ARCHITECT OF THE 

CAPITOL

Incorporating All 

Leading Practices 

Could Improve 

Accuracy and 

Credibility of Projects’ 

Cost Estimates

Report to Congressional Committees

March 2014

GAO-14-333

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-333, a report to 

congressional committees

March 2014

ARCHITECT OF THE CAPITOL

Incorporating All Leading Practices Could Improve 

Accuracy and Credibility of Projects' Cost Estimates

Why GAO Did This Study

AOC is responsible for the 

maintenance, renovation, and new 

construction of the U.S. Capitol 

complex, which comprises more than 

four dozen facilities. Reliable cost 

estimates for projects are crucial to 

AOC’s capital-planning and 

construction processes. The House 

Appropriations Committee report 

accompanying the fiscal year 2014 

Legislative Branch Appropriations bill 

mandated that GAO review AOC’s 

cost-estimating methodology. 

This report addresses the extent to 

which AOC’s policies and guidance for 

developing cost estimates adheres to 

leading practices. GAO analyzed 

AOC’s cost-estimating guidance, 

interviewed AOC officials, and 

compared AOC’s cost-estimating 

guidance and documentation and two 

projects’ cost estimates to leading 

practices in GAO’s Cost Guide. When 

most or all of the practices associated 

with each characteristic of a highquality, reliable estimate are followed, 

GAO considers the characteristic to be 

“fully” or “substantially” met. When, in 

turn, all four characteristics are at least 

“fully” or “substantially” met, GAO 

considers a cost estimate to be 

reliable.

What GAO Recommends

GAO recommends that AOC 

incorporate additional leading practices 

into its cost-estimating guidance and 

submit the confidence levels of project 

estimates to Congress. AOC concurred 

with the recommendations and 

provided context and clarification on its 

cost-estimating guidance and policies.

What GAO Found

GAO’s Cost Estimating and Assessment Guide (Cost Guide) defines 12 leading 

practices that are associated with four characteristics—comprehensive, well 

documented, accurate, and credible—that are important to developing highquality, reliable project-cost estimates. Using the Cost Guide, GAO determined 

that the Architect of the Capitol’s (AOC) cost-estimating guidance conforms to 

leading practices for developing estimates that are, in general, comprehensive

and well-documented. However, AOC’s guidance does not substantially conform 

to leading practices related to developing cost estimates that are accurate and 

credible. For example, pertaining to the credible characteristic, AOC’s guidance 

does not require determining the confidence level of estimates or quantifying the 

extent to which a project’s costs could vary due to changes in key assumptions. 

GAO found the strengths and weaknesses of AOC’s guidance generally reflected 

in the cost estimates for AOC’s Cannon House Office Building’s (Cannon 

Building) renewal project ($753 million) and Capitol Dome’s restoration project 

($125 million). 

• Cannon Building renewal—GAO found the estimate is substantially 

comprehensive, well documented, and accurate, but several factors that 

affect its credibility are lacking. For example, AOC’s risk analysis does 

not allow for determination of which risks have the greatest influence on 

project costs and may overstate the effect of the risks. 

• Capitol Dome restoration—GAO found the estimate is substantially 

comprehensive and well documented, but lacking key analysis that 

support accurate and credible estimates. For example, AOC did not use 

actual costs from completed phases to update its estimates and did not 

complete a risk and uncertainty analysis. 

Overall, AOC’s cost-estimating guidance may not enable fully reliable estimates 

because it incorporates some, but not all, leading practices. Without reliable cost 

estimates that convey their confidence levels, AOC’s projects risk experiencing 

cost overruns or budget surpluses, missed deadlines, and performance 

shortfalls. Potential limitations in the reliability of AOC’s estimates may make it 

difficult for Congress to make well-informed funding decisions and affect how 

AOC allocates resources across competing projects in its capital portfolio.

GAO’s Assessment of AOC’s Cost-Estimating Characteristics in Its Guidance for Two 

Project Cost Estimates

Characteristic AOC’s guidance Cannon Office Building Capitol Dome

Comprehensive ● ◕ ◕

Well documented ● ◕ ◕

Accurate ◑ ◕ ◑

Credible ◔ ◑ ◔

Source: GAO analysis of AOC documents and data.

●= Fully Meets ◕=Substantially Meets ◑=Partially Meets ◔=Minimally Meets ○= Does Not Meet

Note: A characteristic is fully met when the associated tasks of underlying leading practices are 

completely satisfied; substantially met when a large portion of the associated tasks are satisfied; 

partially met when about half of the associated tasks are satisfied; minimally met when a small portion 

of the associated tasks are satisfied; and not met when none of the associated tasks are satisfied.

View GAO-14-333. For more information, 

contact Lorelei St. James at (202) 512-2834 or 

stjamesl@gao.gov 
Page i GAO-14-333 Capitol Complex Cost Estimating

Letter 1 

Background 4

AOC’s Policies and Guidance Conform to Leading Practices for 

Two Characteristics of Reliable Cost Estimates, but Fall Short 

in Two Others 11

Conclusions 23

Recommendations 23

Agency Comments and Our Evaluation 23

Appendix I The Leading Practices for Developing High-Quality Cost 

Estimates and Associated Tasks 25

Appendix II Objectives, Scope, and Methodology 28

Appendix III GAO’s Summary Assessments of AOC’s Project Cost Estimates 

for the Cannon Building’s Renewal and Capitol Dome’s Restoration 31

Appendix IV Comments from the Architect of the Capitol 34

Appendix V GAO Contact and Staff Acknowledgments 43

Tables

Table 1: GAO’s Cost-Estimating Characteristics and Leading 

Practices 4

Table 2: Phases and Budget of the Capitol Dome’s Restoration 

Project, as of February 2014 10

Table 3: GAO Summary Assessment of AOC Cost-Estimating 

Guidance and Policies 11

Contents
Page ii GAO-14-333 Capitol Complex Cost Estimating

Figures

Figure 1: Cannon House Office Building, Washington D. C. 6

Figure 2: Scope and Phases of AOC’s Renewal Project for the 

Cannon Building, as of February 2014 8

Figure 3: Damage to Capitol Dome, Outside Left, Inside Right 

(2013 Photographs) 9

Abbreviations

AOC Architect of the Capitol

EAC estimate at completion 

EVM earned value management

FCA facility condition assessment

ICE independent cost estimate 

LCCE life-cycle cost estimate

WBS work breakdown structure

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-14-333 Capitol Complex Cost Estimating

441 G St. N.W.

Washington, DC 20548

March 25, 2014

The Honorable Jeanne Shaheen

Chairwoman

The Honorable John Hoeven

Ranking Member

Subcommittee on Legislative Branch

Committee on Appropriations

United States Senate

The Honorable Tom Cole

Chairman

The Honorable Debbie Wasserman Schultz

Ranking Member

Subcommittee on Legislative Branch

Committee on Appropriations

House of Representatives

The Architect of the Capitol (AOC) is responsible for the maintenance, 

renovation, and new construction of the U.S. Capitol complex in 

Washington, D. C., which comprises more than four dozen facilities. 

Among the major projects involving these facilities, AOC has begun work 

restoring the dome atop the U.S. Capitol (Capitol Dome) and designing 

the renewal of the Cannon House Office Building (Cannon Building). AOC 

currently estimates the Capitol Dome and Cannon Building project costs 

to be $125 million and $753 million, respectively.1

Reliable cost estimates are crucial for supporting AOC’s capital planning 

and construction processes. Without a reliable cost estimate, an AOC 

project is at risk of experiencing cost overruns, budget surpluses, missed 

deadlines, and performance shortfalls. Furthermore, AOC’s ability to 

generate reliable cost estimates is important to informing Congress’ 

funding decisions and enabling AOC to effectively allocate resources 

 

1

For the purposes of this report, a cost estimate is the summation of individual cost 

elements, using established methods and valid data, to estimate the future costs of a 

program, based on what is known today. AOC’s estimates for the Capitol Dome 

restoration and Cannon Building renewal include costs for planning, design, construction, 

and implementation. Implementation includes costs for construction contract 

administration, testing, inspection, and quality control. 
 

Page 2 GAO-14-333 Capitol Complex Cost Estimating

across competing projects in its capital program. The House 

Appropriations Committee report accompanying the fiscal year 2014 

Legislative Branch Appropriations Bill (H.R. 2792) mandated that we 

review AOC’s cost-estimating methodology to ensure that AOC is 

accounting for all of the variables that should contribute to a project’s cost 

estimates.2 This report addresses the extent to which AOC’s policies and 

guidance for developing cost estimates conform to leading practices 

identified in GAO’s Cost Estimating and Assessment Guide3

In conducting our study, we reviewed AOC’s policies and guidance for 

developing cost estimates and interviewed AOC officials. To determine 

the extent to which AOC’s policies and guidance comply with practices for 

cost estimating, we compared them to the leading practices set forth in 

GAO’s Cost Estimating and Assessment Guide (Cost Guide).

and provide 

a reliable basis to support funding and capital program decisions. This 

report also examines whether the estimates for the Capitol Dome and the 

Cannon Building projects reflect leading practices.

