

missions; the strategic goals to achieve them; and a defined process for assessing 

whether partnering arrangements are aligned with and further the organizations’ 

missions and goals.

• Clear, well-articulated mission and goals 

facilitate appropriate partnering decisions.

• Consider whether potential partners and 

partnering arrangements are in line with 

mission and goals.

Principle 2: Ensure top leadership support for partnering arrangements

Top leadership support for partnering arrangements is critical to successfully

pursing and engaging with partners. The tone at the top—management’s 

philosophy and operating style—sets the stage for how the organization will make 

management decisions, including decisions related to partnering with the 

nonfederal sector. As a champion for these types of arrangements, leaders can 

encourage their staff and stakeholders to see the value in creatively building on 

the assets and resources of partner organizations.

• Tone at the top matters.

• Institutionalize top leadership support.

Principle 3: Assess and manage risks

Partnering decisions should reflect both the likely risk and the organization’s 

tolerance for risk in partnering. Incorporating risk assessment and risk 

management practices into partnering decisions can help ensure that the 

organization recognizes and is prepared to manage explicit risks (e.g., financial 

and physical) and implicit risks (e.g., reputational). The specific risk mitigation and 

management methodology used will likely vary by organization because of 

differences in missions and varying tolerance for risk.

• Incorporate risk assessment by formalizing 

partner selection.

• Manage partnering risks.

Principle 4: Select complementary partners and appropriate projects

Selecting appropriate partners and projects is central to a successful partnering 

arrangement. Partners should bring complementary resources, skills, and financial 

capacities to the relationship. Further, a systematic approach helps to identify 

projects that are well-suited for partnering opportunities and helps to achieve an 

organization’s mission.

• Select partners with the right resources and 

expertise.

• Create a process to systematically propose, 

evaluate, and select projects consistent with 

mission.

Principle 5: Manage partnering arrangements

Partnering arrangements are relationships between or among different parties that 

should be managed actively. Technology can enable information sharing between 

partners to facilitate the leveraging of resources. Formalizing collaborations 

between the partners, including documenting dispute resolution processes, can 

enable productive partner interactions. Further, it is important to have the staff with 

the right skills and experience to manage these opportunities.

• Use technology to leverage partner 

resources. 

• Use written documentation to foster partner 

collaboration.

• Attract and retain staff with the right skills for 

partnering.

Principle 6: Evaluate partnering arrangements

Information about how well existing partnering arrangements leverage nonfederal 

resources is important to inform decisions about continuing existing arrangements 

or entering into new ones. Gathering this information also presents an opportunity 

to evaluate progress toward a project’s intended goals.

• Evaluate how partners leverage nonfederal 

resources.

• Evaluate specific partnering arrangements.

Source: GAO.
 

Page 18 GAO-13-549 Congressionally Chartered Organizations

Organizations that leverage partnering arrangements have clear, wellarticulated missions; the strategic goals to achieve them; and a defined 

process for assessing whether partnering arrangements are aligned with 

and further the organizations’ missions and goals. This is consistent with 

our past work noting that organizations must have a clear and compelling 

rationale to work together to overcome significant differences in missions, 

cultures, and established ways of doing business.32

A clear, well-articulated mission and supporting goals can help facilitate 

CCOs’ decision making about partnering. For example, the Presidio 

Trust’s efforts to clearly determine and articulate its mission have helped 

it make partnering decisions. Although the Presidio Trust’s authorizing 

legislation set out two broad goals—one to preserve the park and the 

other to achieve financial self-sufficiency in 15 years—the Presidio Trust 

made a strategic decision that self-sufficiency was to be its primary goal 

since it was a necessary condition for preserving the park’s beauty and 

natural resources. That is, officials reasoned that the Presidio Trust could 

only be preserved if the park was still in existence and well managed. To 

achieve the goal of self-sufficiency, the Presidio Trust worked with real 

estate and construction firms to plan, develop, and manage the 

rehabilitation and rental of structures. These partnering efforts helped the 

Presidio Trust successfully meet its goal of financial self-sufficiency by 

fiscal year 2012, within the mandated deadline, while also making 

significant progress in historical preservation.

Organizations that are unable to articulate a clear and well-defined 

mission and to prioritize multiple goals in support of that mission are not 

well-positioned to make strategic partnering decisions. The Valles 

Caldera Trust was mandated by law to achieve a number of goals, 

including self-sufficiency by the end of 2015.33 We previously found that 

officials set out to achieve an acceptable balance in the pursuit of all six 

goals instead of prioritizing them and had did not have a strategic plan 

laying out those goals nor a performance plan that could measure 

progress in achieving those goals.34

 

32

Based on our analysis and the 

GAO-06-15. 

33 Pub. L. No. 106-248, title I, §§ 108(d), 111, 114 Stat. 598 (Jul. 25, 2000).

34 In October 2009, the Chair of the Board of the Valles Caldera Trust responded to us 

that there was no excuse not to have a strategic plan and subsequently in late 2011 

produced a strategic plan for fiscal years 2012 to 2018.

Principle 1: Make 

Partnering Decisions 

in Line with Mission

Clear, Well-Articulated 

Mission and Goals Facilitate 

Appropriate Partnering 

Decisions 
 

Page 19 GAO-13-549 Congressionally Chartered Organizations

principles we compiled, we believe that because the Valles Caldera Trust 

lacked these plans, it would have also found it difficult to make partnering 

decisions.35

Complementary goals and missions are important to a successful 

partnership. Officials at both the Smithsonian Institution and Holocaust 

Memorial Museum described processes they have in place to make such 

determinations. For example, officials at Smithsonian Enterprises, the unit 

that oversees the Smithsonian Institution’s revenue generating activities, 

implemented a process to help ensure that business partners and 

projects have missions that are compatible with that of the institution. 

