FEDERAL REAL 

PROPERTY

GSA Should Clarify 

Savings Goals for the 

National Broker 

Contract Program

Report to Congressional Requesters

October 2013

GAO-14-14

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-14, a report to 

congressional requesters 

October 2013

FEDERAL REAL PROPERTY 

GSA Should Clarify Savings Goals for the National 

Broker Contract Program 

Why GAO Did This Study

For fiscal year 2013, GSA expected to 

lease approximately 197 million square 

feet at a cost of about $5.2 billion. 

Since 2005, GSA has acquired some 

leased space using its NBC program to 

enlist commercial real estate 

brokerage firms to negotiate with 

building owners on behalf of the 

government. In 2012, GSA relied on 

this contract to replace approximately

33 percent of its expiring leases. 

GAO was asked to review GSA’s NBC 

program. This report examines (1) 

NBC’s program goals and the extent to 

which they are being realized and (2)

the changes GSA has made to the 

program and what challenges and 

suggestions for improvement, if any, 

key stakeholders identified. GAO 

reviewed NBC contract documentation, 

agency documents, relevant legislation 

and regulations, and available data on 

leasing tasks assigned to brokers. 

GAO interviewed officials from GSA 

headquarters, all 11 GSA regions, and 

representatives of all 4 brokers 

currently participating in the program. 

What GAO Recommends

GAO recommends that GSA ensure 

the program’s goals are linked to cost 

savings achieved through the use of 

NBC brokers, and develop and 

implement a means of evaluating and 

reporting results. GSA concurred with 

the recommendation.

What GAO Found

While the General Services Administration (GSA) has used the National Broker 

Contract (NBC) program to assist with the agency’s lease portfolio, it is unclear 

whether the program has resulted in the rental rate cost savings that GSA 

anticipated when proposing the program. GSA officials have stated that brokers 

should be able to obtain lower rental rates than in-house staff because brokers

have greater market expertise and in addition are able to credit a portion of the 

broker’s commission to the rental rate. In 2012, when GSA attempted to compare 

rental rates negotiated by brokers with those negotiated by in-house staff, the

agency not only found little difference between the two, but also stated that the 

data were insufficient to conduct a meaningful comparison. In April 2013, GSA 

began requiring the use of a different market rent data report —“Bullseye”— 

which includes market information, analysis, and insight regarding the local 

submarket. Officials said this new data would improve their ability to compare 

rental rates negotiated by brokers to market rental rates, but will likely not allow 

officials to determine whether brokers are negotiating better deals than in-house 

staff. Beginning in fiscal year 2013, GSA also deemphasized previous annual

goals for broker use and began identifying and assigning leases to brokers based 

on where agency officials believe the brokers provide the greatest value. 

GSA’s goals and metrics for evaluating the NBC program have not been linked to 

the anticipated cost savings in rental rates. As a result, GSA has no means of 

evaluating and reporting on this aspect of the program and the value of the NBC 

program in terms of cost savings continues to be unclear. Clarifying goals and 

linking them to cost savings would also serve as a way to be transparent with 

Congress and other stakeholders about the program’s purpose and how GSA 

plans to monitor and achieve its objectives. Clear, linked goals are especially 

important given that GSA is planning to seek a third generation of broker 

contracts in 2015.

Officials from all 11 GSA regional offices and representatives from all 4 broker 

firms identified challenges and made suggestions to improve the program. Two 

areas frequently cited are: the broker evaluation process and greater flexibility

using brokers. 

• Broker evaluation process: Both GSA regional officials and brokers 

expressed dissatisfaction with the current broker performance evaluation 

system and brokers suggested additional guidance and training would 

help. Both groups also suggested that GSA officials be allowed to use 

region-specific performance evaluation data to award tasks.

• Greater flexibility using brokers: Regional officials suggested that greater 

flexibility in applying the NBC program would allow them to make better 

use of brokers. Regional officials described a preferred “menu of 

services” that would allow them to use the brokers more selectively for 

the specific tasks where GSA wants assistance as opposed to working 

with the broker throughout the entire lease procurement. 

GSA has begun identifying potential changes to the structure and administration 

of the NBC program as the agency develops a strategy for the third generation of 

NBCs. For example, officials told GAO they are examining alternatives to the 

current commission and rent structure.