4

 

2

H. R. Rep. No. 113-173, at 11 (2013).

The Cost 

Guide identifies 12 leading practices that represent work across the 

federal government and private sector and that have been found to be the 

basis for a high-quality, reliable project cost estimate. An estimate created 

using the leading practices exhibits four broad characteristics: it is 

comprehensive, well documented, accurate and credible. That is, each 

characteristic is associated with a specific set of leading practices. In turn, 

each leading practice is made up of a number of specific tasks. (See 

appendix I for a listing of the tasks that make up each of the 12 leading 

practices.) When the tasks associated with the leading practices that 

define a characteristic are mostly or completely satisfied, we consider the 

characteristic to be “substantially” or “fully” met. When all four 

3

GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009). 

4

GAO-09-3SP. 
 

Page 3 GAO-14-333 Capitol Complex Cost Estimating

characteristics are at least “substantially met”—we consider a cost 

estimate to be reliable.5

We also examined AOC’s cost estimates for two major capital projects: 

the Cannon Building renewal and the Capitol Dome restoration. We 

selected these projects based on their significance to the Capitol 

complex, comparatively high costs, and public visibility. In addition, our 

review of the Cannon Building’s renewal estimate is responsive to 

another mandate in the House Appropriations Committee report 

accompanying the fiscal year 2010 Legislative Branch Appropriations Bill 

(H.R. 2918) requiring us to monitor the progress of the project.6

We conducted our work from September 2013 to March 2014 in 

accordance with all sections of GAO’s Quality Assurance Framework that 

are relevant to our objectives. The framework requires that we plan and 

perform the engagement to obtain sufficient and appropriate evidence to 

meet our stated objectives and to discuss any limitations in our work. We 

We 

selected versions of the estimates to review that had the most complete 

information for our assessments. We assessed the reliability of data used 

in developing the estimates and found them to be sufficiently reliable for 

the purposes of this report. For example, while some source data were

unavailable to us, we were able to assess AOC’s process for building its 

estimates with the data and check for errors. We also interviewed AOC 

staff and its technical consultant about these projects and observed 

existing conditions at the Cannon Building and Capitol Dome. While our 

review of these projects’ cost estimates provides key insights and 

illustrates recent products of AOC’s cost-estimating policies and 

guidance, the results of our review should not be used to make 

generalizations about all AOC project cost estimates.

 

5

We established five descriptions for our assessments of leading practices and cost 

estimate characteristics: Fully Meets, Substantially Meets, Partially Meets, Minimally 

Meets, and Does Not Meet. We consider a leading practice to be fully met when the 

associated tasks are completely satisfied; substantially met when a large portion of the 

associated tasks are satisfied; partially met when about half of the associated tasks are 

satisfied; minimally met when a small portion of the associated tasks are satisfied; and not 

met when none of the associated tasks are satisfied. Our assessment method weights 

each leading practice equally and bases the assessment of each characteristic on the 

average score of underlying leading practices. We assign each description a numerical 

value (5 for Fully Meets to 1 for Does Not Meet) and round scores to the higher numerical 

value (i.e., a score of 4.5 would round up to 5). 

6

H. R. Rep. No. 111-160, at 21 (2009).
 

Page 4 GAO-14-333 Capitol Complex Cost Estimating

believe that the information and data obtained, and the analysis 

conducted, provide a reasonable basis for any findings and conclusions in 

this product. Appendix II provides a more detailed description of our 

scope and methodology.

The GAO Cost Estimating and Assessment Guide7 explains how four 

characteristics of a high-quality, reliable cost estimate can be understood 

in relation to 12 leading practices. The extent to which an agency meets 

the leading practices underlying each characteristic determines its 

performance for that characteristic.8

Table 1: GAO’s Cost-Estimating Characteristics and Leading Practices

For example, we consider the 

comprehensive characteristic to be “substantially met” if the organization 

substantially meets the underlying leading practices of (1) developing an 

estimating plan and (2) determining an estimating structure. Because the 

leading practices are separate and discrete, an agency’s performance in 

each of the characteristics can vary. For example, an organization’s cost 

estimating methodology could be found to be comprehensive and well 

documented, but not accurate or credible, resulting in the organization 

producing cost estimates of limited reliability. Table 1 illustrates the 

relationship of the 12 leading practices to the four characteristics of a 

high-quality, reliable estimate.

Four characteristics of a high-quality, reliable cost estimate 12 leading practices to develop high-quality, reliable estimates

Comprehensive when estimate accounts for all possible costs 

associated with a program, is structured in sufficient detail to 

ensure that costs are neither omitted nor double counted, and 

documents all cost-influencing assumptions.

Develop the estimating plan

Determine the estimating structure

Well documented when supporting documentation explains the 

process, sources, and methods used to create the estimate; 

contains the underlying data used to develop the estimate; and 

is adequately reviewed and approved by management.

Define the estimate’s purpose

Define the program’s characteristics

Identify ground rules and assumptions

Obtain the data

 

7

GAO-09-3SP. 

8

See footnote 5.

Background

Cost-Estimating Leading 

Practices
 

Page 5 GAO-14-333 Capitol Complex Cost Estimating

Four characteristics of a high-quality, reliable cost estimate 12 leading practices to develop high-quality, reliable estimates

Document the estimate

Present the estimate to management for approval

Accurate when estimate is not overly conservative or optimistic, 

is based on an assessment of the costs most likely to be 

incurred, and is regularly updated so that it always reflects the 

program’s current status.

Develop the “point estimate”

a

Update the estimate to reflect actual costs/changes

Credible when (1) any limitations of the analysis because of 

uncertainty or sensitivity surrounding data or assumptions are 

discussed, (2) the estimate’s results are cross-checked, and (3) 

an independent cost estimate is conducted by a group outside 

the acquiring organization to determine whether other 

estimating methods produce similar results. 

Compare the point estimate to an independent cost estimatea

Conduct sensitivity analysis

Conduct a risk and uncertainty analysis

Source: GAO.

a

As described in the GAO Cost Estimating and Assessment Guide, developing the point estimate and comparing it to an independent 

cost estimate—shown separately in the table—are separate parts of a single leading practice. For purposes of assessing the extent to 

which a cost estimate achieves the characteristics of a high-quality cost estimate, developing the point estimate contributes to 

accuracy, while comparing the point estimate to an independent cost estimate contributes to credibility. A “point estimate” is the most 

likely value for the cost estimate, given the underlying data.

AOC project development consists of three stages: planning, design, and 

construction. According to AOC’s guidance, AOC refines requirements 

and updates cost estimates as projects progress through these stages. 

AOC has guidance and requirements for cost estimates at each stage of 

a project’s development. In general, as projects develop over time and 

requirements are refined, the accuracy of cost estimates is expected to 

increase.

Given the current fiscal environment and existing building conditions, 

AOC must prioritize projects in its capital program and decide to either 

request funding for a project or defer it while mitigating potential facility 

issues. For example, in fiscal year 2014, AOC requested almost $155 

million for 17 projects that AOC deemed urgent, while deferring 46 

projects estimated to cost about $172 million.9 Two of AOC’s largest and 

most recognizable projects that it considers urgent are the Cannon 

Building renewal and the Capitol Dome restoration.

The Cannon Building, completed in 1908, is the oldest congressional 

office building and is occupied by members of the House of 

 

9

Architect of the Capitol, Budget Justification Fiscal Year 2014 (Washington, D.C.).

AOC’s Project 

Development

Cannon Building’s

Renewal
 

Page 6 GAO-14-333 Capitol Complex Cost Estimating

Representatives and their staffs. (See fig. 1.) The building houses 142 

office suites, 5 conference rooms, 4 hearing rooms, and the Caucus 

Room, which can accommodate large meetings. The building also 

provides space for a library, food service, and a health unit.

Figure 1: Cannon House Office Building, Washington D. C. 

According to AOC planning studies, the building is plagued with serious 

safety, health, environmental, and operational issues that are worsening. 

For example, without action, essential systems for heating and cooling 

that are located behind walls and in mechanical rooms will continue to 

deteriorate, potentially negatively affecting Members of Congress, staff, 

and constituents. AOC has been developing the scope of the Cannon 

Building’s renewal project since approximately 2004 when AOC’s

consultant conducted a facility condition assessment (FCA) that identified 

the building’s deficiencies.10 In 2009, we reviewed AOC’s progress in 

developing the Cannon Building project and found that while it had 

followed a reasonable process to plan the building’s renewal such as 

through updating the FCA, it was important that AOC continue, as 

planned, to refine the project’s scope and cost estimate.11

 

10Condition assessments provide information on a facility’s state of repair and are 

developed from inspections of structural, electrical, mechanical, plumbing, and other 

building systems. FCA reports typically catalog all of the deficiencies identified during the 

inspections along with the estimated cost to correct the problems. 

Since our 2009 

review, AOC has proceeded with the design phase of the project, based 

11GAO, Architect of the Capitol: Plans for Renovating the Cannon House Office Building 

and Garages, GAO-09-673T (Washington, D.C.: May, 6, 2009). 
 

Page 7 GAO-14-333 Capitol Complex Cost Estimating

upon its budget of $753 million for the planning, design, and construction 

phases. The project is currently expected to be completed by 2025.