Smithsonian Enterprises has a strategic advisory committee composed of 

15 to 18 staff from across the institution that meets quarterly to discuss 

new activities, updates, and ideas. These quarterly meetings have 

included substantive discussions about whether particular proposed 

business relationships are consistent with the Smithsonian Institution’s 

mission. Outside Smithsonian Enterprises, the Smithsonian Institution 

also carefully assesses whether potential partnering arrangements and 

partners are in line with its mission. For example, when making partnering 

decisions, officials rank potential projects based on the extent to which 

they might help to advance the institution’s mission. Specifically, officials 

assess the extent to which potential partners have complementary 

missions and beliefs. For example, officials noted that the institution has 

declined corporate sponsorship offers from private companies who have 

publicly espoused beliefs that are different from the institution’s core 

beliefs and principles, especially key scientific theories, such as evolution, 

that are important to its mission.

Similarly, Holocaust Memorial Museum officials said they carefully assess 

partner organizations’ goals to help ensure that they align with the 

museum’s strategic vision and that potential partners’ causes do not 

conflict with or overshadow the museum’s own mission. To do so, officials 

consider how partners could further the Holocaust Memorial Museum’s 

mission. For example, the museum has partnered with the company 

Ancestry.com to develop software that could be used to index and access 

information on victims of the Holocaust. In this instance, according to 

museum officials, the partners have leveraged their complementary 

 

35 See GAO-06-98 and GAO-10-84. 

Consider Whether Potential 

Partners and Partnering 

Arrangements Are in Line 

with Mission and Goals
 

Page 20 GAO-13-549 Congressionally Chartered Organizations

missions—to track individual and family heritage information—to provide 

this resource to more than 1 million people each year.

• Are the CCO’s mission and goals well-defined and clearly articulated?

• Are the partner’s goals clearly articulated and well aligned with the 

CCO’s mission and goals?

• Will partners understand how key activities, core processes, and 

resources link to shared mission and goals?

• How will the partner contribute to the CCO’s mission to deliver 

programs and services?

Top leadership support for partnering arrangements is critical to 

successfully pursuing and engaging partners. The tone at the top—

management’s philosophy and operating style—sets the stage for how 

the organization will make management decisions, including decisions 

related to partnering with the nonfederal sector. As a champion for these 

types of arrangements, leaders can encourage their staff and 

stakeholders to see the value in creatively building on the assets and 

resources of partner organizations. This is consistent with our past work 

noting that top-level commitment and continuity in leadership is a key 

issue when organizations work to collaborate with each other.36

Officials from all four CCOs we studied told us their top leaders have 

encouraged their organization to leverage external resources. To that 

end, they have cultivated an environment that has facilitated staffs’ ability 

to form, pursue, and engage with partners. Specifically, a Smithsonian 

Institution official told us that partnerships at the institution have benefited 

from extensive top leadership support, and that the Secretary has greatly 

increased the emphasis on partnerships and collaborations in general. 

For example, leaders at the Smithsonian Institution have championed the 

Grand Challenges Consortia Program, which offers competitive funding 

for interdisciplinary projects through internal grants to researchers that 

work with interdisciplinary partners to conduct research that aligns with 

the institution’s strategic goals. Leadership support of this program has 

sent a clear message about the importance of partnering across 

interdisciplinary boundaries, and officials noted such partnering has 

increased since the Consortia was established. In another example, 

Presidio Trust officials said their top leaders’ efforts to encourage the

 

36 GAO-12-1022. 

Key Questions to Consider

Principle 2: Ensure Top 

Leadership Support for 

Partnering Arrangements

Tone at the Top Matters
 

Page 21 GAO-13-549 Congressionally Chartered Organizations

leveraging of nonfederal resources have resulted in $4 of private 

investment for every federal dollar received.

In contrast, the lack of consistent top leadership can hinder CCOs’ 

partnering efforts. We previously found that leadership turnover at the 

Valles Caldera Trust caused management challenges. Specifically, the 

first executive director served for only 18 months. The position remained 

vacant for about 7 months and the next executive director resigned after 

10 months. Other key positions became vacant in 2004 and 2005, 

including the controller, business manager, programs director, chief 

administrative officer, communications manager, and cultural program 

coordinator. In our past work, we found that the lack of consistent 

leadership and progress in organizational and program development 

contributed greatly to staff turnover.37

CCOs institutionalize leadership support for partnering through their 

strategies and guiding principles and the actions of their top leaders. One 

way to institutionalize this support is to clearly document how partnering 

arrangements can be used to achieve organizational missions and goals. 

For example, the Smithsonian Institution’s strategic plan identifies the use 

of federal and nonfederal partners as a strategy to pursue the institution’s 

key goals. The plan also identifies steps to achieve this goal. Specifically, 

the plan states that the institution will enhance its research capacity by 

leveraging resources from a range of partners including federal agencies 

such as the National Aeronautics and Space Administration, universities, 

nongovernmental organizations, industry, and other domestic and 

international agencies.

This frequent turnover led both to 

delays in partnering decisions about partnerships and false starts to 

programs. When we followed up on our prior work in February 2013, we 

learned that, just in the past year, the Valles Caldera Trust had appointed 

as its new executive director an employee who served in various roles at 

the preserve for over 10 years. This official’s long tenure and hands-on 

experience at the Valles Caldera can, among other things, help the Valles 

Caldera Trust engage partners in a way that could leverage nonfederal 

resources.

 

37 GAO-06-98. 

Institutionalize Top Leadership 

Support
 

Page 22 GAO-13-549 Congressionally Chartered Organizations

• Are top leaders and managers committed to a common vision of 

success in partnering arrangements?

• Are specific responsibilities and accountability for the partnering 

arrangement clearly defined and established?

• Do open and candid communications with all stakeholders occur to 

minimize potential resistance to establishing the partnering 

arrangement?

