MILLENNIUM 

CHALLENGE 

CORPORATION

Review of Compact 

Records and 

Information 

Management Program

Report to the Ranking Member, 

Subcommittee on State, Foreign 

Operations, and Related Agencies, 

Committee on Appropriations, U.S. 

Senate

June 2013

GAO-13-615

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-615, a report to the 

Ranking Member, Subcommittee on State, 

Foreign Operations, and Related Agencies, 

U.S. Senate

June 2013

MILLENNIUM CHALLENGE CORPORATION 

Review of Compact Records and Information 

Management Program

Why GAO Did This Study

MCC has approved 26 bilateral 

compact agreements, providing a total 

of about $9.3 billion to help eligible 

developing countries reduce poverty 

and stimulate economic growth. MCC 

is subject to the Federal Records Act, 

which requires that agencies preserve 

all records documenting its functions 

and other important transactions. 

GAO was asked to review MCC’s 

management of records and 

information. This report (1) examines 

MCC’s records and information 

management program and practices 

and (2) assesses partner governments’ 

implementation of MCC’s information

retention guidelines. GAO analyzed 

MCC documents, interviewed MCC 

officials, and tested MCC’s ability to 

retrieve compact-related information 

from five closed compacts. GAO

selected these compacts because they 

closed after May 2011, when MCC’s 

Program Closure Guidelines went into 

effect.

What GAO Recommends

To strengthen MCC’s records and 

information management program, 

MCC’s Chief Executive Officer should 

(1) develop a policy requiring—and 

conduct—periodic reviews of MCC’s 

compact-management records to 

ensure they are complete, (2) revise 

guidelines to include a sample 

document retention schedule 

specifying standard types of compactrelated information compacts should

retain, and (3) review MCC’s policy of 

delegating storage of most compactrelated information to partner 

governments. MCC agreed with all 

three recommendations and stated that 

they have already taken steps to 

implement them.

What GAO Found

In 2006, the Millennium Challenge Corporation (MCC) established a records and 

information management program to maintain and preserve its federal records. 

The program includes policies related to compact management records—a 

subset of MCC’s federal records. These policies also address the handling of 

other compact-related information generated by MCC partner governments’ 

accountable entities, which typically manage compact implementation until the 5-

year compacts close. MCC’s policies require that the entities transfer their 

compact management records to MCC for storage before compact closure. MCC 

also requires that partner governments retain compact-related information not 

classified as records, such as survey data and data quality reviews, for at least 5 

years after their compacts close, to facilitate audits and analysis of MCC 

assistance. However, MCC does not require, and has not conducted, periodic

reviews to determine whether it has received all compact-management records 

from the accountable entities consistent with federal internal control standards. 

As a result, MCC cannot be sure that it is meeting the federal requirement that it 

preserve all records documenting its functions, activities, and other transactions.

In reviews of five closed compacts—Armenia’s, Benin’s, El Salvador’s, Ghana’s, 

and Mali’s—GAO found variation in the accountable entities’ implementation of 

MCC document retention requirements and the partner governments’ ability to 

retrieve requested compact-related information after the compacts closed. As 

required by MCC’s compact closure guidelines, all five program closure plans 

that we reviewed contained some discussion of retaining and storing documents, 

but each accountable entity addressed the guidelines’ requirements differently. 

MCC’s guidelines do not provide a list specifying standard types of compactrelated information that most compacts should retain. Such variation in 

approaches to retaining and storing compact-related information will make it 

more difficult for MCC to verify that standard compact information is retained in 

all partner countries after the compacts close. In addition, in a test of MCC’s 

ability to retrieve documents from the partner governments after compact 

closure, GAO found that four of the five governments provided all or most 

requested documents within 30 days, but Mali’s, which is involved in political 

turmoil, provided no documents (see fig.). Political turmoil in Madagascar, 

another compact-recipient country, has also impeded MCC’s ability to obtain 

compact information that may be needed to conduct future audits, evaluate 

project impact, or inform future compact designs. 

Number of Documents Returned to GAO within 30 Days, by Country

View GAO-13-615. For more information, 

contact David Gootnick at (202) 512-3149 or 

gootnickd@gao.gov.
Page i GAO-13-615 Millennium Challenge Corporation

Letter 1 

Background 3

MCC Has Established a Records and Information Management 

Program but Has Not Reviewed Its Inventory of CompactManagement Records 5

Partner Countries’ Implementation of MCC Document Retention 

Requirements and Their Ability to Provide Requested 

Documents Vary 10

Conclusions 14

Recommendations 15

Agency Comments and Our Evaluation 16

Appendix I Objectives, Scope, and Methodology 18

Appendix II MCC Scores on NARA Self-Assessment Survey, 2009-2012 23

Appendix III Comments from the Millennium Challenge Corporation 25

Appendix IV GAO Contact and Staff Acknowledgments 27

Tables

Table 1: Descriptions of MCC Compact Management Records and 

Other Compact-Related Information 8

Table 2: MCC’s Score on 2012 NARA Survey, by Section 10

Table 3: Selected USAID Office of the Inspector General Audit 

Reports, by Title and Number 20

Table 4: Number of Documents in Random Sample, per MCC 

Compact and Type of Audit 21

Table 5: MCC Scores on NARA Self-Assessment Survey, by Section, 

2009 23

Table 6: MCC Scores on NARA Self-Assessment Survey, by Section, 

2010 23

Table 7: MCC Scores on NARA Self-Assessment Survey, by Section, 

2011 24

Contents 
Page ii GAO-13-615 Millennium Challenge Corporation

Table 8: MCC Scores on NARA Self-Assessment Survey, by Section, 

2012 24

Figure

Figure 1: Number of Requested Documents Returned within 30 

Days, by Country 13

Abbreviations

FOIA Freedom of Information Act

OIG Office of the Inspector General

MCA Millennium Challenge Account

MCC Millennium Challenge Corporation

NARA National Archives and Records Administration

USAID United States Agency for International Development

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Page 1 GAO-13-615 Millennium Challenge Corporation