View GAO-14-14. For more information, 

contact David Wise at (202) 512-2834 or 

wised@gao.gov.
Page i GAO-14-14 Federal Real Property

Letter 1 

Background 3

Achievement of Goals Is Mixed, and Cost Savings from the NBC 

Program Are Unclear 6

GSA Has Made Changes to the NBC Program, and Stakeholders 

Have Suggested Additional Actions That Can Improve the 

Program 13

Conclusion 22

Recommendation for Executive Action 23

Agency Comments 23

Appendix I Objectives, Scope, and Methodology 25

Appendix II Comments from General Services Administration 27

Appendix III GAO Contact and Staff Acknowledgments 29

Figures

Figure 1: Description of Typical Steps for GSA’s Real Property 

Lease Acquisition 6

Figure 2: GSA Data on Cost of Leased Space Relative to Industry 

Market Rates, 2006 to 2012 7

Figure 3: Comparison of One Broker Firm’s 2012 Single Regional 

and Overall National Broker Performance Evaluation 

Scores 18

Contents 
Page ii GAO-14-14 Federal Real Property

Abbreviations

COTR Contracting Officer’s Technical Representative

FAR Federal Acquisition Regulation 

GSA General Services Administration

IG Inspector General 

MSA metropolitan statistical area

NBC National Broker Contract

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Page 1 GAO-14-14 Federal Real Property

441 G St. N.W.

Washington, DC 20548

October 31, 2013

The Honorable Thomas R. Carper

Chairman

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Claire McCaskill

Chairman

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate

As the federal government’s principal landlord, the General Services 

Administration (GSA) is responsible for acquiring and managing a 

significant amount of leased space for federal agency customers.1 GSA 

reports that for fiscal year 2013, the agency expected to lease 

approximately 197-million square feet at an annual cost of about $5.2 

billion. In some cases, GSA uses its National Broker Contract (NBC) to 

enlist commercial real-estate brokerage firms (i.e., brokers) to negotiate 

with building owners on behalf of the federal government and acquire 

leased space. In 2012, it relied on this contract to acquire approximately 

33 percent of its expiring leases.2

The NBC program began in 2004, when GSA awarded contracts to four 

private broker firms that have a nationwide presence, and GSA began 

enlisting these firms to negotiate with building owners on behalf of the 

federal government in 2005. The agency expected to realize a range of 

benefits that would lower costs. The initial contracts expired in 2010, at 

which point GSA awarded four more contracts.3 Contracts were awarded 

for one year with four one-year extension options. This program is 

 

1 Some agencies have independent statutory authority, which authorizes them to acquire 

leased space. 

2 This percentage was calculated by GSA based on the average of leases expiring in 

fiscal years 2013, 2014, 2015, and 2016 minus non-commissionable leases, which include 

leases for things such as border stations, renewals and parking. 

3 GSA awarded contracts to CB Richard Ellis (CBRE); Jones Lang LaSalle, Inc. (JLL); 

Studley Inc.; and UGL Equis Corporation.

 
 

Page 2 GAO-14-14 Federal Real Property

different from many service contracts held by the government because 

GSA does not directly pay for broker services. Instead, brokers are 

compensated by commission—a percentage of the cost of the lease—

paid by building owners. Thus, Congress does not appropriate funds for 

the work conducted by brokers.4 Members of Congress have raised 

questions about why GSA chose to use contractors to acquire leases for 

GSA, rather than performing this service itself, the extent to which the 

program has resulted in benefits, and whether the brokers are providing 

the best value for the government. Furthermore, there are concerns that 

these brokers—whose commission is a percentage of the lease price—

may have an inherent conflict of interest in negotiating the best deal for 

the government.5 GSA intends to continue using private sector brokers 

and is currently developing the next generation of broker contracts with 

the intent to award the next round of contracts in fiscal year 2015. You 

asked us to review GSA’s NBC program. This report examines (1) NBC 

program goals and the extent to which they are being realized, and (2) 

the changes GSA has made to the program and what challenges and 

suggestions for improvement, if any, key stakeholders identified.

To meet these objectives, we analyzed GSA’s NBC contract 

documentation and reviewed available data on leasing tasks assigned to 

brokers. These data were available beginning in 2005, the first year after 

the contract was signed, through 2013. We analyzed GSA’s in-house and 

broker-negotiated rental rates, and discussed with GSA headquarters 

officials the methodology used and the limitations of their analysis and 

findings. In consultation with an economist and social science analyst at 

GAO, we determined that performing our own analysis would be limited 

by the same factors identified by GSA. We reviewed internal and external 

reports on the NBC program, which provided information about program 

outcomes. In addition, we obtained data from GSA on the NBC program 

including information on commissions and credits and on use of brokers. 

To determine the reliability of this data, we reviewed relevant 

documentation including internally published reports, and we interviewed 

agency officials about their processes for reviewing the data and ensuring 

their accuracy. We found the broker-related leasing data generally 

 

4 Building owners typically factor the cost of the commission into the rent charged to a 

tenant. Tenants indirectly pay the commission through their rental payments.