• How will partners operate across different organizational cultures to 

accomplish respective partner missions and goals?

Partnering decisions should reflect both the likely risk and the 

organization’s tolerance for risk in partnering. Incorporating risk 

assessment and risk management practices into partnering decisions can 

help ensure that the organization recognizes and is prepared to manage 

explicit risks (e.g., financial and physical) and implicit risks (e.g., 

reputational).38 The specific risk mitigation and management methodology 

used will likely vary by organization because of differences in missions 

and varying tolerance for risk. This is consistent with our prior work noting 

that risk management helps organizations assess risk, strategically 

allocate finite resources, and take actions under conditions of 

uncertainty.39

The Smithsonian Institution developed a formalized partner selection 

process to assess risks associated with its Affiliations Program, which 

shares institution resources, including artifacts, with museums 

nationwide. As part of the application process, the Smithsonian Institution 

implemented a process to verify the applicant’s nonprofit status, mission 

statement, and organization chart. Additionally, applicants are required to 

be in good standing under state laws and adhere to certain industry 

standards for managing and storing collections. Through this risk 

 

38 We have previously defined explicit risk as financial exposures including liabilities, 

contingencies, and financial commitments. In this report, we also use explicit risk to mean 

damage, destruction, loss, or theft of CCOs’ physical assets. We have also previously 

defined implicit risk as exposures that stem not from a legal obligation of the federal 

government but rather from implied commitments embedded in the government’s current 

policies or in the public’s expectations about the role of government. See GAO, Fiscal 

Exposures: Improving the Budgetary Focus on Long-Term Costs and Uncertainties, 

GAO-03-213 (Washington, D.C.: Jan. 24, 2003).

39 GAO, Risk Management: Strengthening the Use of Risk Management Principles in 

Homeland Security, GAO-08-904T (Washington, D.C.: June 25, 2008).

Key Questions to Consider

Principle 3: Assess and 

Manage Risks

Incorporate Risk Assessment 

by Formalizing Partner 

Selection 
 

Page 23 GAO-13-549 Congressionally Chartered Organizations

assessment process, the Smithsonian Institution evaluates the 

management abilities of potential partners and determines whether those 

partner institutions will be appropriate stewards of the loaned artifacts and 

resources.

Similarly, the National Gallery of Art has assessed partnering risks 

through a formalized process to identify partners for its privately-funded 

Art Around the Corner program. This program brings District of Columbia 

public school classes to the museum to experience art through 

discussion, role-playing, sketching, art making, and creative writing. To 

select classes for the program, program staff first communicated with 

school principals and then invited teachers and their students to visit the 

museum as a class. During these visits, National Gallery of Art staff 

observed teacher and student interactions, the teacher’s enthusiasm for 

the program, and general class dynamics. Further, Art Around the Corner 

officials make themselves available to provide more information about the 

program as needed so that teachers understand their role in the program 

and the expected outcome for their students. During this observation 

process, National Gallery of Art program staff and teachers can mutually 

assess the program’s benefits and consider whether or not to be involved.

Risks—both explicit and implicit—should be assessed and managed 

when partnering. For example, the way that the Smithsonian Institution 

funds projects as part of its Grand Challenges Consortia program takes 

explicit risks into account by minimizing the institution’s financial 

exposure. Specifically, the Consortia program staff review grant proposals 

and provide seed funding of $20,000 and then later up to $100,000 after a 

project has demonstrated increased capacity. This approach allowed the 

Smithsonian Institution to take calculated risks on new projects in a 

manner that mitigates extensive financial losses. Similarly, the Holocaust 

Memorial Museum has also assessed and managed explicit risks in its 

traveling exhibitions program by establishing requirements based on 

industry best practices regarding potential partners’ physical space. 

Specifically, partners that would like to borrow the museum’s artifacts are 

required to meet certain facility, security, and preservation requirements 

to reduce the risk that artifacts are damaged or lost.

It is also important to manage implicit risks, such as the likelihood that 

partners could potentially damage a CCO’s reputation. For example, the 

Smithsonian Institution allows the use of its space in connection with 

Manage Partnering Risks 
 

Page 24 GAO-13-549 Congressionally Chartered Organizations

substantial donations under the condition that the use is consistent with 

certain policies to help ensure the institution can retain appropriate control 

over its facilities.40

Another type of implicit risk which can affect a CCO’s reputation is 

community and stakeholder opinion. Presidio Trust officials received a 

high degree of neighborhood opposition to a plan to build a contemporary 

art museum on its grounds. Preservationists and others fiercely opposed 

the scale of the museum as being inconsistent with the overall historical 

character of the park and criticized the Presidio Trust for failing to 

consider and plan for traffic impacts on local streets. Faced with adamant 

resistance from these outside groups, a decision was made not to pursue 

plans for the museum.

These policies include, for example, a prohibition on 

the use of facilities for such events as weddings or birthdays; partisan, 

political, or religious gatherings; fundraising; and marketing activities.

• Have explicit and implicit risks—both between and among all partners 

and internally between staff offices—been identified, analyzed, and 

allocated?

• Have the likelihood and significance of risks as well as strategies to 

manage those risks been identified?

Selecting appropriate partners and projects is central to a successful 

partnering arrangement. Partners should bring complementary resources, 

skills, and financial capacities to the relationship. Further, a systematic 

approach helps to identify projects that are well-suited for partnering 

opportunities and helps to achieve an organization’s mission. This is 

consistent with our past work noting the importance of ensuring that 

relevant participants have been included in the collaborative effort. 

Further, we have found that it is helpful when the participants have full 

knowledge of their resources; the ability to commit these resources and 

make decisions; the ability to regularly attend all activities of the 

collaborative mechanism; and the knowledge, skills, and abilities to 

contribute to the outcomes of the collaborative effort.41

 

40 Officials noted that while the Smithsonian Institution provides the venue, the private 

entities pay other expenses related to food, drink, and entertainment.