441 G St. N.W.

Washington, DC 20548

June 20, 2013

The Honorable Lindsey Graham

Ranking Member

Subcommittee on State, Foreign Operations, and Related Agencies

Committee on Appropriations

United States Senate

Dear Senator Graham:

The Millennium Challenge Corporation (MCC), a U.S. government 

corporation, provides aid to developing countries that have demonstrated 

a commitment to ruling justly, encouraging economic freedom, and 

investing in people. MCC provides its assistance to eligible countries 

through 5-year compact agreements with the specific goal of reducing 

poverty by stimulating economic growth. Since its establishment in 2004, 

MCC has signed 26 compacts with the governments of 25 low-income or 

lower-middle-income countries, committing approximately $9.3 billion for 

compact assistance.1 The partner governments vest accountable entities, 

generally referred to as Millennium Challenge Accounts (MCAs), with 

responsibility for implementing the compacts, including managing 

compact records and other information, in accordance with MCC policies 

and guidelines.

The Federal Records Act of 1950, as amended, requires each federal 

agency, including MCC, to make and preserve records that, among other 

things, document the agency’s decisions, procedures, and essential 

transactions.2 Since 2009, the National Archives and Records 

Administration (NARA) has required agencies to complete an annual self-

 

1

MCC commits funding when a compact is signed and obligates funds after the compact 

enters into force. As of May 2013, MCC had signed initial compacts with, in chronological 

order, Madagascar, Honduras, Cape Verde, Nicaragua, Georgia, Benin, Vanuatu, 

Armenia, Ghana, Mali, El Salvador, Mozambique, Lesotho, Morocco, Mongolia, Tanzania, 

Burkina Faso, Namibia, Senegal, Moldova, the Philippines, Jordan, Malawi, Indonesia, 

and Zambia. The compacts with Honduras, Cape Verde, Georgia, Vanuatu, Nicaragua, 

Armenia, Benin, Ghana, and El Salvador have ended. In addition, MCC terminated the 

compacts with Madagascar and Mali because both countries underwent a nondemocratic 

change of government. In February 2012, MCC signed a second compact with Cape 

Verde.

2

Codified at 44 U.S.C., chapters 21, 29, 31, and 33.

 
 

Page 2 GAO-13-615 Millennium Challenge Corporation

assessment of their records management practices, which it uses to rate 

the agencies’ compliance with the Federal Records Act and other laws 

and regulations related to records management. As our previous work 

has shown, agencies with poorly managed records risk increased costs 

when attempting to search their records in response to Freedom of 

Information Act (FOIA) requests or litigation-related discovery actions. 

Without effective management of the documentation of government 

actions, the ability of the people to hold the government accountable is 

jeopardized.3 In addition, effective records management is an important 

tool for efficient government operation; without adequate and readily 

accessible documentation, agencies may not have access to important 

operational information to make decisions and carry out their missions.4

You asked us to review MCC’s approach to records management, 

including its practice of delegating the retention and storage of most 

compact-related information to partner governments. This report (1) 

examines MCC’s records and information management program and 

practices and (2) assesses partner governments’ implementation of MCC 

guidelines for retention and storage of compact-related information.

To describe MCC’s approach to records management, we reviewed 

NARA’s records-management guidance and the self-assessment survey 

that NARA administers to assess agencies’ compliance with federal 

requirements. We also reviewed MCC’s policies and procedures and 

interviewed cognizant officials at MCC and NARA. To assess the extent 

to which MCAs have implemented MCC’s guidelines for information 

retention, we selected five closed MCC compacts—with Armenia, Benin, 

El Salvador, Ghana, and Mali—to use as case studies.5 We reviewed 

certain documentation compiled by each MCA or partner government in 

accordance with MCC’s guidelines6 and conducted a test of MCC’s ability 

 

3

See GAO, Information Management: The Challenges of Managing Electronic Records, 

GAO-10-838T (Washington, D.C.: June 17, 2010).

4

See GAO, Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

5

We chose these countries because they were subject to MCC’s Program Closure 

Guidelines, which were finalized in May 2011.

6

We focused on the following three documents: Records and Information Management 

Policy (June 2011), Policy and Procedures for Compact-Related Federal Recordkeeping 

(September 2012), and Program Closure Guidelines (May 2011).
 

Page 3 GAO-13-615 Millennium Challenge Corporation

to retrieve compact-related information after compact closure. For this 

test, we drew a random sample of MCA documents that had been used 

for audits conducted by the U.S. Agency for International Development’s 

(USAID) Office of the Inspector General in our case-study countries.7 We 

provided MCC with a list of about 20 documents8 for each case-study 

country and asked that the partner governments provide the documents 

to us within a specific timeframe. (See app. I for further details of our 

scope and methodology.)

We conducted this performance audit from September 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.

In accordance with the Federal Records Act and NARA’s implementing 

regulations for records management and retention, MCC is responsible 

for managing the records that it generates. MCC has established policies 

and issued guidance intended to ensure that the records generated by 

the governments receiving compact and threshold assistance are 

properly identified and transferred to MCC for storage and management.9

The Federal Records Act, as amended,10 requires each federal agency to 

make and preserve records that (1) document the organization, functions, 

policies, decisions, procedures, and essential transactions of the agency; 

 

7

USAID’s Office of the Inspector General is also responsible for overseeing MCC 

activities.

8

We requested 20 documents each from Benin, Ghana, and Mali. We requested 18 

documents from El Salvador and 15 documents from Armenia because these were the 

complete sets of appropriate documents from the Inspector General’s audit files.

9

In addition to compact agreements, MCC provides foreign assistance through its 

Threshold Program, which is designed to assist a country in becoming compact eligible by 

supporting target policy and institutional reforms.