According to AOC officials and current design documents, AOC plans to 

correct most of the Cannon Building’s identified deficiencies and to 

address requirements such as energy conservation, physical security, 

hazardous materials abatement, and historic preservation. The project is 

to involve substantial reconfiguration of interior and exterior spaces to 

include reconstructing the building’s top floor, which now partially consists 

of storage space, and landscaping the courtyard. The project is also 

expected to provide refurbished windows and a new roof. Additional work 

is intended to preserve and repair the building’s stone exterior. The 

project is also expected to allow for complete replacement of all plumbing, 

heating and cooling, fire protection, electrical, and alarm systems; 

refurbish restrooms and make them more accessible to people with 

disabilities; and provide new wall and floor finishes in some areas. In 

addition, the project includes removing asbestos that may be contained in 

plaster ceilings and walls. AOC plans to conduct the work in phases 

corresponding to the four sections of the building and including an initial 

phase for utility work as shown in figure 2. Tenants displaced during 

construction of each section are to move to temporary offices while other 

occupants will remain in building sections not affected by construction.
 

Page 8 GAO-14-333 Capitol Complex Cost Estimating

Figure 2: Scope and Phases of AOC’s Renewal Project for the Cannon Building, as of February 2014

The U.S. Capitol Dome, an important symbol of American democracy and 

an architectural icon, was constructed of cast iron more than 150 years 

ago. According to AOC, the dome has not undergone a complete 

restoration since 1960, and due to age and weather is now plagued by 

more than 1,000 cracks and deficiencies that are causing it to deteriorate. 

Figure 3 shows cracks at the exterior column base and deteriorating 

interior paint.

Capitol Dome Restoration
 

Page 9 GAO-14-333 Capitol Complex Cost Estimating

Figure 3: Damage to Capitol Dome, Outside Left, Inside Right (2013 Photographs)

The project is intended to stop deterioration in the dome’s cast iron 

structure as well as to ensure the protection of the interior of the dome 

and rotunda. In the 1960 restoration, the dome was stripped of its paint so 

the ironwork could be repaired, primed with a rust inhibitor, and then 

repainted. As part of the current project, AOC is undertaking similar 

restorative work to include removing old paint, repairing the cast iron, and 

repainting.

The project has proceeded in phases as shown in table 2, with phase IIA 

restoration work currently in progress. In earlier phases, AOC completed 

interim painting, revalidated the project’s design, and restored the base—

or skirt—of the dome. To complete the project, AOC is seeking 

appropriations of about $20 million for construction and other costs for 

phase IIC work in fiscal year 2015. As of February 2014, AOC estimated 

the total cost of the Capitol Dome restoration project at about $125 

million.
 

Page 10 GAO-14-333 Capitol Complex Cost Estimating

Table 2: Phases and Budget of the Capitol Dome’s Restoration Project, as of 

February 2014

Phase Description Status 

Total cost

($ Thousands)

IA Interim painting 2002 Completed 01/03/2003 Not included

IB Interim painting 2010 Completed 12/20/2010 2,500

IC Skirt restoration Completed 09/01/2012 19,959

Phase II Design revalidation Completed 12/12/2012 3,996

Phase IIA Dome restoration exterior

estimated 24-month duration

Contract Awarded 

09/30/2013

58,070

Phase IIB Dome restoration interior

estimated 9-month duration

Option in phase IIA 

contract

(fiscal year 2014 

appropriations received, 

option not yet exercised)

15,400

Phase IIC Dome restoration Rotunda 

estimated 1- month duration

Unfunded option in phase 

IIA contract (estimated to 

be awarded in fiscal year 

2015)

20,220

Other 

Costs

Study, design, inspection,

US Capitol Police overtime

Miscellaneous over phases 5,228

Total 125,373

Source: GAO analysis of AOC data. 

Note: We focused our assessment on estimates for work currently in progress (phase IIA) or planned 

to be completed (phases IIB and IIC).
 

Page 11 GAO-14-333 Capitol Complex Cost Estimating

As previously discussed, the GAO Cost Estimating and Assessment 

Guide12 defines 12 leading practices related to four characteristics—

comprehensive, well documented, accurate, and credible—that are 

important to developing high-quality, reliable estimates.13 Our analysis 

determined how well AOC met a characteristic based on our assessment 

of AOC’s conformance to the leading practices related to that 

characteristic. We discuss characteristics using five rating categories—

does not meet, minimally meets, partially meets, substantially meets, or 

fully meets.14

Table 3: GAO Summary Assessment of AOC Cost-Estimating Guidance and Policies

As shown in table 3, our analysis found that AOC’s costestimating policies and guidance contribute to estimates that are 

comprehensive and well documented in that AOC fully meets most of the 

tasks that underlie the leading practices associated with these two 

characteristics. We found that AOC’s cost-estimating policies and 

guidance partially met the accuracy characteristic and minimally met the 

credible characteristic based on their conformance to the leading 

practices associated with those characteristics. Table 3 also contains key 

examples of our rationale for our assessment of each leading practice 

and characteristic.

GAO 

assessment Characteristic Leading Practice Key examples of rationale for assessment 

● Comprehensive Develop the estimating plan AOC has a formal process that develops the estimating plan, 

including describing responsible parties and defining specific tasks.

Determine the estimating 

structure 

The estimating structure follows a work breakdown structure (WBS)a

that appears to be standard in the construction industry.

● Well 

documented

Define estimate’s purpose AOC uses different types of cost estimates and has defined when 

each applies and what each entails.

Define the program’s 

characteristicsb AOC has formally defined program characteristics.

Identify ground rules and 

assumptions

AOC points to supporting documents that, when developed, should 

contain ground rules and assumptions specific to a given project. 

Obtain the data AOC guidance is specific about sources of data. These include 

commercially available construction cost databases as well as 

market and industry knowledge, staff knowledge, and historical data.

 

12GAO-09-3SP. 

13See Appendix I for the associated tasks within the 12 leading practices.

14See footnote 5.

AOC’s Policies and 

Guidance Conform to 

Leading Practices for 

Two Characteristics 

of Reliable Cost 

Estimates, but Fall 

Short in Two Others
 

Page 12 GAO-14-333 Capitol Complex Cost Estimating

GAO 

assessment Characteristic Leading Practice Key examples of rationale for assessment 

Document the estimate AOC’s guidance explains how to document the estimate.

Present estimate to 

management for approval

AOC’s guidance requires management approval of estimates. 

◐ Accurate Develop the point estimatec AOC develops point estimates as projects progress through 

planning and design phases to support budget requests.

Update the estimate to 

reflect actual costs/changes

AOC does not update estimates with actual costs as projects 

progress.

◔ Credible Compare the point estimate 

to an independent cost 

estimate (ICE)c

ICE’s defined by AOC’s estimating process have a limited degree of 

independence.

Conduct a sensitivity 

analysis

AOC guidance discusses some sensitivity analysis, but it skips 

many steps identified by GAO in its leading practices.

Conduct a risk and 

uncertainty analysis

AOC’s guidance is to set aside a fixed amount for contingency.d This 

is not as beneficial as quantitative-risk and uncertainty analysis to 

assess the variability in the estimate and the level of confidence 

associated with the cost estimate. 

Source: GAO analysis of AOC data. 

●= Fully Meets: AOC provided complete evidence that satisfies the associated tasks of the leading 

practices

◕=Substantially Meets: AOC provided evidence that satisfies a large portion of the associated tasks 

of the leading practices

◑=Partially Meets: AOC provided evidence that satisfies about half of the associated tasks of the 

leading practices

◔=Minimally Meets: AOC provided evidence that satisfies a small portion of the associated tasks of 

the leading practices

○= Does Not Meet: AOC provided no evidence that satisfies the associated tasks of the leading 

practices

a

A WBS deconstructs a program’s end product into successive levels with smaller specific elements 

until the work is subdivided to a level suitable for management control. AOC requires use of the 

ASTM UNIFORMAT II structure, which is organized according to systems or assemblies that are 

common to most buildings, for estimates.

b

In the context of this report, a program refers to a group of projects or functions associated with 

delivering a capital asset. For example, the Cannon House Office Building program refers to projects 

or functions—completed via contract or by AOC staff—for planning, designing, and constructing all 

phases of the renewal work and providing for ongoing operations and maintenance of the facility.

c

As described in the GAO’s Cost Estimating and Assessment Guide, developing the point estimate 

and comparing it to an independent cost estimate are separate parts of a single leading practice. For 

purposes of assessing the extent to which a cost estimate achieves the characteristics of a highquality cost estimate, developing the point estimate contributes to accuracy, while comparing the 

point estimate to an independent cost estimate contributes to credibility.

d

AOC applies additional percentages to the items in the cost estimate for contingencies at a series of 

milestones in completing projects’ design and construction documents as established by AOC policy. 

For example, early in the projects’ design, AOC establishes a contingency range for design at 20 to 

25 percent and construction at 5 to 20 percent. When the design is completed, the design 

contingency is removed.
 

Page 13 GAO-14-333 Capitol Complex Cost Estimating

In reference to the leading practices underlying the characteristics of a 

comprehensive cost estimate, we found that AOC

• has a formal process for developing estimating plans, and

• follows an estimating approach incorporating a work breakdown 

structure (WBS) that is widely used in the construction industry.15

In developing estimating plans, we found that AOC’s policies and 

guidance that describe the project-planning process provide the 

framework for meeting this leading practice. In the planning stage, AOC 

project managers establish project scope and outline roles and 

responsibilities for planning, design, and construction stages. To facilitate 

these efforts, AOC project managers are to use particular documents. 

One document, the Project Development Form, provides a basis for 

preparing requirements studies that help to define scope and estimate 

costs. AOC then is to use this information in developing Project 

Management Plans that are to describe other key components of project 

delivery. These components include defining the strategy for providing 

design and construction services, identifying project team members, 

establishing a communications plan, and setting project controls such for 

managing project changes. AOC also considers cost reporting as a 

component of the project delivery process.16

 

15A WBS deconstructs a program’s end product into successive levels with smaller 

specific elements until the work is subdivided to a level suitable for management control. 