41 GAO-12-1022. 

Key Questions to Consider

Principle 4: Select 

Complementary Partners 

and Appropriate Projects
 

Page 25 GAO-13-549 Congressionally Chartered Organizations

Partners have broadened CCOs’ audiences. The CCOs we met with have 

used partners to expand their audiences locally and throughout the world. 

For example, the National Gallery of Art has expanded its audience 

through its Art Around the Corner program which partners with District of 

Columbia public schools to bring fourth and fifth grade students to the 

museum who were otherwise unlikely to visit. As part of this program, 

students visit the museum up to 14 times over two school years to view, 

discuss, and create art. According to Art Around the Corner officials, the 

program also has provided an opportunity for the museum to engage with 

students’ families, some of whom have never visited the museum.

Some CCOs reached a broader global audience through international 

partners. For example, the Holocaust Memorial Museum and the 

Mémorial de la Shoah in Paris convened an international symposium in 

2010 to assess governments’ capacities to effectively respond to 

genocide and mass atrocities. The symposium—which was attended by 

leading genocide prevention and human rights officials and experts 

worldwide—highlighted and examined core issues in genocide prevention 

to governments all over the globe. Further, strategies were recommended 

to enhance international cooperation on this issue. Similarly, the National 

Gallery of Art has collaborated with foreign museums to broaden its 

international audience. For example, the museum organized an exhibition

on Victorian art and design with the Tate Britain museum in London,

England.42

Partners have provided technical support. The CCOs we studied worked 

with partners who have provided technical support in various areas of 

business expertise. For example, the Smithsonian Institution and George 

Mason University leveraged their respective expertise and resources to 

develop the Smithsonian-Mason School of Conservation. This school 

offers a semester-long residential academic program for undergraduate 

students in conservation biology located at the Smithsonian Conservation 

Biology Institute in Fort Royal, Virginia. A program official explained that 

George Mason University had previously offered conservation studies at 

the graduate level only and that this new program provides 

undergraduates access to prominent scientists and educators earlier in 

The exhibition is also scheduled to travel to the State Pushkin 

Museum of Fine Arts in Moscow, Russia.

 

42 The Tate Britain holds the national collection of British art from 1500 to the present day 

in addition to international modern and contemporary art. 

Select Partners with the Right 

Resources and Expertise
 

Page 26 GAO-13-549 Congressionally Chartered Organizations

their academic careers. George Mason University provided academic and 

business expertise to help manage the program and conducted a market 

analysis to demonstrate the program’s economic sustainability. The 

Smithsonian Institution contributed scientific resources, such as 

experienced scientists, laboratories, and connections with other 

programs. The institution also made property available to house new 

dormitories and dining facilities. A program official noted that leveraging 

the university’s complementary areas of expertise was critical to the 

school’s success and economic self-sufficiency. 

The Smithsonian Institution has also contracted with companies to 

provide specialized services in connection with certain business 

opportunities, including managing food and beverage services, 

distributing Smithsonian books, and creating Smithsonian-branded 

products. Specifically, the Smithsonian Enterprises unit works with private 

sector partners to provide various business services, and the resulting 

revenues are used to fund programs throughout the institution. For 

example, the home shopping television channel, QVC, which has a large 

viewership and marketing expertise, helped the Smithsonian Institution 

sell jewelry with designs based on the institution’s gem collection. In 

another instance, Smithsonian Enterprises leveraged Mattel’s product 

development expertise to design, produce, and sell a paleontologist

Barbie doll. In both arrangements, the Smithsonian Institution received a 

portion of the revenue.

Partners have provided operational support. Volunteers and organizations 

have provided critical operational support to the CCOs we studied. For 

example, the Smithsonian Institution’s 6,500 volunteers outnumber its 

paid employees. Volunteers have led tours, conducted field work, 

assisted with research, provided administrative support, and staffed 

information desks, among other wide-ranging services. Volunteers have 

also provided specific technical services to the four CCOs we studied. For 

example, the Holocaust Memorial Museum worked with a law firm whose 

lawyers conducted legal research on genocide issues free of charge.

Operational support may also come in the form of what is more 

traditionally viewed as a public-private partnership. For example, prior to 

the establishment of the Presidio Trust in September 1995, the National 

Park Service entered into a 55-year ground lease with Thoreau Center 

Partners, a for-profit California real estate company, to rehabilitate part of
 

Page 27 GAO-13-549 Congressionally Chartered Organizations

an old hospital.

43 Thoreau Center Partners leased, developed, and 

operated some of these buildings, now known as the Thoreau Center for 

Sustainability, and then subleased the improved office space to a variety 

of subtenant organizations. Since the Presidio’s transfer from the National 

Park Service in 1998, the Presidio Trust has overseen this public-private 

partnership. When we followed up with Presidio Trust officials about this 

project in May 2013, they noted that this lease resulted in a good 

outcome for the National Park Service by providing for the rehabilitation of 

the building with outside funds.44

According to Presidio Trust officials, the Presidio Trust continues to 

pursue a development strategy that includes rehabilitating and leasing 

buildings by executing long-term building and ground leases with tenants 

who independently fund building improvements. Officials noted that this 

approach provides a mix of revenue sources that balances low-risk, longterm, and market-driven rents which provide greater certainty of revenues 

during economic downturns. Further, officials said it allows tenants to 

make significant investments toward operational and rehabilitation costs.