10The relevant provisions of the Federal Records Act of 1950 and subsequent records 

management statutes are largely codified in chapters 21, 29, 31, and 33 of Title 44 of the 

U.S. Code. 

Background 

Federal Records Act 

Requirements
 

Page 4 GAO-13-615 Millennium Challenge Corporation

and (2) provide the information necessary to protect the legal and 

financial rights of the government and of persons directly affected by the 

agency’s activities.11 Such records must be managed and preserved in 

accordance with the act’s provisions.

To ensure that they have appropriate systems for managing and 

preserving their records, the act requires agencies to develop records 

management programs.12 These programs are intended, among other 

things, to provide for accurate and complete documentation of the policies 

and transactions of each federal agency, to control the quality and 

quantity of records they produce, and to provide for judicious preservation 

and disposal of federal records. A records management program 

identifies records and sources of records and provides records 

management guidance, including agency-specific recordkeeping 

practices that establish what records need to be created to conduct 

agency business, among other things.

Under the Federal Records Act, NARA has general responsibilities for 

oversight of agencies’ federal records management.13 These 

responsibilities include issuing guidance for records management; 

working with agencies to implement effective controls over the creation, 

maintenance, and use of records in the conduct of agency business; 

providing oversight of agencies’ records management programs; 

approving the disposition (destruction or preservation) of records; and 

providing storage facilities for agency records on a fee-for-service basis.

NARA has issued regulations requiring that records be effectively 

managed throughout their life cycle, including records creation and 

receipt, maintenance and use, and disposition. One key records 

management process is scheduling, the means by which NARA and 

agencies identify federal records and determine timeframes for 

disposition. Creating records schedules involves identifying and 

 

11The definition of a record is given at 44 U.S.C. 3301. 

1244 U.S.C. § 3102. 

13Under the Federal Records Act, NARA shares a number of records management 

responsibilities and authorities with the General Services Administration. In addition, the 

Office of Management and Budget has records management oversight responsibilities 

under the Paperwork Reduction Act and the E-Government Act.

NARA Records 

Management Oversight 

and Requirements
 

Page 5 GAO-13-615 Millennium Challenge Corporation

inventorying records, appraising their value, determining whether they are 

temporary or permanent, and determining how long they should be kept 

before they are destroyed or turned over to NARA for archiving. 

Scheduling records requires agencies to invest time and resources to 

analyze the information that an agency receives, produces, and uses to 

fulfill its mission. Such an analysis allows an agency to set up processes 

and structures to associate records with schedules and other information 

to help it find and use records during their useful lives and dispose of 

those no longer needed. Scheduling involves broad categories of records 

rather than individual documents or file folders.

Since 2009, NARA has required federal agencies to complete an annual 

self-assessment of their records management practices, to determine 

whether the agencies are compliant with statutory and regulatory records 

management requirements. The 2012 self-assessment survey called for 

agencies to evaluate themselves in four areas: (1) records management 

activities, (2) oversight and compliance, (3) records disposition, and (4) 

electronic records. NARA scores the self-assessments, and the 

accompanying agency documentation, and uses the scores to categorize 

each agency as low, moderate, or high risk in terms of compliance with 

federal regulations.

Beginning in 2006, MCC established a records and information 

management program and subsequently established guidelines for 

handling compact management records and other compact-related 

information. However, MCC has not created a policy for—or conducted—

periodic reviews of the extent to which it has received the compact 

management records that it requires MCAs to provide to MCC for 

storage. In 2012, MCC’s score on the NARA survey placed the agency in 

the moderate risk category—an average rating—for compliance with 

federal requirements.

MCC Has Established 

a Records and 

Information 

Management Program 

but Has Not Reviewed 

Its Inventory of 

Compact Management 

Records 
 

Page 6 GAO-13-615 Millennium Challenge Corporation

MCC established its records and information management program in 

2006.14 The program’s stated objectives, according to the 2011 version of 

its Records and Information Management Policy, are to create, maintain, 

and preserve adequate and proper documentation of its policies, 

transactions, and decisions; ensure the security and integrity of MCC’s 

federal records, including the safeguarding of records against 

unauthorized access or disposition; and prevent the removal of records 

and control the removal of other materials from the agency.

MCC’s Records and Information Management Policy defines “federal 

record” consistently with the Federal Records Act’s definition of “record.” 

According to the policy, MCC catalogues its federal records into four 

major series, based on the records’ functions.15

• Administrative: Records commonly found at any federal agency, 

such as accounting and finance files, and budget, personnel, and 

procurement files.

• Governance: Records related to the Millennium Challenge Act of 

2003, authorities, laws, and legislation, such as Board of Directors 

meeting minutes and resolutions, legal opinions, and ethics program 

records.

• Communications: Exchanges with external entities, such as MCC’s 

annual report, congressional notifications, press releases, and official 

speeches, among other things.

• Millennium Challenge Account Assistance: MCC mission 

development, implementation, oversight, results, and closeout 

information pertaining to threshold programs and compacts. This 

category also includes compact management records, which are 

generated at least in part by the MCAs.

 

14MCC hired a records management officer in 2006 to establish the records and 

information management program. 

15A “record series” is the basic unit for organizing and controlling files. It is a group of files 

or documents kept together because they relate to a particular subject or function, result 

from the same activity, document a specific type of transaction, take a particular physical 

form, or have some other relationship arising out of their creation, receipt, maintenance, or 

use.