5 While this conflict is inherent to this type of commission based payment for services, it is 

typical in the commercial real estate industry.
 

Page 3 GAO-14-14 Federal Real Property

reliable for the purposes of this report. We interviewed GSA headquarters 

officials, officials from all 11 GSA regions concerning the NBC program, 

and individuals representing all four brokers currently part of NBC. We 

asked officials to identify challenges and suggestions that could help 

improve the program. Therefore, we could not always determine whether 

these challenges or suggestions were applicable in other regions or with 

other broker firms unless other officials brought them to our attention. We 

reviewed relevant legislation, regulations, prior GAO work, GSA 

guidance, and industry reports. We also identified GAO guidance on 

standards for internal controls—plans, methods, and procedures used to 

meet missions, goals, and objectives—that are key to helping agencies 

better achieve their missions and desired program results and assessed 

GSA’s efforts to set goals and objectives to achieve the desired results of 

the NBC program.6 We conducted this performance audit from October 

2012 to October 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. For more 

information on our scope and methodology, see appendix I.

GSA increased its use of brokers in the years prior to beginning the NBC. 

Before 1997, all leasing acquisition work was performed in-house. 

However, downsizing initiatives in the 1990s reduced GSA’s in-house 

capacity to acquire leases, and in 1997 GSA began to sign contracts with 

private broker firms to assist with its leasing portfolio. From 1997 to 2003, 

GSA had multiple, separate regional contracts for broker services, and 

GSA paid brokers a fee from appropriated funds in exchange for a variety 

of lease acquisition and other services. By 2003, approximately 20 

percent of the leasing work was being performed by brokers under the 

regional contracts, although the regional contracts were found to be 

administratively burdensome and inconsistent, because of variations in 

the contracts’ terms, conditions, and pricing structures. In 2003, GSA 

conducted a business analysis comparing the advantages, 

 

6 GAO, Internal Control: Standards for Internal Control in the Federal Government, 

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

Background 
 

Page 4 GAO-14-14 Federal Real Property

disadvantages, and costs of different types of contracting options on a 

national, zonal and local level.7

Based on this analysis, GSA concluded that the national contracts 

through the NBC program represented the best option available, and 

GSA awarded four contracts in October 2004, and contract performance 

began on April 1, 2005.8 GSA identified three expected savings from the 

NBC program: reduced rental rates, reduced administrative expenses and 

fees, and reduced personnel expenses. GSA officials believed that rental 

rates would be reduced as a result of a broker’s expert knowledge of the 

commercial real estate market, which would assist in negotiating lower 

rental rates. In addition, brokers agreed to forgo a portion of the 

commission they received—in the form of a commission credit reducing 

the government’s initial rental cost. GSA officials also stated that the 

national contract would reduce its administrative expenses because the 

previous regional contracts had differing terms, conditions, and pricing 

structures. In 2007,9 we recommended, among other things, that GSA 

quantify savings associated with reduced fees and administration 

expenses using the NBC. In response to our recommendation, GSA 

reported that it had identified cost savings as a result of moving from 

regional contracts to the NBC. Finally, GSA anticipated achieving further 

savings by hiring fewer realty specialists—the position responsible for 

handling leasing transactions—over time. GSA stated that, as a result of 

government downsizing, the number of in-house realty specialist staff had 

decreased from 811 in 1995 to 450 in 2003. GSA estimated that 

approximately 140 realty specialists were eligible to retire by the end of 

2005, and that the agency would need to hire approximately 300 

additional staff to handle the leasing workload. In our 2007 report, we 

found that, after implementing the NBC program, officials subsequently 

determined that there were additional tasks for realty specialist staff and 

no longer viewed the NBC program as a way to avoid hiring additional 

staff. According to GSA officials, in October 2012 they employed 

approximately 476 realty specialists.

 

7

 GSA, Business Analysis and Case for National Contracts for Brokerage Services in GSA 

(Aug. 25, 2003).

8 The starting date was delayed by bid protests.

9 GAO, GSA Leasing: Initial Implementation of the National Broker Services Contracts 

Demonstrates Need for Improvements, GAO-07-17 (Washington, D.C.: Jan. 31, 2007). 
 