For example, the Presidio Trust replaced the previously vacant Letterman 

Army Medical Center with a new 850,000 square foot campus by 

partnering with filmmaker George Lucas whose company invested $300 

million to rehabilitate the complex. This project—known as the Letterman 

Digital Arts Center—is home to Lucasfilm, Ltd and a number of its 

subsidiary companies including Industrial Light and Magic, LucasArts, 

and the George Lucas Educational Foundation. The Presidio Trust earns 

an revenue of approximately $6 million from the ground lease each 

year.

However, the official said that rental 

rates had not kept pace with market changes. 

45

 

43 A ground lease is a lease for the use and occupancy of land only, usually for a long 

period of time. It is also called a land lease.

Other examples of projects that relied on nonfederal partners to 

rehabilitate and lease Presidio Trust buildings include the Walt Disney 

Family Museum and the Presidio Landmark residential apartments. 

Between 2005 to 2011, the Presidio Trust executed 226 ground leases for 

44 For more information on the Thoreau Center Project at the Presidio, see GAO, PublicPrivate Partnerships: Key Elements of Federal Building and Facility Partnerships, 

GAO/GGD-99-23 (Washington, D.C.: Feb. 3, 1999).

45 The Letterman Digital Arts Center’s ground lease is a 60-year term with a 30-year 

option to extend.
 

Page 28 GAO-13-549 Congressionally Chartered Organizations

nearly 1 million square feet that have provided rental revenues valued at 

$240 million over the duration of these leases. 

Partners have provided financial support. Nonfederal financial support is 

critical to CCOs’ ability to further their missions. Nonfederal partners have 

provided millions of dollars of support to each of the CCOs we studied. 

These funds allowed CCOs to purchase art and artifacts, construct new 

buildings, develop exhibitions, enhance program offerings, conduct 

research, and otherwise further the CCO’s mission. CCOs have worked 

with donor or member groups to solicit funds from individuals and 

corporations. For example, the Presidio Trust partnered with the Golden 

Gate National Parks Conservancy to raise private philanthropic funds.

Projects are proposed internally and externally and some CCOs have 

developed internal processes to help ensure they select appropriate 

projects for partnering opportunities. Specifically, some CCOs have used 

committees to evaluate proposals against set criteria, including the extent 

to which the proposal would be consistent with the CCO’s mission and 

goals. For example, the Smithsonian Grand Challenges Consortia 

program assembles a review committee that rates potential projects 

based on a set of criteria that includes scholarly merit, ability to meet 

Consortia goals, ability to build coalitions, social impact, team member 

qualifications, ability to finish the project on time with the provided 

resources, and potential to garner additional funds.

• What resources will each partner contribute and how will the CCO 

leverage those resources?

• To what extent does the CCO have the key skills needed to create, 

manage, and monitor partners and projects?

• How will the potential partners and projects be selected and 

evaluated?

Create a Process to 

Systematically Propose, 

Evaluate, and Select Projects 

Consistent with Mission

Key Questions to Consider
 

Page 29 GAO-13-549 Congressionally Chartered Organizations

Partnering arrangements are relationships between or among different 

parties that should be managed actively. Technology can enable 

information sharing between partners to facilitate the leveraging of 

resources. Formalizing collaborations between the partners, including 

documenting dispute resolution processes, can enable productive partner 

interactions. Further, it is important to have the staff with the right skills 

and experience to manage these opportunities.

CCOs have created online tools that help partners share resources. For 

example, the Holocaust Memorial Museum leveraged the time and skills 

of individuals through the power of crowdsourcing on the Internet as part 

of the World Memory Project. Thousands of volunteers have helped to 

transcribe more than 2 million records of Holocaust-related historical 

documents into an online database hosted by the company 

Ancestry.com.46

In another example, the National Gallery of Art developed online 

educational resources to help it connect with students and teachers, who 

can help achieve the museum’s mission of fostering an understanding of 

works of art.

The software developed by Ancestry.com allowed 

volunteers across the globe to easily access information and perform 

tasks that helped achieve the Holocaust Memorial Museum’s mission.

47 These free resources include teaching packets and online 

interactive lessons. Specifically, the website includes lesson plans, 

worksheets, and other educational materials on topics such as selfportraits, 19th century American art, and art and ecology. The National 

Gallery of Art also has a website with activities and games to engage 

children in art.48

To facilitate collaboration, it is important that partners agree on roles and 

responsibilities and that there is a process in place to resolve disputes. 

One subject matter specialist noted that processes to mediate and 

resolve disputes and conflicts can help CCOs avoid confusion about 

partner expectations and may contribute to partners’ willingness to invest 

resources in the project. This is consistent with our recent work on 

collaborative mechanisms, in which we found that articulating these 

 

46 See http://www.worldmemoryproject.org/. 

47 See http://www.nga.gov/content/ngaweb/education.html. 

48 See http://www.nga.gov/content/ngaweb/education/kids.html. 

Principle 5: Manage 

Partnering Arrangements

Use Technology to Leverage 

Partner Resources 

Use Written Documentation to 

Foster Partner Collaboration 
 

Page 30 GAO-13-549 Congressionally Chartered Organizations

agreements in formal documents can strengthen organizations’ 

commitment to working collaboratively, and that it is important to address 

diverse organizational cultures to enable a cohesive working relationship 

and to create the mutual trust required to enhance and sustain the 

collaborative effort.49

The Smithsonian-Mason School of Conservation used written 

documentation to foster partner collaboration. Specifically, the 

Smithsonian Institution and George Mason University signed a 

memorandum of understanding outlining roles and responsibilities, 

describing the financial commitments expected of each party, allocating 

financial risk between the partners, and setting terms for renewing the 

agreement. The document also established a dispute resolution process 

for discussing and negotiating conflicts. Specifically, the memorandum 

dictated when one partner has the final authority and, in other cases, 

when and how a consensus will be reached. Smithsonian Institution 

officials credited the memorandum of understanding with their ability to 

manage the whole academic, residence, and dining complex as one 

unified program, which has facilitated problem solving and deemphasized the distinction among staff from both institutions.