MCC’s Records and 

Information Management 

Program Includes 

Guidelines Defining 

Records 
 

Page 7 GAO-13-615 Millennium Challenge Corporation

MCC provides guidance regarding the maintenance of compact 

management records and the retention and storage of compact-related 

information. In 2007, MCC issued Policy and Procedures for CompactRelated Federal Recordkeeping,16 which was updated in 2012. The policy 

outlines specific policies and procedures regarding compact management

records—which MCC refers to as a subset of federal records—and other 

compact-related information.17 The policy also includes a list specifying 

the types of documents that MCC classifies as compact management

records. The policy and procedures apply regardless of whether the 

records and other compact-related information are created by MCC staff, 

partner governments, MCA entities, contractors, or other parties.18

• Maintenance of compact management records. According to 

MCC’s Policy and Procedures for Compact-Related Federal 

Recordkeeping, all information defined as a compact management

record must be maintained at MCC headquarters during compact 

development and implementation and after compact closure. For 

example, under the policy, the following monitoring and evaluation 

documents are classified as compact management records, to be 

maintained at headquarters: indicator tracking tables, monitoring and 

evaluation plans and revisions, reviews and final impact evaluations, 

and data quality reviews.

• Retention and storage of compact-related information. MCC’s 

Policy and Procedures for Compact-Related Federal Recordkeeping 

further states that the partner governments must retain, for at least 5 

years after compact closure, types of information that are not defined 

as records but are important to the implementation and closure of 

compacts.19 The policy specifies, as examples of such information, (1) 

 

16The document was originally titled “Recordkeeping Procedures for the Implementation of 

Compacts Policy.” 

17MCC considers other compact-related information to be “non-records.” 

18MCC compact management records fall into 10 categories: (1) compact core document, 

(2) program oversight, (3) MCC decisions and approvals, (4) program procurement, (5) 

monitoring and evaluation, (6) environment and social assessment, (7) infrastructure, (8) 

fiscal accountability, (9) program MCA documents, and (10) compact close and postcompact.

19In addition, the five compacts we reviewed contained a provision that requires the 

partner governments to maintain compact documents for at least 5 years after compact 

closure.

MCC Has Issued Guidance 

for Managing Compact 

Management Records and 

Other Compact-related 

Information 
 

Page 8 GAO-13-615 Millennium Challenge Corporation

documents to support audits by MCC’s Office of the Inspector General 

and GAO and (2) program evaluation documents to support ongoing 

analysis of MCC assistance. In another policy document, Program 

Closure Guidelines, MCC also requires MCAs to provide to MCC 

certain compact-related information for storage at MCC headquarters. 

For example, MCAs are required to provide the following information 

related to compact monitoring and evaluation: all MCC-funded survey 

data sets and supporting materials, such as questionnaires, 

enumerator field guides, data entry manuals, data dictionaries, and 

final reports; other analyses; evaluations; and data quality reviews 

and special studies that were funded through the compact’s 

monitoring and evaluation budget.

Table 1 describes compact management records and other compactrelated information.

Table 1: Descriptions of MCC Compact Management Records and Other CompactRelated Information

Type of information Description

Compact management 

records

A subset of the Millennium Challenge Account 

Assistance series of federal records that must be 

maintained by MCC headquarters during 

implementation and after compact closure.

Compact-related information

• To be retained by partner 

governments for at least 5

years after compact 

closure. 

Documents that may be needed to support future 

audits or analysis of MCC assistance.

• To be provided by MCAs 

for storage by MCC 

headquarters.

Documents or copies of documents that must be 

provided to MCC during implementation or at 

compact closure, such as survey data sets and 

supporting materials.

Source: GAO analysis of guidance from MCC, Policy and Procedures for Compact-Related Federal Recordkeeping (2012) and 

Program Closure Guidelines (2011). 

MCC’s Policy and Procedures for Compact-Related Federal 

Recordkeeping assigns the responsibility for ensuring that the country’s 

compact management records are transmitted and received at MCC 
 

Page 9 GAO-13-615 Millennium Challenge Corporation

headquarters to the MCC Resident Country Director serving in each 

partner country.20 The policy states that MCC has the responsibility to 

ensure that MCAs are taking reasonable steps to meet records 

management requirements. The policy also states that MCC is 

responsible for ensuring that the partners understand (1) what is covered 

by both compact management records and other compact-related 

information and (2) that MCC or a U.S. government audit, legal, or 

oversight entity may need to have access to such information for at least 

5 years after the compact end date.

MCC policy does not call for, and MCC has not performed, reviews of the 

extent to which it has received the compact management records that it 

requires MCAs to provide to MCC for storage. According to Standards for 

Internal Control in the Federal Government,21 a federal agency should 

have in place control activities—that is, policies, procedures, techniques, 

and mechanisms, including reviews of performance—to help ensure that 

management’s directives are carried out. MCC’s Policy and Procedures 

for Compact-Related Federal Recordkeeping assigns to the MCC 

Resident Country Director in each partner country the responsibility for 

ensuring the transmittal and receipt of the country’s compact 

management records at MCC headquarters. However, MCC policy does 

not require periodic reviews of the records received from the MCAs to 

ensure that all required records have been transferred. In addition, MCC’s 

Records Management Officer stated that MCC has not reviewed the 

compact management records it has received, for the following reasons: 

(1) the first compacts ended only recently, and (2) the records 

management program has limited resources. However, of the 11 

compacts that have closed or been terminated, 5 ended in 2011 and 2 

ended in 2010. Without periodically reviewing the compact management

records it receives from the MCAs, MCC cannot be sure that it is meeting 

the Federal Records Act’s requirement that it preserve all records 

documenting its functions, activities, decisions, and other important 

transactions.

 

20Prior to compact signature, MCC’s Country Team Leader is responsible for ensuring that 

the appropriate records are retained.

21GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, DC: November 1999.)

MCC Has Not Reviewed Its 

Compact Management 

Records for Completeness
 

Page 10 GAO-13-615 Millennium Challenge Corporation

In 2012, MCC received a revised score of 77 out of 100 on NARA’s selfassessment survey, which placed MCC in the moderate risk category in 

terms of compliance with federal requirements (see table 2). A NARA 

official characterized this score as an “average rating” for federal 

agencies. In the previous 3 years, MCC received the following scores: 92 

(2009), 83 (2010), and 76 (2011) (see app. II for more information.) 