For estimates, AOC requires use of the ASTM UNIFORMAT II structure, which is 

organized according to systems or assemblies that are common to most buildings. 

For example, AOC typically 

requires its design contractors to provide cost reports at the same time 

incremental design submittals are made. Because AOC’s project 

development process accounts for cost reporting, we determined that it 

16AOC’s policies and guidelines define cost reports that are relevant to various points of a 

project’s development. Reports range from “exploratory cost assessments,” conducted at 

a pre-planning stage, to a “construction cost estimate,” based on completed and approved 

construction documents. 

AOC Conforms to the 

Leading Practices 

Associated with 

Comprehensive and Well 

Documented Cost 

Estimates

Comprehensive
 

Page 14 GAO-14-333 Capitol Complex Cost Estimating

satisfies the intent of the leading practice encouraging use of a formal 

process for developing estimating plans.

With regard to leading practices related to producing well-documented 

estimates, we found that AOC

• requires formal definitions of program17

• develops ground rules and assumptions from supporting documents;

characteristics, such as the 

program’s purpose;

• requires the use of cost data sources that are specific to the 

construction industry (i.e., obtain the data);

• requires documenting the estimate and supporting documents; and

• requires management approval of the cost estimate.

AOC fully meets the requirements of most of these leading practices.18

For example, AOC’s policies and guidance for the project development 

process provide the structure to enable an adequate understanding of 

program characteristics—such as key design features, technical 

definitions, and the acquisition strategy—that will comprise the cost 

estimate. In addition, AOC guidance establishes requirements for use of 

industry-accepted cost-data sources and allows for application of staff 

knowledge and historical data in developing estimates.19

 

17In the context of this report, a program refers to a group of projects or functions 

associated with delivering a capital asset. For example, the Cannon House Office Building 

program refers to projects or functions—completed via contract or by AOC staff—for 

planning, designing, and constructing all phases of the renewal work and providing for 

ongoing operations and maintenance of the facility. 

AOC guidance 

also provides for estimates to be documented to show important 

parameters, assumptions, descriptions, methods, and calculations used 

to derive the estimate. However, while AOC requires management 

approval of its cost estimates, it falls short of fully meeting the 

requirements of this leading practice. In particular, AOC’s briefings do not 

include the level of information defined by our leading practice, 

18We determined that AOC fully meets the well-documented characteristic even though it 

does not fully meet the requirements of the six underlying leading practices. Our 

assessment method weights each leading practice equally and bases the category-level 

assessment on the average score of underlying leading practices. Because the average 

score of all leading practices contributing to the well documented characteristic is at the 

fully meets level, we say that AOC fully meets the requirements of the well-documented 

characteristic.

19Industry sources include the R.S. Means Cost Database.

Well Documented
 

Page 15 GAO-14-333 Capitol Complex Cost Estimating

particularly information related to risks associated with the underlying 

data and methods. This is due, in part, to AOC’s policies and guidance 

not requiring a risk and uncertainty analysis in developing estimates. We 

discuss this leading practice in the following section of this report.

We found that AOC policies and guidance do not require enough detail to 

suggest that resulting estimates would be accurate and credible.

In reference to accuracy, we found that AOC’s policies and guidance 

partially meet the respective underlying leading practices pertaining to 

this characteristic. According to AOC’s policies and guidance, AOC is to 

develop estimates as projects progress through planning and design 

phases that are based on sufficiently detailed documentation of 

construction requirements. AOC is to then use these estimates to support 

budget requests for construction funding. However, AOC’s guidance does 

not require that cost estimates be updated with actual costs during a 

project’s construction phase—a leading practice. According to the Cost 

Guide, updating estimates to reflect actual costs as the project 

progresses allows agencies to review variances between planned and 

actual costs and provides insight as to how the project changed over 

time.

In reference to credibility, we found that AOC’s policies and guidance 

minimally meet the underlying leading practices pertaining to this 

characteristic. For example, we found that AOC’s guidance does not 

require

AOC Partially and 

Minimally Conforms to the 

Leading Practices 

Associated with Accurate 

and Credible Cost 

Estimates, Respectively

Accurate

Credible
 

Page 16 GAO-14-333 Capitol Complex Cost Estimating

• following all steps for conducting a “sensitivity analysis”20

• conducting a risk and uncertainty analysis.

and 

determining the estimate’s reasonableness, and

21

While AOC guidance does discuss conducting some sensitivity analysis, 

it skips many associated tasks of leading practices we identified, such as 

identifying key cost drivers, ground rules and assumptions for sensitivity 

testing, and evaluating the results to determine which drivers most affect 

the cost estimate. Similarly, while AOC guidance provides that 

contingencies be added to estimates to account for risk and uncertainty, 

AOC’s guidance does not provide documented reasons explaining how 

the actual budgeted amounts for unforeseen costs were developed.22

AOC officials told us that while their policies and guidance do not require 

sensitivity or “quantitative-risk and uncertainty analyses,” they perform 

such assessments qualitatively to establish budget contingency. 

However, the leading practice to determine whether a program is 

realistically budgeted is to perform a quantitative-risk and uncertainty 

analysis,23

 

20According to the Cost Guide, a “sensitivity analysis” addresses some of the estimating 

uncertainty by testing discrete cases of assumptions and other factors that could change. 

By examining each assumption or factor independently, while holding all others constant, 

the cost estimator can evaluate the results to discover which assumptions or factors most 

influence the estimate. A sensitivity analysis also requires estimating the high and low 

uncertainty ranges for significant cost driver input factors. To determine what the key cost 

drivers are, a cost estimator needs to determine the percentage of total cost that each 

cost element represents. The major contributing variables within the highest percentage 

cost elements are the key cost drivers that should be varied in a sensitivity analysis.

so that the probability associated with achieving its point 

estimate can be determined. The results of a quantitative-risk and 

uncertainty analysis—the range of costs around a point estimate—can be 

useful to decision makers because it conveys the confidence level in 

21“Quantitative-risk and uncertainty analysis” provide a way to assess the variability in the 

estimate. Using this type of analysis, a cost estimator can model such effects as 

schedules slipping, missions changing, and proposed solutions not meeting user needs, 

allowing for a known range of potential costs.

22AOC applies additional percentages to the items in the cost estimate for contingencies 

at a series of milestones in completing the design and construction documents of the 

project as established by AOC policy. For example, early in the projects’ design, AOC 

establishes a contingency for design at 20 to 25 percent and construction at 5 to 20 

percent. When the design is completed, the design contingency is removed. 

23The analysis produces a cumulative probability distribution, more commonly known as 

an S curve—usually derived from a simulation such as Monte Carlo—and is useful in 

portraying the uncertainty implications of various cost estimates.
 

Page 17 GAO-14-333 Capitol Complex Cost Estimating

achieving the most likely cost and informs them about cost, schedule, and 

technical risks.

24

In addition, pertaining to the leading practice of developing a point 

estimate and comparing it to an independent cost estimate (ICE)—which 

affects both accurate and credible characteristics—we found that the 

independent estimates defined by AOC’s estimating process have a 

limited degree of independence and focus solely on proposed contractor 

costs rather than on the entire cost estimate, including both government 

and contractor efforts. According to our leading practices, an ICE, 

conducted by an organization outside the program office, provides an 

objective and unbiased assessment of whether the agency’s program 

estimate can be achieved. However, because AOC’s project 

management and cost-estimating functions are performed within the 

same organizational group, the estimates could potentially be influenced 

by AOC’s project managers and therefore could be susceptible to bias.

Not having an understanding of an estimate’s 

confidence level limits AOC’s ability to determine the appropriate level of 

contingency that is needed to address risks and uncertainty for a 

particular project and could lead AOC to ineffectively allocate resources 

across competing projects if contingency levels are either overstated or 

understated. In addition, absent information on estimates’ confidence 

levels, Congress will not have critical information for making well-informed 

funding decisions.

Because of the weaknesses in AOC’s policies and guidance pertaining to 

two of the four characteristics that are important to developing highquality, reliable estimates, the project cost estimates that AOC produces 

may not always be reliable. Without reliable cost estimates, AOC’s 

projects risk experiencing cost overruns or budget surpluses, missed 

deadlines, and performance shortfalls. Furthermore, potential limitations 

in the reliability of its estimates may impair Congress’s ability to make 

well-informed funding decisions and affect how AOC allocates resources 

across competing projects in its capital program.

 

24A “point estimate” is the most likely value for the cost estimate, given the underlying 

data. The “level of confidence for the point estimate” is the probability that the point 

estimate will actually be met. For example, if the confidence level for a point estimate is 80 

percent, there is an 80 percent chance that the final cost will be at or below the point 

estimate and a 20 percent chance that costs will exceed the point estimate.
 

Page 18 GAO-14-333 Capitol Complex Cost Estimating

In comparing the Cannon Office Building’s renewal and Capitol Dome’s

restoration cost estimates to GAO’s leading practices, we found strengths 

and weaknesses that generally correspond to our assessment of AOC’s 

overall policies and guidance for developing cost estimates.25 We initially 

determined that both estimates were comprehensive while lacking, to a 

varying extent, in their documentation, accuracy, and credibility.