Another subject matter specialist made the related 

point that it is also important to think ahead about whether other suitable 

partners exist if an arrangement fails. 

In another example, the National Gallery of Art has used written contracts 

outlining the teachers’ roles and responsibilities to encourage teacher 

engagement for its Art Around the Corner program. The National Gallery 

of Art provides extensive materials to teachers and students, including 

curricula, workbooks, sketchbooks, art reproductions, art materials, and 

children’s books. According to officials, integrating program-developed 

activities into the classroom has helped reinforce students’ critical thinking 

skills and therefore it has been important for teachers to follow through in 

carrying out the curriculum in their classrooms. To help ensure that 

teachers adhere to their contractual responsibilities, the teachers are paid 

an annual stipend only after their classes successfully completed the 

program.

In addition to written agreements, establishing mutual expectations 

facilitated successful partnering arrangements. As noted by one subject 

 

49 GAO-12-1022. 
 

Page 31 GAO-13-549 Congressionally Chartered Organizations

matter specialist, developing such an understanding takes time and is 

predicated on coordinating, communicating, and learning how partners 

operate. Smithsonian Institution officials discussed the importance of 

setting expectations about how much time is needed for the partnering 

arrangement. Specifically, the institution has worked to set realistic 

expectations internally and externally about the time frames needed for its 

business enterprises. To assist with this process internally, Smithsonian 

Enterprises maintains a flow chart of the key dates for review. Externally, 

officials have managed private partners’ expectations by explaining that 

the development of licenses takes longer than in the private sector.

Each of the four CCOs we studied has made use of their previously 

described legal authorities and exemptions to attract and retain 

appropriate staff to facilitate partnering. CCOs have used these 

authorities for staff in areas such as business development, philanthropy, 

and key management positions that require skills to facilitate and manage 

partnering arrangements. Further, one CCO used this exemption to be 

nimble and responsive when its partnering needs changed. Specifically, 

when working with private contractors, the Presidio Trust was able to 

downsize construction staff when the 2008 decline in real estate values 

resulted in less demand for housing in the San Francisco area.

CCOs also have had a strong focus on recruiting and retaining staff 

skilled at facilitating partnering arrangements. This is consistent with our 

prior work, in which we found that strategic human capital management 

allows agencies to perform their missions economically, efficiently, and 

effectively and facilitates agencies’ ability to deploy the right skills, in the 

right places, at the right time.50

• How will roles and responsibilities surrounding the partnering 

arrangement be delineated, agreed upon, and documented?

For example, the Presidio Trust has 

offered a rent credit program for selected employees who live on the park. 

It has also conducted an employee survey to assess personal work 

experience; recruitment, development, and retention strategies; job 

satisfaction; and feedback on the performance culture and leadership. 

These practices have helped the Presidio Trust retain staff with, among 

other skills, expertise in partnering.

 

50 See for example, GAO, Human Capital: Key Principles for Effective Strategic Workforce 

Planning, GAO-04-39 (Washington, D.C.: Dec. 11, 2003).

Attract and Retain Staff with 

the Right Skills for Partnering

Key Questions to Consider
 

Page 32 GAO-13-549 Congressionally Chartered Organizations

• Are there clear lines of authority to coordinate and elevate decision 

making discussions?

• How will programmatic decisions be made and disputes be resolved?

• How will the CCO ensure or promote effective and open 

communications between partners and what tools, if any, would 

facilitate this communication?

• What key knowledge, skills, and abilities are needed to manage the 

partnering arrangement?

• If the organization does not have staff on board with the necessary

skills to manage partnering arrangements, how will it attract and retain 

that talent?

Information about how well existing partnering arrangements leverage 

nonfederal resources is important to inform decisions about continuing 

arrangements or entering into new ones. Gathering this information also 

presents an opportunity to evaluate progress toward a project’s intended 

goals.

It is important to evaluate the role of partners at an organizational level to 

help ensure nonfederal resources are effectively leveraged. To better 

understand the role of partners at the Smithsonian Institution and to 

promote internal and external collaborations, officials have completed

various reports over time that identify the strengths, weaknesses, 

opportunities, and threats to partnering. These reports also focused on 

how the Smithsonian Institution can better develop a collaborative culture. 

In a February 2012 report, officials compiled an inventory of active 

collaborations with external partners. A separate April 2009 report 

recommended steps the Smithsonian Institution could take to facilitate 

collaboration. In addition, a 2008 Smithsonian Institution task force report 

evaluated the management of revenue-generating activities and 

recommended restructuring Smithsonian Enterprises to improve capacity, 

cost, and focus.

Evaluating the effectiveness of specific partnering efforts can serve an 

important role in improving partnering arrangements. In past work, we 

found that agencies that create a means to monitor, evaluate, and report 

the results of collaborative efforts can better identify areas for 

improvement.51

 

51

Evaluations can also serve as a means to provide 

GAO-12-1022. 

Principle 6: Evaluate 

Partnering Arrangements

Evaluate How Partners 

Leverage Nonfederal Resources

Evaluate Specific Partnering 

Arrangements 
 

Page 33 GAO-13-549 Congressionally Chartered Organizations

feedback to private donors that funded a program. For example, the 

National Gallery of Art conducted an external evaluation of its Art Around 

the Corner program’s outcome and participant impact. The December 

2012 evaluation assessed the program’s mission and participant impact 

through interviews, and identified potential program improvements. 

National Gallery of Art officials have begun discussions about how to 

address the recommendations identified in the evaluation and also plan to 

use this as a means to report back to the private donors that funded the 

program. 

CCOs have also evaluated the success of potential programs by 

conducting pilot programs. For example, the Smithsonian-Mason School 

of Conservation used a pilot to determine the effectiveness of its business 

model and academic curriculum before fully implementing the program. 