MCC’s Records Management Officer also stated that meeting NARA 

requirements, especially for electronic records, is difficult for small federal 

agencies with limited resources and that MCC, in conjunction with other 

small agencies, has appealed to NARA for assistance.22

Table 2: MCC’s Score on 2012 NARA Survey, by Section

Survey section

MCC points 

received

Total possible 

points Percentage

Records management activities 21 21 100% 

Oversight/compliance 23 31 74

Records disposition 15 15 100

Electronic records 18 33 55

Total score 77 100 77% 

Source: GAO analysis of MCC results on the NARA survey.

For the five closed compacts that we reviewed—MCC’s compacts with 

Armenia, Benin, El Salvador, Ghana, and Mali—the MCAs provided 

varying levels of detail about their plans for retaining compact-related 

information to address MCC requirements. In addition, the five partner 

governments showed varying capacity to provide the documents that we 

asked MCC to retrieve.

 

22According to NARA, it has not received a specific appeal for assistance from MCC. 

However, NARA noted that smaller agencies that have limited resources, like MCC, and 

experience similar challenges have generally appealed for assistance.

MCC’s Records 

Management Program 

Received an Average 

Rating on NARA Survey in 

2012

Partner Countries’ 

Implementation of 

MCC Document 

Retention 

Requirements and 

Their Ability to 

Provide Requested 

Documents Vary
 

Page 11 GAO-13-615 Millennium Challenge Corporation

For the five compacts that we reviewed, the MCAs provided varying 

levels of detail about their plans for retaining compact-related information. 

MCC’s Program Closure Guidelines instruct accountable entities to 

develop program closure plans describing their strategy for retaining and 

storing compact-related information. The guidelines state that each 

accountable entity should provide the following three items for MCC 

approval prior to the compact end date:

• a list of the types of documents the partner government will retain,

• a document retention schedule, and

• a brief description of the form and manner in which the documents will 

be stored.23

MCC’s compact closure guidelines do not provide a sample document 

retention schedule specifying standard types of compact-related 

information that most compacts would need to retain or provide.

All five program closure plans that we reviewed contained some 

discussion of filing and storing documents, but each MCA addressed the 

guidelines’ three requirements differently. Such variation in approaches to 

scheduling and storing compact documentation will make it more difficult 

for MCC to verify that standard compact information is being retained in 

all partner countries after the compacts have closed.

Types of documents to be retained. The program closure plans for the 

Armenia, Ghana, and Mali compacts specified that the respective partner 

governments would retain all compact-related information. The program 

closure plan for the Benin compact did not list the types of documents 

that the government would retain but stated that the MCA would provide 

further information in the document retention schedule. The program 

closure plan for the El Salvador compact stated that the government, 

through a contractor, would retain original files related to personnel, 

projects, procurement, finance, monitoring and evaluation, and studies.

Document retention schedule. The MCAs’ document retention 

schedules also varied. Armenia and Benin did not provide document 

 

23According to the Program Closure Guidelines, the documents must be maintained at a 

site that is secure, locked, and acclimatized to ensure the documents’ viability and the 

proper treatment of sensitive information.

MCAs Provided Varying 

Levels of Detail about 

Document Retention Plans
 

Page 12 GAO-13-615 Millennium Challenge Corporation

retention schedules.24 El Salvador provided a comprehensive listing, by 

category, of all documents to be retained; however, it provided this list for 

the purposes of our review in April 2013, after the compact end date. 

Ghana’s schedule, submitted after the compact end date but within the 3-

month compact closure period, specified document types to be retained. 

Mali provided an undated printout of its electronic file system. According 

to MCC officials, the disparity among the MCAs’ document retention 

schedules stemmed from insufficiently specific guidance provided by 

MCC.

Form and manner of document storage. The MCAs’ program closure 

plans specified varying forms and manners of storage for compact-related 

information after compact closure. According to the plans:

• Armenia will store the documents at three different government 

agencies: the state archives, the Ministry of Transport and 

Communications, and the Foreign Financing Projects Management 

Center (a foreign donor coordination unit);

• Benin will store the documents at its national archives;

• El Salvador has made a contractor responsible for the safekeeping of 

compact-related files and documents;

• Ghana’s MCA will continue as a foreign donor coordination unit after 

compact closure and will retain all MCC documents; and

• Mali will store compact-related information at the Office of the 

Secretary General of the President (the “Office of the Segal”), which 

was the office of the principal government representative under the 

compact.

Our test of MCC’s ability to retrieve compact-related information from the 

five countries produced varying results that depended on the stability of 

the governments. Four of the governments provided all or most of the 

documents we requested. In contrast, Mali’s government, which is in 

transition, provided none of the requested documents. Figure 1 displays 

the test results.

 

24Armenia provided a draft contract that it would sign to create physical archives. Benin 

provided the protocol that it had signed with the government entity that maintains the 

country’s archives.

Countries’ Ability to 

Provide Specific 

Documents Varied
 

Page 13 GAO-13-615 Millennium Challenge Corporation

Figure 1: Number of Requested Documents Returned within 30 Days, by Country

Note: El Salvador provided two additional documents after the 30-day period.