26

• the Cannon Building renewal estimate to be substantially 

comprehensive, well documented, and accurate while lacking in 

elements affecting its credibility, and

Following our initial determination, AOC provided further documentation 

that resulted in improvements to each estimate’s assessment. Our final 

assessment found that

• the Capitol Dome restoration estimate to be substantially 

comprehensive and well documented while lacking in areas pertaining 

to accuracy and credibility. 

In aggregate, because of weaknesses pertaining to characteristics that 

are important to the development of high-quality, reliable estimates, 

AOC’s cost estimates for the Cannon Building’s renewal and Capitol 

Dome’s restoration may not be fully reliable.27

In reference to the comprehensive characteristic, we found that the 

estimate substantially met the underlying leading practices.

Appendix III provides 

additional details on our comparison of these two cost estimates to our 

leading practices.

28 In particular, 

the estimate uses a WBS29

 

25The strengths and weakness in the Cannon Building’ renewal and Capitol Dome’s

restoration estimates are generally consistent with the strengths and weaknesses we 

found in reviewing other agencies’ estimates. Estimates that we have reviewed include 

those from the departments of Agriculture, Commerce, Defense, Energy, Homeland 

Security, Transportation, and Veterans Affairs; the Internal Revenue Service; and the

Missile Defense Agency. 

that is standard in the construction industry 

26Our initial assessments were based upon documentation provided by AOC over a period 

of 3 months from October to December 2013.

27While our review of these projects’ cost estimates provides key insights and illustrates 

products of AOC’s cost-estimating methodology, the results of our review cannot be 

generalizable to the universe of all AOC project cost estimates.

28Appendix III provides additional information on our assessment of these estimates 

compared to the characteristics of high-quality, reliable estimates.

29See footnote 15.

Strengths and 

Weaknesses in AOC’s 

Policies and Guidance Are 

Reflected in the Cannon 

Building and Capitol Dome 

Projects

Cannon Building’s Renewal

Estimate
 

Page 19 GAO-14-333 Capitol Complex Cost Estimating

and allows for tracking of cost and schedule performance by defined 

elements of work. In addition, AOC conducted a life-cycle-cost analysis of 

the heating and cooling system alternatives it considered to include 

analyzing their energy consumption for the purpose of comparing 

operational costs. However, the estimate did not fully meet the 

characteristic as it did not include full life-cycle costs, from inception 

through design, construction, operation, and maintenance. Without a lifecycle cost analysis that captures the total cost of the project, AOC cannot 

evaluate design alternatives on a total-cost basis.

In terms of being well documented, we found that the estimate 

substantially met associated leading practices. In general, the information 

provided by AOC describes how the estimate was built up from 

engineering drawings, specifications, and design documents. In addition, 

there was evidence of documented management approval. However, the 

documentation AOC provided did not contain source data, such as from 

contractor bids or cost estimating databases. While AOC officials said 

they could obtain this information for our review, to the extent that it was 

available,30

For the accuracy characteristic, we found the estimate substantially met 

leading practices. AOC’s acquisition approach to the building’s renewal 

involves its contracting with an architect, construction manager, and 

construction contractor, each of whom produced separate estimates. 

These estimates have a limited degree of independence because they 

were conducted for the same program office and focus only on the 

proposed contractor cost. However, this array of estimates has enabled 

AOC to make comparisons among them, determine similarities and 

our leading practices indicate that an estimate’s 

documentation should be detailed enough so that the derivation of each 

cost element can be traced to all sources allowing for the estimate to be 

easily replicated and updated. Because AOC could not readily provide the 

actual source data for the estimate, we determined that it did not fully 

meet the requirements of this characteristic.

 

30AOC indicated that source data for one of the estimates we reviewed derives from a 

proprietary system maintained by its contractor. As such, AOC said that the source 

information contained in this system could not be provided to us. 
 

Page 20 GAO-14-333 Capitol Complex Cost Estimating

differences, and develop a reasonably accurate assessment of estimated 

costs.31

For the credibility characteristic, we found the estimate partially met 

leading practices. During the course of our review, AOC conducted a risk 

and uncertainty analysis in accordance with a key leading practice for this 

characteristic.32 However, we found several issues affecting the quality of 

the analysis that AOC provided to us. For example, AOC’s analysis 

concluded that the Cannon Building’s renewal estimate had a confidence 

level that exceeded 90 percent—meaning there is a greater than a 90 

percent probability that actual costs will be equal to or less than AOC’s 

estimate—which may be unreasonably high.33 However, an AOC official 

said that the agency will be reconsidering the confidence level once the 

design progresses further. In addition, we found that the method AOC 

used to model the project’s risks it identified (1) resulted in an unusually 

narrow range of estimated costs across the confidence intervals and (2) 

provides managers limited ability to understand the effects of individual 

risks.34

 

31We did not assess the cost of Cannon Building’s renewal project estimate for one of the 

leading practices for accuracy. As construction has not begun on the project, AOC has not 

had the opportunity to update the estimate with actual costs. 

Because AOC aggregated risks for the purposes of its analysis as 

opposed to modeling them separately, AOC cannot identify relationships 

between risk elements and determine which risks have the greatest 

influence on project costs. As a result, AOC is limited in its ability to 

manage the risks. In addition, modeling the aggregated risks likely 

contributes to the overly narrow range of estimated costs over the 

32While AOC’s policies and guidance for developing cost estimates do not require 

conducting a risk and uncertainty analysis, AOC officials determined during the course of 

our review that it would be beneficial to perform a quantitative-risk and uncertainty 

analysis on the cost estimate for the Cannon Building’s renewal. AOC provided a draft of 

its analysis in January 2014, and our report discusses our assessment of AOC’s draft 

analysis.

33A project funded to an unreasonably high confidence level may be over-budgeted. While 

our leading practices do not specify target confidence levels, experts we consulted in 

developing our leading practices agreed that program cost estimates should be budgeted 

to at least the 55 percent confidence level and potentially as high as 80 percent. 

34AOC identified 60 risks to the project in conducting its risk and uncertainty analysis and 

estimated that their potential cost impact was $161 million. AOC used the aggregated 

risks in creating a distribution of construction costs using a Monte Carlo simulation. 
 

Page 21 GAO-14-333 Capitol Complex Cost Estimating

confidence levels, which implies that AOC’s analysis overstates the effect 

of the risks.35

In reference to the comprehensive characteristic, we found that the 

estimate substantially met leading practices. In particular, the estimate 

uses an industry-standard WBS format and contains sufficient detail of 

the technical characteristics of the project. However, the estimate did not 

fully meet leading practices, in part because we did not find a 

consolidated list of ground rules and assumptions or descriptions of how 

these affected the estimate. Contract documents provide indications of 

ground rules and assumptions affecting the project. For example, contract 

specifications and drawings for the recently-awarded phase II work 

describe assumptions pertaining to availability of funding for contract 

options and accessibility of the site during the workday. However, we 

could not determine if these represented a comprehensive assessment of 

all ground rules and assumptions. According to the Cost Guide, because 

ground rules and assumptions can significantly affect cost and introduce 

risk, it is important that they are clearly documented in the estimate to 

enable areas of potential risk to be identified and resolved.

For the well documented characteristic, we determined the estimate as 

having substantially met leading practices. We found, for example that 

cost elements from the estimate can be compared to information in the 

drawings and specifications that define the contract for the phase II 

restoration. This linkage enables a good understanding of key 

characteristics of the estimate. In addition, AOC attested that the estimate 

had been briefed to and approved by management. However, because 

records describing briefings of the estimate to management are not well 

documented, it is difficult to trace management’s recommendations for 

changes, feedback, and key decisions affecting the project. While AOC 

officials told us that its project staff and management communicate 

routinely as part of their normal business functions, documenting 

management briefings is important because some key personnel have 

changed over the life of the Capitol Dome restoration project, which 

 

35AOC’s analysis shows, for example, the difference between the estimate at the 50 

percent confidence level and 90 percent confidence level is about $25 million, 

approximately 3 percent of the total estimate. Modeling the risks individually would likely 

have resulted in a greater spread between the 50 and 90 percent confidence levels and 

given a more accurate indication of expected costs and of which risks were most 

significant.

Capitol Dome’s Restoration 

Estimate
 

Page 22 GAO-14-333 Capitol Complex Cost Estimating

originated more than 15 years ago. By not having well documented 

records of management briefings over the life of the project, AOC risks 

loss of continuity in its oversight.

Considering the accuracy characteristic, we determined that the estimate 

partially met leading practices. We found, for example, that the estimating 

software and database used to construct the estimate included standard 

information, such as costs for labor, materials, and equipment. However,

AOC did not consider the actual cost of previously completed restoration 

phases in updates to its estimate for the phase II work. While AOC used 

information on the price it paid for certain items in the phase I restoration 

work that are also part of the phase II project, it did not determine the 

contractor’s actual cost to perform the work. AOC officials said that 

having information on actual contractor costs for items may be of limited 

usefulness because market conditions and other factors determine what 

contractors bid and AOC ultimately pays. However, not having 

information on actual costs makes it difficult for AOC to assess the 

difference between the price it paid and its contractors’ costs to determine 

the estimate’s reasonableness.