Five pilot programs were conducted between 2008 and 2011 to evaluate 

the school’s curriculum and determine whether the program could 

become financially self-sustaining. These pilots allowed officials to 

evaluate the program’s financial and operational feasibility before fully 

committing resources. Upon the successful completion of these pilots, the 

school has been fully operational and has significantly increased the size 

of its program.

• To what extent are partnering arrangements used to better leverage 

nonfederal resources?

• How are partners and their performance evaluated?

• What data-based tools are available to determine whether a 

partnering arrangement is leveraging nonfederal resources 

effectively?

• What lessons learned from other partnering arrangements are used to 

inform new partnering decisions?

Increasingly, the federal government relies on networks of partners to 

achieve critical results, often including multiple federal agencies, sectors, 

and levels of government. CCOs are in a unique position to leverage 

nonfederal resources by working with partners to produce greater public 

value than they can achieve alone, especially given the special 

managerial flexibilities and legal authorities they enjoy. Chief among 

these flexibilities is the ability to solicit private funds and accept gifts. 

These nonfederal resources are particularly valuable in light of today’s 

constrained budget environment, in which agencies may no longer expect 

regular increases in their budgets.

Key Questions to Consider

Conclusions 
 

Page 34 GAO-13-549 Congressionally Chartered Organizations

While the four CCOs we studied—the Holocaust Memorial Museum, the 

National Gallery of Art, the Presidio Trust, and the Smithsonian 

Institution—benefit from millions of nonfederal, nonappropriated dollars 

that provide programmatic, research, and operational support, information 

about how these CCOs leveraged nonfederal funds are not reported in a 

timely, consistent manner. Congress does not direct the CCOs’ use of 

nonfederal funds. However, because the federal budget process is the 

primary means by which Congress evaluates competing demands for 

federal funds, it is essential that Congress has timely, sufficient 

information about the nature and scope of all resources—federal and 

nonfederal—being used to serve a public purpose. Absent a requirement 

to present this information in a timely, transparent fashion and make it 

available for use in congressional budget deliberations, Congress will lack 

complete information about CCOs’ federal and nonfederal financial 

resources. Further, CCOs may be missing an opportunity to share good 

practices and strategies for leveraging resources and strengthening 

relationships with private and nonprofit partners in new, more costeffective ways.

To provide more timely, complete information about CCOs’ fiscal health, 

and increase awareness about good practices and strategies for 

leveraging resources from nonfederal partners, congressional committees 

should consider requiring CCOs under their jurisdiction to report on their 

total nonfederal funds—including a breakdown of the amounts and uses 

of these funds—in their annual budget requests. In requiring this 

information, Congress should also consider what types of information on 

CCOs’ nonfederal funds would be helpful to them, how that information 

should be reported and at what level of detail, and whether the 

information should be presented consistently across CCOs.

We provided the Executive Director of the Holocaust Memorial Museum, 

the Director of the National Gallery of Art, the Executive Director of the

Presidio Trust, and the Secretary of the Smithsonian Institution with a 

draft of this report for review and comment. All of the CCOs generally 

agreed with the findings and conclusions in this report. They also 

provided technical comments, which we have incorporated, as 

appropriate. 

The Director of the National Gallery of Art provided written comments that 

we have reprinted in appendix II. In written comments, the Director of the 

National Gallery of Art agreed that Congress should have timely 

Matter for 

Congressional 

Consideration 

Agency Comments 

and Our Evaluation
 

Page 35 GAO-13-549 Congressionally Chartered Organizations

information about the nature and scope of nonfederal resources. 

However, he noted that Congress should not direct or restrict the use of 

private funding. Instead, the Board of Trustees has full fiduciary 

responsibility over nonfederal funds. We agree that Congress does not 

direct CCOs’ use of nonfederal funds. We have clarified this point in the 

report, as appropriate. 

We are sending copies of this report to the Holocaust Memorial Museum, 

the National Gallery of Art, the Presidio Trust, the Smithsonian Institution, 

and other interested parties. In addition, the report will 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 irvings@gao.gov. Contact points for our Offices 

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

page of this report. GAO staff who made major contributions to this report 

are listed in appendix II.

Susan J. Irving

Director for Federal Budget Analysis

Strategic Issues
Appendix I: Selected Examples of How 

Congressionally Chartered Organizations 

Leveraged Nonfederal Resources

Page 36 GAO-13-549 Congressionally Chartered Organizations

Smithsonian Institution

Business activities Smithsonian Enterprises, the institution’s revenue-producing organization, works with 

nonfederal partners in its three major business divisions: (1) The media division manages the 

institution’s magazines, books, and the Smithsonian Channel, (2) the retail operation manages 

the museum and airport stores, three IMAX theaters, and food concessions, and (3) the 

consumer products division manages agreements with more than 75 companies permitting the 

use of the Smithsonian name following collaboration with staff and curators. Smithsonian 

Enterprises works closely with the private sector to provide the services in each of their 

business divisions. 

Research The Smithsonian Grand Challenges Consortia help foster a spirit of interdisciplinary 

collaboration to stimulate intellectual exchange within the institution and beyond. The Consortia 

develop and launch collaborations, research centers, and programs that address the 

Smithsonian Institution’s four Grand Challenges: (1) Unlocking the Mysteries of the Universe, 

(2) Understanding and Sustaining a Biodiverse Planet, (3) Valuing World Cultures, and (4) 

Understanding the American Experience.

Programs • The institution partners with George Mason University to create, manage, and operate the 

Smithsonian-Mason School of Conservation. The program offers residential, hands-on, 

interdisciplinary programs in conservation biology for undergraduate and graduate 

students and professionals at a jointly developed facility in Front Royal, Virginia.