Owing to its policy of relying on partner governments to retain and store 

compact-related information, MCC lost access to this information for 2 of 

the 11 closed compacts when, because of political turmoil, it terminated 

its compacts with Mali and Madagascar. Mali’s government has been in 

transition since March 2012, when the administration at that time was 

overthrown. According to MCC, the transitional government in Mali will 

establish an office to handle post-compact issues but has not provided a 

point of contact. As a result, MCC officials reported that although they 

believe the information related to the Mali and Madagascar compacts 

exists and has been maintained in an organized fashion, they are 

currently unable to access the requested documents. MCC has previously 

noted that political turmoil in Madagascar, whose government was 

overthrown in 2009, impeded MCC’s ability to access documents.25

MCC officials stated that they considered the response rate to our test to 

be good, particularly since the people retrieving the documents were not 

 

25In June 2009, MCC terminated its compact with Madagascar because of an 

undemocratic transfer of power in March of that year. MCC has stated that it has no 

diplomatic authority to independently engage with the post-coup government in 

Madagascar.
 

Page 14 GAO-13-615 Millennium Challenge Corporation

necessarily the same people who created or stored them. Previously, 

MCC has stated that its ability to retrieve documents from partner 

countries is reliant on its ability to access key individuals.26 MCC officials 

further stated that the difference in document return rates among the four 

countries that provided all or most of the requested documents may have 

been due to our test methodology. According to these officials, some of 

the documents we requested were not “critical path” documents, and our 

descriptions of the documents may not have been specific enough to 

allow the partner countries to identify them. However, all of the 

documents we requested were used in audits by the USAID’s Office of 

the Inspector General. They thus serve as examples of the types of 

documents that might be needed to support future audits—one of the 

purposes for which MCC requires the partner governments to retain 

compact-related information for at least 5 years.

Records and information management is important in all government 

agencies, in part because it helps ensure that the agencies remain 

transparent and accountable to the public and allows for congressional 

and executive branch oversight. MCC established a records management 

program that, according to NARA, is comparable to many others in the 

federal government. Yet, as an international aid agency providing bilateral 

assistance to partner governments, MCC’s situation regarding records 

and information management is atypical: Much of the information related 

to its core business is generated by the partner governments’ 

accountable entities, the MCAs. In accordance with NARA guidelines, 

MCC has established policies and guidelines stipulating that the MCAs 

must provide it with the compact management information it classifies as 

U.S. federal records. However, because its policies do not call for, and it 

does not conduct, systematic reviews of the records it receives, MCC 

cannot be sure that it is meeting the Federal Records Act’s requirement 

that it preserve all records documenting its functions, activities, decisions, 

and other important transactions.

MCC also has established policies that require partner governments to 

retain other compact-related information for at least 5 years after the 

 

26MCC does not require that MCAs designate points of contact for document retention 

issues. However, MCC guidelines do require each MCA to identify designated 

representatives who will serve as the primary points of contact for any monitoring- and 

evaluation-related obligation of the government.

Conclusions 
 

Page 15 GAO-13-615 Millennium Challenge Corporation

compact closes, to support audits and its own program evaluations. 

However, for the five closed compacts that we reviewed, the variations in 

the partner governments’ plans for retaining compact-related information 

could make it difficult for MCC to verify that the appropriate information is 

being retained. While MCC provides the partner governments a list 

specifying what types of documents it classifies as compact management

records needed for storage at MCC headquarters, it does not provide 

such a list for other compact-related information expected to be retained 

in-country by the partner governments. A standardized schedule of 

compact-related information to be retained by each partner government 

would improve MCC’s ability to find and use this information and increase 

MCC’s efficiency in comparing similar information across compacts.

Last, while four of the five partner governments were able to provide the 

information we requested in our test of MCC’s system, the inability of one 

country—Mali, whose government is in transition—to produce any of the 

requested documents calls into question MCC’s policy of relying on 

partner governments to retain and store most compact-related 

information. While the situation in Mali is unusual, the recent political 

turmoil in Madagascar, another former MCC partner, shows that such 

situations are not unique. Given that the countries that MCC targets for 

aid are, by definition, in transition, MCC could benefit from taking 

precautionary steps—such as weighing the costs and benefits of storing 

more compact-related information at MCC headquarters—to protect and 

ensure access to compact-related information.

We recommend that MCC’s Chief Executive Officer take the following 

three actions to strengthen MCC’s records and information management 

program:

1. Develop a policy requiring—and conduct—periodic reviews of each 

set of compact management records that MCC receives from partner 

governments, to ensure that the records are complete.

2. Revise program closure guidelines to include a sample document 

retention schedule, specifying standard types of compact-related 

information that most compacts would need to retain.

3. Review MCC’s policy of delegating the storage of compact-related 

information to partner governments, weighing the costs and benefits 

of storing more of this information at MCC headquarters.

Recommendations 
 

Page 16 GAO-13-615 Millennium Challenge Corporation

In written comments about a draft of this report, MCC stated that it agrees 

with our recommendations and is taking steps to implement them.

• With respect to our first recommendation—to develop a policy 

requiring, and to conduct, periodic reviews of each set of compact 

management records received from partner governments—MCC 

stated that, although it has been conducting selected reviews of 

compliance with compact records management requirements, making 

the practice more systematic would be useful. To that end, its 

Department of Compact Operations will ensure that reviews of MCC 

and MCA compliance with compact management records polices are 

incorporated in both implementation and close-out procedures.

• With respect to our second recommendation—to revise program 

closure guidelines to include a sample document retention schedule—

MCC stated that it will consider how best to structure a standardized 

list of core documents that also preserves a country’s flexibility to 

tailor its document retention schedule in light of local laws and the 

specific types of compact projects.

• With respect to our third recommendation—to weigh the costs and 

benefits of storing more compact-related information at MCC 

headquarters—MCC stated that it will review, and revise as 

necessary, its Policy and Procedures for Compact-Related Federal 

Record Keeping to ensure that it specifies all documents that should 

be defined as federal records.

We have reprinted MCC’s comments in appendix III. We have also 

incorporated technical comments from MCC in our report where 

appropriate.

NARA also provided technical comments on a draft of this report, which 

we have incorporated as appropriate. In addition, NARA stated that 

having reviewed our description of MCC’s classification of federal records 

and “non-records” as they pertain to the MCAs, it will contact MCC to 

ensure that proper classification is occurring.