For the credibility characteristic, we determined that the estimate 

minimally met leading practices. We found, in contrast to the approach it 

took in developing the Cannon Building renewal estimate, that AOC did 

not conduct a risk and uncertainty analysis of the Capitol Dome 

restoration estimate. While AOC officials told us they have not conducted 

a quantitative-risk and uncertainty analysis of the estimate, they said they 

have taken steps to qualitatively assess and mitigate project risks. For 

example, AOC structured the phase II contract solicitation to have 

contractors include a base bid (phase IIA) and pre-priced options for later 

stages (phases IIB and IIC) of the work. According to AOC officials, by 

structuring the contract this way, AOC is protected from price escalations 

affecting the future phases. In addition, AOC established unit prices and 

quantity allowances for some restoration tasks that are of indefinite 

quantity, such as repairing cracks. According to AOC officials, this will 

help to control project costs because, while their quantity estimates may 

be imprecise, knowing the unit prices associated with the work should 

mitigate some cost risk. While these actions are encouraging, they are 

not documented within the context of a quantitative-risk and uncertainty 

analysis. As a result, we do not know how these actions relate to other 

risk mitigation efforts that may have been considered and why AOC 

chose these actions over other efforts. Moreover, not having a 

quantitative-risk and uncertainty analysis precludes establishing a level of 

confidence associated with achieving the estimated cost and limits AOC 
 

Page 23 GAO-14-333 Capitol Complex Cost Estimating

management’s ability to determine an appropriate level of contingency 

reserves that may be necessary to address risks that AOC has identified.

AOC project’s cost-estimating guidance policy and two resulting project 

estimates that we reviewed may not be fully reliable because they 

incorporated some, but not all, leading practices in cost estimating. 

Because AOC’s project cost estimates inform Congress’s funding 

decisions and affect AOC’s ability to effectively allocate resources across 

competing projects in its capital program, there is a risk that funding 

decisions and resource allocations could be made based on information 

that is not reliable. We recognize that incorporating GAO’s costestimating best practices into AOC’s cost-estimating policy and guidance 

may involve additional costs—such as for conducting a risk and 

uncertainty analysis for projects and conveying the confidence level of the 

estimate to Congress and AOC managers. However, without investing in 

these practices, Congress risks making funding decisions and AOC 

management risks making resource allocation decisions without the 

benefit that a robust analysis of levels of risk, uncertainty, and confidence 

provide decision makers.

To improve the Architect of the Capitol’s project-cost-estimating process, 

enhance the transparency of its related process, and allow for more 

informed decision making related to projects’ costs, we recommend that 

the Architect of the Capitol take the following two actions, to the extent 

that the benefits exceed the costs:

• incorporate leading practices we identified as lacking for cost 

estimating in the AOC’s cost-estimating guidance and policies, and

• for ongoing and future projects, submit the confidence level derived 

from risk and uncertainty analyses along with budget documentation 

to appropriate congressional decision makers, so that Congress is 

aware of the range of likely costs and AOC’s associated confidence 

levels.

We provided a draft of this report to the Architect of the Capitol for review 

and comment. AOC agreed with our recommendations and provided us 

with additional context and information on specific actions that the AOC

has taken or intends to take to more fully address our recommendations. 

For example, AOC said that it planned to revise its policies and 

procedures to require quantitative-risk and uncertainty analysis be done, 

as specified in the Cost Guide, for high-dollar-value projects prior to 

Conclusions

Recommendations

Agency Comments 

and Our Evaluation
 

Page 24 GAO-14-333 Capitol Complex Cost Estimating

requesting construction funding. In addition, AOC said that it would 

explore the most effective approach for communicating to congressional 

decision makers the confidence level derived from risk and uncertainty 

analyses along with budget documentation. We made no changes to our 

draft based upon AOC’s comments. AOC’s comments are reprinted in 

appendix IV, followed by our response to AOC’s detailed comments.

We are sending copies of this report to appropriate congressional 

committees and the Architect of the Capitol. In addition, the report is 

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) 512-2834 or stjamesl@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 key contributions to this 

report are listed in appendix V.

Lorelei St. James

Director, Physical Infrastructure Issues.
Appendix I: The Leading Practices for 

Developing High-Quality Cost Estimates and 

Associated Tasks

Page 25 GAO-14-333 Capitol Complex Cost Estimating

Step Leading practice Associated task

1 Define estimate’s purpose • Determine estimate’s purpose, required level of detail, and overall scope;

• Determine who will receive the estimate. 

2 Develop estimating plan • Determine the cost-estimating team and develop its master schedule;

• Determine who will do the independent cost estimate;

• Outline the cost-estimating approach;

• Develop the estimate’s timeline. 

3 Define program characteristics • In a technical baseline-description document, identify the program’s purpose and its 

system and performance characteristics and all system configurations;

• Any technology implications;

• Its program acquisition schedule and acquisition strategy;

• Its relationship to other existing systems, including predecessor or similar legacy 

systems;

• Support (manpower, training, etc.) and security needs and risk items;

• System quantities for development, test, and production;

• Deployment and maintenance plans. 

4 Determine estimating structure • Define a work breakdown structure (WBS) and describe each element in a WBS 

dictionary (a major automated-information system may have only a cost element 

structure); 

• Choose the best estimating method for each WBS element;

• Identify potential cross-checks for likely cost and schedule drivers;

• Develop a cost-estimating checklist. 

5 Identify ground rules and 

assumptions

• Clearly define what the estimate includes and excludes;

• Identify global and program-specific assumptions, such as the estimate’s base year, 

including time phasing and life cycle;

• Identify program schedule information by phase and program acquisition strategy;

• Identify any schedule or budget constraints, inflation assumptions, and travel costs;

• Specify equipment the government is to furnish as well as the use of existing facilities 

or new modification or development;

• Identify prime contractor and major subcontractors;

• Determine technology refresh cycles, technology assumptions, and new technology to 

be developed;

• Define commonality with legacy systems and assumed heritage savings;

• Describe effects of new ways of doing business. 

Appendix I: The Leading Practices for 

Developing High-Quality Cost Estimates and 

Associated Tasks
Appendix I: The Leading Practices for 

Developing High-Quality Cost Estimates and 

Associated Tasks

Page 26 GAO-14-333 Capitol Complex Cost Estimating

Step Leading practice Associated task

6 Obtain data • Create a data collection plan with emphasis on collecting current and relevant 

technical, programmatic, cost, and risk data;

• Investigate possible data sources;

• Collect data and normalize them for cost accounting, inflation, learning, and quantity 

adjustments;

• Analyze the data for cost drivers, trends, and outliers and compare results against 

rules of thumb and standard factors derived from historical data;

• Interview data sources and document all pertinent information, including an 

assessment of data reliability and accuracy;

• Store data for future estimates. 

7 Develop point estimate and 

compare it to an independent cost 

estimate

• Develop the cost model, estimating each WBS element, using the best methodology 

from the data collected, and including all estimating assumptions;

• Express costs in constant year dollars;

• Time-phase the results by spreading costs in the years they are expected to occur, 

based on the program schedule;

• Sum the WBS elements to develop the overall point estimate;

• Validate the estimate by looking for errors like double counting and omitted costs;

• Compare estimate against the independent cost estimate and examine where and why 

there are differences;

• Perform cross-checks on cost drivers to see if results are similar;

• Update the model as more data become available or as changes occur and compare 

results against previous estimates. 

8 Conduct sensitivity analysis • Test the sensitivity of cost elements to changes in estimating input values and key 

assumptions;

• Identify effects on the overall estimate of changing the program schedule or quantities;

• Determine which assumptions are key cost drivers and which cost elements are 

affected most by changes. 

9 Conduct risk and uncertainty 

analysis

• Determine and discuss with technical experts the level of cost, schedule, and technical 

risk associated with each WBS element;

• Analyze each risk for its severity and probability;

• Develop minimum, most likely, and maximum ranges for each risk element;

• Determine type of risk distributions and reason for their use;

• Ensure that risks are correlated;

• Use an acceptable statistical analysis method (e.g., Monte Carlo simulation) to 

develop a confidence interval around the point estimate;

• Identify the confidence level of the point estimate;

• Identify the amount of contingency funding and add this to the point estimate to 

determine the risk-adjusted cost estimate;

• Recommend that the project or program office develop a risk management plan to 

track and mitigate risks. 
Appendix I: The Leading Practices for 

Developing High-Quality Cost Estimates and 

Associated Tasks

Page 27 GAO-14-333 Capitol Complex Cost Estimating

Step Leading practice Associated task

10 Document the estimate • Document all steps used to develop the estimate so that a cost analyst unfamiliar with 

the program can recreate it quickly and produce the same result;

• Document the purpose of the estimate, the team that prepared it, and who approved 

the estimate and on what date;

• Describe the program, its schedule, and the technical baseline used to create the 

estimate;

• Present the program’s time-phased life-cycle cost;

• Discuss all ground rules and assumptions;

• Include auditable and traceable data sources for each cost element and document for 

all data sources how the data were normalized;

• Describe in detail the estimating methodology and rationale used to derive each WBS 

element’s cost (prefer more detail over less);

• Describe the results of the risk, uncertainty, and sensitivity analyses and whether any 

contingency funds were identified;

• Document how the estimate compares to the funding profile;

• Track how this estimate compares to any previous estimates. 