• The Smithsonian Affiliations program shares the institution’s collections, scholarship, and 

exhibitions with Americans in their own communities by collaborating with museums and 

cultural and educational organizations. The program brings the institution’s resources to 

local communities through its 177 affiliates in 41 states, Puerto Rico, and Panama.

• Through the Encyclopedia of Life the Smithsonian Institution partners with other research 

organizations to compile and make available scientific research, data, and information to 

users worldwide. Its goal is to create “a webpage for every species” by bringing together 

trusted information from resources across the world such as museums, learned societies, 

expert scientists, and others into one database and a single, easy-to-use online portal. 

Internal operations Volunteers provide office and event support by offering programmatic and administrative 

services, such as working on special projects, staffing information desks, providing docent 

tours, and caring for animals. 

National Gallery of Art

Research • The National Gallery of Art collaborates with conservation scientists and conservators, 

conservation laboratories, and universities both nationally and internationally on art 

conservation.

• The Center for Advanced Study in the Visual Arts collaborates with historians, critics, art 

theorists, and social science and humanities scholars to study the production, use, and 

cultural meaning of art, artifacts, architecture, urbanism, photography, and film, from 

prehistoric times to the present. 

Programs • Art Around the Corner partners with the District of Columbia Public School System’s 

elementary schools to bring fourth and fifth graders to the National Gallery of Art up to 14 

times over 2 years to experience art through personal and interdisciplinary connections. In 

small groups, students look closely at works of art, engaging in open-ended discussion, 

role-playing, sketching, art making, and creative writing.

• The National Gallery of Art partners with educators to disseminate information and foster 

an understanding and appreciation of art. It provides resources for educators and students 

such as free interactive lesson units online that include lesson plans, worksheets, and 

student activities.

Internal operations Volunteers assist the public by staffing the information desks at the museum as well as 

providing docent tours of the art for the public. 

Appendix I: Selected Examples of How 

Congressionally Chartered Organizations 

Leveraged Nonfederal Resources 
Appendix I: Selected Examples of How 

Congressionally Chartered Organizations 

Leveraged Nonfederal Resources

Page 37 GAO-13-549 Congressionally Chartered Organizations

U.S. Holocaust Memorial Museum

Research • The museum’s Center for Advanced Holocaust Studies worked with international 

academics to support scholarship and publications in the field of Holocaust studies, 

promotes the growth of Holocaust studies at American universities, seeks to foster strong 

relationships between American and international scholars, and initiates programs to 

ensure the ongoing training of future generations of scholars specializing in the Holocaust.

• The Holocaust Memorial Museum’s World Memory Project program leveraged individual 

volunteer’s efforts to identify photographs of thousands of children. Further, the public 

helps to piece together information about the children’s wartime and postwar experiences 

and facilitate renewed connections among these young survivors, their families, and other 

individuals who were involved in their care during and after the war. 

Programs • The Genocide Prevention Task Force was jointly convened by the Holocaust Memorial 

Museum, U.S. Institute of Peace, and the American Academy of Diplomacy and funded 

through private foundations. Its goals included spotlighting genocide prevention as a 

national priority and developing practical policy recommendations to enhance the capacity 

of the U.S. government to respond to emerging threats of genocide and mass atrocities.

• The traveling exhibitions program allows different organizations to borrow exhibitions and 

thereby extend its educational activities to a broader audience. Since 1991, the museum’s 

traveling exhibitions have been to 150 cities in 45 U.S. states, as well as Canada and 

Germany.

Internal operations • Volunteers worked to assist the Holocaust Memorial Museum’s operations such as visitor 

services special projects, clerical work, research, translation, and transcription.

• To augment the work of the museum, the Office of General Counsel said that law firms are 

periodically engaged to provide pro bono and discounted paid legal services, such as 

research on international law, advice on specific aspects of intellectual property law, and 

advice on major mediations. 

Presidio Trust

Business activities • The Presidio Trust employs a firm specializing in residential leasing to manage residential 

homes in 21 neighborhoods, and a nonresidential management firm to manage leases for 

nonresidential building space.

• The Presidio Trust oversaw the rehabilitation of a historic building into the Inn at the 

Presidio and entered into a management service agreement with a hotel management 

company to manage and operate the inn.

• Presidio Trust Special Events issues permits for recreational uses.

• The Presidio Trust hospitality department rents out seven event venues for meetings and 

private events.

Research

and preservation

The Presidio Trust partners with the National Park Service, academics, and researchers on 

archeology, historical preservation, and open space restoration. 

Programs The Presidio Trust partners with the National Park Service, Golden Gate National Parks 

Conservancy, Presidio YMCA, and other organizations to provide cultural, recreational and 

natural resource programming.

Source: GAO summary of documents and interviews with officials from the four congressionally chartered organizations we studied.
Appendix II: Comments from the National 

Gallery of Art

Page 38 GAO-13-549 Congressionally Chartered Organizations

Appendix II: Comments from the National 

Gallery of Art
Appendix II: Comments from the National 

Gallery of Art

Page 39 GAO-13-549 Congressionally Chartered Organizations
Appendix III: GAO Contacts and Staff 

Acknowledgments

Page 40 GAO-13-549 Congressionally Chartered Organizations

Susan J. Irving, (202) 512-6806 or irvings@gao.gov

In addition to the contact named above, Jacqueline M. Nowicki, Acting 

Director, Melissa Emrey-Arras, Shirley S. Hwang, Melissa L. King, and 

Catherine H. Myrick made major contributions to this report. Also 

contributing to this report were Mallory Barg Bulman, Amy R. Bowser, 

Elizabeth Erdmann, Robert L. Gebhart, Mehrzad Nadji, Amy J. Radovich, 

Cynthia M. Saunders, Sabrina C. Streagle, and Sarah Veale.

Appendix III: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts

Staff 

Acknowledgments 

(450980)
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