We are sending copies of this report to interested congressional 

committees and the Millennium Challenge Corporation. In addition, this 

report is available at no charge on the GAO website at 

http://www.gao.gov. 

Agency Comments 

and Our Evaluation
 

Page 17 GAO-13-615 Millennium Challenge Corporation

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

contact David Gootnick at (202) 512-3149 or gootnickd@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 members 

who made major contributions to this report are listed in appendix IV.

Sincerely yours,

David Gootnick

Director

International Affairs and Trade
Appendix I: Objectives, Scope, and 

Methodology

Page 18 GAO-13-615 Millennium Challenge Corporation

Our objectives were to (1) examine the Millennium Challenge 

Corporation’s (MCC) records and information management program and 

practices and (2) assess partner-country governments’ implementation of 

MCC guidelines for retention and storage of compact-related information.

To examine MCC’s records and information management program and 

practices, we reviewed MCC’s policies and guidelines regarding records 

and information management, focusing in particular on three documents: 

Records and Information Management Policy (June 2011), Policy and 

Procedures for Compact-Related Federal Recordkeeping (September 

2012), and Program Closure Guidelines (May 2011). We also reviewed 

the results of MCC’s annual self-assessment surveys from 2009 through 

2012, a tool that the National Archives and Records Administration 

(NARA) developed to assess agencies’ self-compliance with the Federal 

Records Act and other laws and regulations related to records 

management, and we reviewed relevant laws, regulations, and circulars 

produced by the Office of Management and Budget. In addition, we 

interviewed officials at MCC and NARA.

To assess partner governments’ implementation of MCC’s guidelines for 

retention and storage of compact-related information, we selected five 

closed compacts—Armenia’s, Benin’s, El Salvador’s, Ghana’s, and 

Mali’s—to use as case studies. We chose these compacts because they 

closed after May 2011 and therefore were subject to MCC’s Program 

Closure Guidelines, which were finalized that month. We reviewed the 

documentation that the partner governments or their accountable entities 

(usually referred to as Millennium Challenge Accounts, or MCAs) had 

provided to MCC in response to those guidelines. Regarding MCC’s 

requirement that the partner governments make provisions for the form 

and manner of document storage, we reviewed the compacts’ program 

closure plans to ensure that provisions for document storage were 

included, but we did not verify that specific storage requirements—such 

as security and acclimatization—were met.

We also conducted a test of MCC’s ability to retrieve compact-related 

information from partner governments after compact closure. For this test, 

we asked MCC to request that the partner governments for the casestudy compacts provide copies of documents that the U.S. Agency for 

International Development’s (USAID) Office of the Inspector General 

(OIG) had collected during the course of performance and financial audits 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 19 GAO-13-615 Millennium Challenge Corporation

of the five countries. 1 We selected the audits from a list that the OIG 

provided, and we drew from those audits a random sample of documents 

that we requested from the partner governments. We used OIG files 

because it has conducted audits in all 5 countries, whereas GAO has not.

• Selection of performance and financial audits. The OIG provided a 

list of 10 performance and 4 financial audits that it considered relevant 

to our case studies. We removed one performance audit from the list, 

because the OIG had conducted the audit prior to any MCC 

compact’s entry into force and the audit therefore would not yield valid 

documents. We then selected three performance audits and one 

financial audit to review for each of the case-study compacts (except 

Armenia’s, for which the OIG did not conduct a financial audit). 

Several of the performance audits on the OIG’s list covered more than 

one of the case-study compacts. Because Armenia and Benin’s 

compacts were both covered in two performance audits and Mali’s 

compacts was covered by three performance audits, we included all 

of these audits in our sample. Because Ghana’s and El Salvador’s 

compacts were each covered by more than three performance audits, 

we randomly selected among the relevant audits. Because the OIG 

conducted only one financial audit per compact (except Armenia’s), 

we selected all of the listed financial audits. See table 3 for a list of the 

audits that we selected from which we randomly drew supporting 

documents for our case studies.

 

1

USAID’s Office of the Inspector General is responsible for overseeing MCC activities.
Appendix I: Objectives, Scope, and 

Methodology

Page 20 GAO-13-615 Millennium Challenge Corporation

Table 3: Selected USAID Office of the Inspector General Audit Reports, by Title and Number

Report title Report number

Audit of the Millennium Challenge Corporation’s Resettlement Activities M-000-13-002-P 

Review of Millennium Challenge Corporation’s Branding and Marking Policies and Practices M-000-12-002-S 

Review of the Millennium Challenge Corporation’s Compact Modifications M-000-12-006-S 

Audit of Millennium Challenge Corporation-Funded Programs in El Salvador M-000-11-005-P 

Review of Millennium Challenge Corporation-Funded Contracts with Government-Owned Enterprises in Mali M-000-11-004-S 

Audit of the Millennium Challenge Corporation’s Access to Markets Program in Benin M-000-10-001-P 

Audit of the Agricultural Credit Program in Ghana M-000-09-005-P 

Audit of Compliance with Procurement Requirements by the Millennium Challenge Corporation and its 

Compact Countries

M-000-08-002-P 

Review of Millennium Challenge Corporation Funded Projects in Benin M-000-12-005-S 

Limited Scope Review of Millennium Challenge Corporation (MCC) Resources Managed by the Millennium 

Development Authority (MiDA), Under the Compact Agreement Between MCC and the Government of Ghana

M-000-11-002-S 

Limited Scope Review of Millennium Challenge Corporation (MCC) Resources Managed by the Millennium 

Challenge Account-Mali (MCA-Mali), Under the Compact Agreement Between the MCC and the Government 

of Mali

M-000-10-004-S 

Millennium Challenge Corporation and Accountable Entities Compliance with “Policies and Procedures for 

Common Payment System” 

M-000-09-001-S 

Source: USAID Office of the Inspector General.