11 Present estimate to management 

for approval

• Develop a briefing that presents the documented life-cycle cost estimate;

• Include an explanation of the technical and programmatic baseline and any 

uncertainties;

• Compare the estimate to an independent cost estimate (ICE) and explain any 

differences;

• Compare the estimate (life-cycle cost estimate (LCCE)) or independent cost estimate 

to the budget with enough detail to easily defend it by showing how it is accurate, 

complete, and high in quality;

• Focus in a logical manner on the largest cost elements and cost drivers;

• Make the content clear and complete so that those who are unfamiliar with it can 

easily comprehend the competence that underlies the estimate results;

• Make backup slides available for more probing questions;

• Act on and document feedback from management;

• Request acceptance of the estimate. 

12 Update the estimate to reflect 

actual costs and changes

• Update the estimate to reflect changes in technical or program assumptions or keep it 

current as the program passes through new phases or milestones;

• Replace estimates with EVM, and independent estimate at completion (EAC) from the 

integrated EVM system;

• Report progress on meeting cost and schedule estimates;

• Perform a post mortem and document lessons learned for elements whose actual 

costs or schedules differ from the estimate;

• Document all changes to the program and how they affect the cost estimate. 

Source: GAO, DHS, DOD, DOE, NASA, SCEA, and industry.
Appendix II: Objectives, Scope, and 

Methodology

Page 28 GAO-14-333 Capitol Complex Cost Estimating

The House Appropriations Committee report accompanying the fiscal 

year 2014 Legislative Branch Appropriations Bill (H.R. 2792) mandated 

that we review the Architect of the Capitol’s (AOC) cost estimating 

methodology to ensure that AOC is accounting for all of the variables that 

should contribute to project cost estimates.1 This report addresses the 

extent to which AOC’s policies and guidance for developing cost 

estimates conform to leading practices identified in GAO’s Cost 

Estimating and Assessment Guide2

To determine the extent to which AOC’s policies and guidance comply 

with leading practices for cost estimating and provide a reliable basis to 

support funding and program decisions, we compared AOC’s documents

to leading practices set forth in GAO’s Cost Estimating and Assessment 

Guide.

and provide a reliable basis to 

support funding and capital program decisions. This report also examines 

whether the estimates for the Capitol Dome and the Cannon Building 

projects reflect leading practices.

3

 

1

H.R. Rep. No. 113-173, at 11 (2013).

The Cost Guide identifies 12 leading practices that represent 

work across the federal government and are the basis for a high-quality, 

reliable cost estimate. An estimate created using the leading practices 

exhibits four broad characteristics: it is accurate, well documented, 

credible, and comprehensive. That is, each characteristic is associated 

with a specific set of leading practices. In turn, each leading practice is 

made up of a number of specific tasks. (See app, I for a listing of the 

tasks that make up each of the 12 leading practices.) When the tasks 

associated with the leading practices that define a characteristic are 

mostly or completely satisfied, we consider the characteristic to be 

“substantially” or “fully” met. When all four characteristics are at least 

2

GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009). 

3

GAO-09-3SP. 

Appendix II: Objectives, Scope, and 

Methodology
Appendix II: Objectives, Scope, and 

Methodology

Page 29 GAO-14-333 Capitol Complex Cost Estimating

“substantially met”—we consider a cost estimate to be reliable.4

In reference to our examination of the estimates for the Capitol Dome and 

Cannon Building projects, we selected these projects based on their 

significance to the Capitol Complex, comparatively high costs, and public 

visibility. In addition, our review of the Cannon Building estimate is 

responsive to a mandate in the House Appropriations Committee report 

accompanying the fiscal year 2010 Legislative Branch Appropriations Bill 

(H.R. 2918) requiring us to monitor the progress of the project.

We 

shared our analysis with AOC officials to review, comment, and provide 

additional information, and we adjusted our analysis where appropriate.

5

We conducted our work from September 2013 to March 2014 in 

accordance with all sections of GAO’s Quality Assurance Framework that 

are relevant to our objectives. The framework requires that we plan and 

We 

selected versions of the estimates to review that had the most complete 

information for our assessments. We assessed the reliability of data used 

in developing the estimates and found them to be sufficiently reliable for 

the purposes of this report. For example, while some source data were

unavailable to us, we were able to assess AOC’s process for building its 

estimates with the data and check for errors. We also interviewed AOC’s

staff and its technical consultant about these projects and observed 

existing conditions at the Cannon Building and Capitol Dome. While our 

review of these projects’ cost estimates provides key insights and 

illustrates products of AOC’s cost-estimating policies and guidance, the 

results of our review should not be used to make generalizations about all 

AOC project-cost estimates. We shared our analysis with AOC officials to 

review, comment, and provide additional information, and we adjusted our 

analysis where appropriate.

 

4

We established five descriptions for our assessments of leading practices and cost 

estimate characteristics: Fully Meets, Substantially Meets, Partially Meets, Minimally 

Meets, and Does Not Meet. We consider a leading practice to be fully met when the 

associated tasks are completely satisfied; substantially met when a large portion of the 

associated tasks are satisfied; partially met when about half of the associated tasks are 

satisfied; minimally met when a small portion of the associated tasks are satisfied; and not 

met when none of the associated tasks are satisfied. Our assessment method weights 

each leading practice equally and bases the assessment of each characteristic on the 

average score of underlying leading practices. We assign each description a numerical 

value (5 for Fully Meets to 1 for Does Not Meet) and round scores to the higher numerical 

value (i.e. a score of 4.5 would round up to 5).

5

H. R. Rep. No. 111-160, at 21 (2009).
Appendix II: Objectives, Scope, and 

Methodology

Page 30 GAO-14-333 Capitol Complex Cost Estimating

perform the engagement to obtain sufficient and appropriate evidence to 

meet our stated objectives and to discuss any limitations in our work. We 

believe that the information and data obtained, and the analysis 

conducted, provide a reasonable basis for any findings and conclusions in 

this product.
Appendix III: GAO’s Summary Assessments of 

AOC’s Project Cost Estimates for the Cannon 

Building’s Renewal and Capitol Dome’s 

Restoration

Page 31 GAO-14-333 Capitol Complex Cost Estimating

GAO 

assessment Estimating leading practice characteristic and rationale for assessment 

Comprehensive

The cost estimate should include both government and contractor costs of the program over its full life cycle, from 

inception of the program through design, development, deployment, operation and maintenance, to retirement of the 

program. It should also completely define the program, reflect the current schedule, and be technically reasonable. 

Comprehensive cost estimates should be structured in sufficient detail to ensure that cost elements are neither 

omitted nor double counted. Specifically, the cost estimate should be based on a product-oriented work breakdown 

structure (WBS) that allows a program to track cost and schedule by defined deliverables, such as hardware or 

software components. Finally, where information is limited and judgments must be made, the cost estimate should 

document all cost-influencing ground rules and assumptions. 

◕

The Cannon Building cost estimate did not include all life cycle costs as AOC guidance did not require these life 

cycle costs to be identified. The estimate tracked well with the work required, as it had a WBS structure consistent 

with this type of effort, and clearly laid out and appeared to update ground rules and assumptions based on evolving 

understanding of the scope of work.

◕ The Capitol Dome cost estimate covers the construction phase of the dome’s restoration. The cost estimate relies on 

specifications and drawings that exist in separate files. The cost estimate uses a standard WBS structure but does 

not include the underlying data. AOC submitted an extract of the data for our review. While the specifications include 

ground rules and assumptions, the cost estimate does not specify them.

Well documented

A good cost estimate—while taking the form of a single number—is supported by detailed documentation that 

describes how it was derived and how the expected funding will be spent in order to achieve a given objective. 

Therefore, the documentation should capture in writing such things as the source data used, the calculations 

performed and their results, and the estimating methodology used to derive each WBS element’s cost. Moreover, this 

information should be captured in such a way that the data used to derive the estimate can be traced back to, and 

verified against, their sources so that the estimate can be easily replicated and updated. The documentation should 

also discuss the technical baseline description and how the data were normalized. Finally, the documentation should 

include evidence that the cost estimate was reviewed and accepted by management.

◕ The Cannon Building cost estimate documentation did not provide source data. It did provide a reasonable 

explanation for how the cost estimates were prepared, what type of data were used, and the basic estimating 

methodologies indicating some step by step processes. The documentation provided consisted of tables of unit 

values, quantities, and extended values. While extended costs were identified, it was difficult to follow the roll-up of 

these costs. Without a copy of or access to the cost model, we were unable to verify the accuracy of escalation 

calculations and we could not trace all of the logic from the source data to the resulting estimate. The calculations 

and changes to the baseline were not well documented but subsequent data and explanations highlighted the 

process for the changes. Additionally, soft costs and contingencies, comprising a substantial portion of total program 

costs, were only superficially addressed. There was evidence of management approval of the estimate.

◕ The Capitol Dome cost estimate captures all source documents used. The cost estimate relies on a WBS and shows 

how the calculations were performed. A cost analyst unfamiliar with the program could develop the cost estimate, 

although in places it is not clear. The cost estimate has a brief reference to the source documents used. Costs are 

presented in constant-year and then-year dollars.

Appendix III: GAO’s Summary Assessments 

of AOC’s Project Cost Estimates for the 

Cannon Building’s Renewal and Capitol 

Dome’s Restoration 
Appendix III: GAO’s Summary Assessments of 

AOC’s Project Cost Estimates for the Cannon 

Building’s Renewal and Capitol Dome’s 

Restoration

Page 32 GAO-14-333 Capitol Complex Cost Estimating

GAO 

assessment Estimating leading practice characteristic and rationale for assessment 

Accurate

The cost estimate should provide for results that are unbiased, and it should not be overly conservative or optimistic. 

An estimate is accurate when it is based on an assessment of most likely costs, adjusted properly for inflation, and 

contains few, if any, minor mistakes. In addition, a cost estimate should be updated regularly to reflect significant 

changes in the program—such as when schedules or other assumptions change—and actual costs, so that it is 

always reflecting current status. During the update process, variances between planned and actual costs should be 

documented, explained, and reviewed. Among other things, the estimate should be grounded in a historical record of 

cost estimating and actual experiences on other comparable programs.

◕ The Cannon Building cost estimate included an uncertainty analysis indicating what confidence level the budget fell 

within, which was greater than 90 percent. Additionally, in the absence of having the cost model used to prepare the 

estimate, we were only able to validate the accuracy of a very small sample of WBS elements. Furthermore, while 

the estimate documentation identified inflation adjustments, because of missing calculation and conversion factors, 

we were unable to determine if the estimate has been adjusted properly for inflation. However, the documentation did 

provide a discussion of what and how the inflation adjustments were applied.

◑ The Capitol Dome cost estimate did not include a risk and uncertainty analysis indicating what confidence level for 

the estimate the budget was set at. The estimate is shown in constant-year and then-year dollars using indices for 

inflation. The indices used to adjust for inflation appear to be out-of-date. The estimate has few errors. AOC updated 

its cost estimate prior to beginning the project, but once the project began, AOC did not update the estimate. AOC 

did not document variances between planned and actual costs. AOC relied on historical records and on an industry 

database to support its estimate. The estimate uses an engineering build-up throughout, which appears appropriate 

for this project.

Credible

The cost estimate should discuss any limitations of the analysis because of uncertainty or biases surrounding data or 

assumptions. Major assumptions should be varied, and other outcomes recomputed to determine how sensitive they 

are to changes in the assumptions. Risk and uncertainty analysis should be performed to determine the level of risk 

associated with the estimate. Further, the estimate’s cost drivers should be crosschecked, and an independent cost 

estimate conducted by a group outside the acquiring organization should be developed to determine whether other 

estimating methods produce similar results.

◑ The Cannon Building cost estimate includes analyses of sensitivity, risk, and uncertainty. However, the sensitivity 

analysis was performed after the fact and was not used to inform the budget or provided for management 

consideration of risk prior to project start. AOC’s risk and uncertainty analysis indicates that the budget for the project 

is set above the 90% confidence level, which may be unreasonably high. AOC has received multiple estimates from 

different sources (architect, construction manager, pre-construction contractor) as a cross-check for reasonableness. 

While these estimates are not necessarily outside the AOC program office’s influence, they do appear to represent 

independent estimates based on each company’s interpretation of the project’s requirements and helped to validate 

the reliability of the estimates.

◔ The Capitol Dome cost estimate does not include a sensitivity, risk, and uncertainty analysis. AOC did not provide 

documented reasons explaining how the actual budgeted contingency amounts for unforeseen costs were 

developed. To mitigate risk, AOC negotiated unit costs to account for uncertainties in effort, such as the number of 

inches of stitching that would be needed to repair cracks. AOC does not appear to cross-check major cost elements, 

but AOC requested and obtained an independent cost estimate. AOC subsequently compared the point estimate and 

the independent cost estimate, and the two numbers were a close match.

Source: GAO analysis of AOC documents.

●= Fully Meets: AOC provided complete evidence that satisfies the associated tasks of the leading 

practices

◕=Substantially Meets: AOC provided evidence that satisfies a large portion of the associated tasks 

of the leading practices

◑=Partially Meets: AOC provided evidence that satisfies about half of the associated tasks of the 

leading practices
Appendix III: GAO’s Summary Assessments of 

AOC’s Project Cost Estimates for the Cannon 

Building’s Renewal and Capitol Dome’s 

Restoration

Page 33 GAO-14-333 Capitol Complex Cost Estimating

◔=Minimally Meets: AOC provided evidence that satisfies a small portion of the associated tasks of 

the leading practices

○= Does Not Meet: AOC provided no evidence that satisfies the associated tasks of the leading 

practices
Appendix IV: Comments from the Architect of 

the Capitol

Page 34 GAO-14-333 Capitol Complex Cost Estimating

Appendix IV: Comments from the Architect of 

the Capitol

Note: GAO’s comments 

supplementing those in 

the report’s text appear at 

the end of this appendix.
Appendix IV: Comments from the Architect of 

the Capitol

Page 35 GAO-14-333 Capitol Complex Cost Estimating

See comment 1.

See comment 2.
Appendix IV: Comments from the Architect of 

the Capitol

Page 36 GAO-14-333 Capitol Complex Cost Estimating
Appendix IV: Comments from the Architect of 

the Capitol

Page 37 GAO-14-333 Capitol Complex Cost Estimating

See comment 4.

See comment 3.
Appendix IV: Comments from the Architect of 

the Capitol

Page 38 GAO-14-333 Capitol Complex Cost Estimating

See comment 6.

See comment 5.

See comment 4.
Appendix IV: Comments from the Architect of 

the Capitol

Page 39 GAO-14-333 Capitol Complex Cost Estimating

See comment 8.

See comment 8.

See comment 7.
Appendix IV: Comments from the Architect of 

the Capitol

Page 40 GAO-14-333 Capitol Complex Cost Estimating

See comment 9.
Appendix IV: Comments from 

the Architect of the Capitol

Page 41 GAO-14-333 Capitol Complex Cost Estima

The following are GAO’s comments on the Architect of the Capitol’s letter 

dated March 14, 2014.

1. We continue to believe that a quantitative risk and uncertainty 

analysis enables more effective oversight than can be obtained by 

taking a qualitative approach. A quantitative risk and uncertainty 

analysis conveys the confidence level in achieving the most likely cost 

and provides actionable information about cost, schedule, and 

technical risks that cannot be obtained qualitatively.

2. While AOC’s contractors act independently, AOC’s Project 

Management Division is responsible for the estimates prepared via 

contract, and AOC’s Cost Estimating Group is responsible for 

reviewing them. Because AOC’s Project Management Division and 

Cost Estimating Group staff are part of the same Planning and Project 

Management organization, the Cost Estimating Group staff could be 

biased because of organizational influences and unable to provide a 

fully objective review of costs to the Project Management Division. 

3. While our leading practices do not specify target confidence levels, 

experts we consulted with in developing our leading practices agreed 

that program cost estimates should be budgeted to at least the 55 

percent confidence level and potentially as high as 80 percent. While 

AOC has good reasons for its interest in maintaining the project’s 

budget at a high confidence level, we believe that the confidence level 

for the project’s budget—exceeding 90 percent—may be excessive. 

4. AOC identified 60 risks to the project and modeled them in aggregate, 

as opposed to individually, in conducting its quantitative risk and 

uncertainty analysis. Modeling the aggregated risks precludes AOC 

from identifying relationships among risk elements and determining 

which risks have the greatest influence on project costs. We continue 

to believe that modeling the risks in aggregate likely contributes to the 

overly narrow range of estimated costs over the confidence levels, 

and can overstate the effect of the risks.

5. Our leading practices indicate that an estimate’s documentation 

should be detailed enough so that the derivation of each cost element 

can be traced to all sources allowing the estimate to be easily 

replicated and updated. Because some information was not readily 

available in documents maintained by AOC, we were unable to 

determine if the estimate has been adjusted properly for inflation. 

6. AOC has taken positive steps in conducting a life-cycle cost analysis 

that considered fixed costs and ongoing maintenance costs to inform 

GAO Comments
Appendix IV: Comments from 

the Architect of the Capitol

Page 42 GAO-14-333 Capitol Complex Cost Estima

the AOC’s selection of mechanical systems for heating and cooling 

the Cannon Building. However, AOC did not conduct life-cycle 

analyses for other components of the project, such as the building’s 

roof and alarm system. This precludes AOC from capturing the total 

cost of the project and evaluating design alternatives on a total-cost 

basis. 

7. AOC takes positive steps to qualitatively identify risks and uncertainty 

and assess sensitivity. While this analysis is useful in setting 

contingencies and managing risks during construction, a quantitative

risk and uncertainty analysis enables more effective oversight 

because it conveys the confidence level in achieving the most likely 

cost and provides actionable information about cost, schedule, and 

technical risks that cannot be obtained qualitatively. 

8. While AOC has used some information from completed phases of the 

Capitol Dome’s restoration project to inform development of the 

estimate for later phases, not having information on actual costs 

makes it difficult for AOC to assess the difference between the price it 

paid and its contractors’ costs to determine the estimate’s 

reasonableness. 

9. Our leading practices indicate that an estimate’s documentation 

should be detailed enough so that the derivation of each cost element 

can be traced to all sources allowing the estimate to be easily 

replicated and updated. Because some information was out-of-date at 

the time of our review, we were unable to determine if the estimate 

had the proper escalation adjustments. 
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 43 GAO-14-333 Capitol Complex Cost Estimating

Lorelei St. James, (202) 512-2834 or stjamesl@gao.gov

In addition to the contact named above Michael Armes, Assistant 

Director; Karen Richey, Assistant Director; George Depaoli, Analyst-inCharge; Laura Erion; Emile Ettedgui; Colin Fallon; Geoffrey Hamilton; 

James Manzo; Faye Morrison; and Vanessa Welker made key 

contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(544199)
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