• Random sample of audit documents. Each audit contained multiple 

files, from which we randomly drew a sample of 93 documents: 20 

documents for Benin’s, Ghana’s, and Mali’s compacts; 18 documents 

for El Salvador’s compact; and 15 documents for Armenia’s compact. 

The number of documents that we sampled per compact varied for

two reasons: (1) because the OIG has not conducted a financial audit 

for Armenia’s compact, we were unable to select any financial-auditrelated documents for our sample, and (2) the performance audit files 

for El Salvador’s compact contained only 18 appropriate documents. 

Table 4 shows the number of documents we sampled per compact, by 

type of audit (financial or performance).
Appendix I: Objectives, Scope, and 

Methodology

Page 21 GAO-13-615 Millennium Challenge Corporation

Table 4: Number of Documents in Random Sample, per MCC Compact and Type of 

Audit

Country

Financial audit

documents

Performance audit 

documents

Total

documents 

Armenia n/a 15 15

Benin 5 15 20

El Salvador 3 15 18

Ghana 5 15 20

Mali 5 15 20

Total 18 75 93

Source: GAO.

• Requests for sampled documents. We provided a list of the 

randomly sampled documents for each case-study compact to MCC. 

We identified each document using, as appropriate, its title, date, and 

other identifying information (e.g., contract number, payment order 

number, beneficiary name, letter recipient). For Benin’s, Ghana’s, El 

Salvador’s, and Mali’s compacts, we listed the document titles and 

other information in the document’s original language (English, 

French, or Spanish). For Armenia, we translated the title and other 

information into English when necessary. We asked MCC to share 

these lists with the five partner governments and to request that they 

send us copies of the documents, either electronic or paper, within 20 

business days, in keeping with the Freedom of Information Act’s 

(FOIA) requirement. In response to an MCC comment that the 

documents we requested would not, as “non-records,” be subject to 

the FOIA requirement, we have reported the numbers of documents 

that the partner governments returned within 30 calendar days—the 

requirement stated in MCC’s Program Closure Guidelines. However, 

the numbers of documents returned within 20 business days were 

identical to the numbers returned within 30 calendar days.

• Verification of requested documents. To verify that the partner 

governments provided the documents we requested, we conducted 

two separate comparisons of the documents we received with 

corresponding electronic copies, which USAID’s OIG had allowed us 

to retain in our files.

We conducted this performance audit from September 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 
Appendix I: Objectives, Scope, and 

Methodology

Page 22 GAO-13-615 Millennium Challenge Corporation

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

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: MCC Scores on NARA SelfAssessment Survey, 2009-2012

Page 23 GAO-13-615 Millennium Challenge Corporation

Since 2009, the National Archives and Records Administration (NARA) 

has administered a survey to assess federal agencies’ compliance with 

federal records-keeping laws and regulations. The Millennium Challenge 

Corporation (MCC) has received the following scores: 92 (2009), 83

(2010), 76 (2011), and 77 (2012). See tables 5 through 8 below for more 

information. 

Table 5: MCC Scores on NARA Self-Assessment Survey, by Section, 2009

Survey sections

MCC 

score

Total 

possible 

score Percentage

Records management program 22 26 85% 

Records disposition 18 18 100

Email 30 30 100

Electronic records 14 18 78

Vital records 8 8 100

Total score 92 100 92%

NARA rating of overall risk factor: Low

Source: GAO analysis of MCC results on NARA survey

Table 6: MCC Scores on NARA Self-Assessment Survey, by Section, 2010

Survey sections

MCC 

score

Total 

possible 

score Percentage

Records management program 14 14 100%

Records management activities 12 15 80

Electronic records 12 15 80

Records disposal 16 18 89

Vital records 8 8 100

Records management training 21 30 70

Total score 83 100 83%

NARA rating of overall risk factor: Moderate

Source: GAO analysis of MCC results on NARA survey

Appendix II: MCC Scores on NARA SelfAssessment Survey, 2009-2012
Appendix II: MCC Scores on NARA SelfAssessment Survey, 2009-2012

Page 24 GAO-13-615 Millennium Challenge Corporation

Table 7: MCC Scores on NARA Self-Assessment Survey, by Section, 2011

Survey sections

MCC 

score

Total 

possible 

score Percentage

Records management activities 20 20 100%

Oversight/compliance 31 37 84

Records disposition 16 18 89

Electronic records 9 25 36

Total score 76 100 76%

NARA rating of overall risk factor: Moderate

Source: GAO analysis of MCC results on NARA survey

Table 8: MCC Scores on NARA Self-Assessment Survey, by Section, 2012

Survey sections

MCC

score

Total 

possible 

score Percentage

Records management activities 21 21 100%

Oversight/compliance 23 31 74

Records disposition 15 15 100

Electronic records 18 33 55

Total score 77 100 77%

NARA rating of overall risk factor: Moderate

Source: GAO analysis of MCC results on NARA survey
Appendix III: Comments from the Millennium 

Challenge Corporation

Page 25 GAO-13-615 Millennium Challenge Corporation

Appendix III: Comments from the Millennium 

Challenge Corporation 
Appendix III: Comments from the Millennium 

Challenge Corporation

Page 26 GAO-13-615 Millennium Challenge Corporation
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 27 GAO-13-615 Millennium Challenge Corporation

David Gootnick, (202) 512-3149, or gootnickd@gao.gov

In addition to the contact named above, Emil Friberg, Jr. (Assistant 

Director) and Miriam Carroll Fenton made key contributions to this report. 

Additional technical assistance was provided by Reid Lowe, Christopher 

Mulkins, Justin Fisher, Martin de Alteriis, Nancy Hunn, Mark Bird, Etana 

Finkler, and Ernie Jackson.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(320942)
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