Page 5 GAO-14-14 Federal Real Property

The NBC program differed from the previous regional contracts in three 

major ways. First, the contracts are national contracts, which means that 

while the program is implemented and used at the regional level by GSA 

regional officials, all regions are subject to the same contract language 

and rules. Second, unlike the previous contracts, wherein brokers were

paid for providing a variety of lease acquisition and other services to 

support GSA in acquiring leases, under the NBC program brokers are to 

perform the full lease acquisition, described in figure 110, as well as lease 

expansion11 or extension and market data collection. Third, under the 

NBC program, brokers are compensated through commissions paid by 

the lessor (the entity leasing space to GSA), and no payments are made 

directly by the government as was the case with the regional contracts.12

Although commission payments are factored by lessors into rental rates, 

these contracts for the NBC program were referred to by GSA as “no 

cost” contracts.13

 

10 GSA headquarters officials noted that requirements development is also considered 

part of the leasing process.

11 Use of brokers for expansions was included in NBC1, but removed from NBC2.

12 Compensating brokers in this way is typical in the commercial real estate industry as we 

reported in our initial review of the NBC program, GAO-07-17. 

13 The term “no cost” is somewhat of a misnomer, since there would be no enforceable 

contract without a tender of consideration by each party. In this case, the consideration 

benefiting the broker stems from its right to collect a share of the lease brokerage fees 

(commission payments) paid by prospective building owners.
 

Page 6 GAO-14-14 Federal Real Property

Figure 1: Description of Typical Steps for GSA’s Real Property Lease Acquisition

GSA’s stated goals for the program are to provide consistent, high-quality 

service nationwide to federal agencies that rely on GSA for lease 

acquisition services, as well as leverage the expertise of private-sector 

brokers. GSA set two more specific goals that the agency uses to 

determine the effectiveness of the NBC program. First, GSA determined 

that brokers should be accountable for achieving rental rates in line with 

the overall GSA goal. For example, in 2012 the overall goal for the 

leasing portfolio was to have rental rates at 9.5 percent below market 

average. Secondly, GSA set yearly goals for using brokers to acquire 

leased space. For example in 2012, GSA set the goal of 55 percent of 

expiring leases to be handled by brokers and 45 percent handled by GSA 

in-house.

GSA officials report that they are meeting their overall rental rate goals for 

the entire lease portfolio. As mentioned previously, GSA sets a yearly 

goal that overall rental rates for space leased from the private sector fall a 

certain percentage below the average industry-market rental rate. These 

rental rate goals do not differentiate between broker-negotiated leases 

Achievement of Goals 

Is Mixed, and Cost 

Savings from the NBC 

Program Are Unclear

Rental Rate Goals Met, but 

Unclear If Cost Savings 

Result from NBC Program
 

Page 7 GAO-14-14 Federal Real Property

and those done in-house. In fiscal year 2012, the goal was for rental rates 

to be 9.5 percent below market; GSA reported that its overall portfolio, 

which includes leases negotiated by both brokers and GSA staff, was on 

average 11.45 percent below market.14 From 2006 to date, GSA has, to 

varying degrees, reported that it exceeded its targets for paying lower 

than average rental rates. See figure 2 below. GSA headquarters officials 

have used this data as an indication of the NBC program’s success,

because they say the data show that the use of brokers has not driven up 

the rental rates. The officials also noted that they consider this an 

indication that brokers are not driving up lease rates to obtain higher 

commissions.

Figure 2: GSA Data on Cost of Leased Space Relative to Industry Market Rates, 

2006 to 2012

Note: The table above demonstrates the extent to which GSA exceeded its goals with respect to 

obtaining below market rates; thus, all percentages pertain to below market rates.

GSA is reportedly meeting its overall rental goals, but it is not clear that 

the NBC program results in rental rates lower than those negotiated by inhouse staff. In 2012, GSA officials attempted to determine if brokers 

negotiated lower rental rates than in-house staff using data from fiscal 

 

14GSA’s metric, used to compare the cost of leased space relative to industry market 

rates, is referred to as “LCRM—Lease Cost Relative to Market.” This measure compares 

GSA leasing rates to third-party data on rates paid by industry. 
 

Page 8 GAO-14-14 Federal Real Property

years 2011 and 2012. GSA’s own analysis did not show that brokers were 

negotiating significantly lower rental rates, and in fact overall it showed 

that brokers were negotiating rental rates that were similar to in-house 

staff.15 Furthermore, GSA officials cautioned us that they found this 

available data insufficient to determine if brokers were negotiating lower 

rental rates than in-house staff. Officials stated that the market rate data 

they were using were not specific enough to provide the level of detail 

necessary to discern the potential difference between the rates. They said 

that the current market data do not take into account the unique 

circumstances for each individual lease, and how these circumstances 

affect the rental rate. For example, a lease for a law enforcement agency, 

with higher security requirements and unique types of space (e.g., a 

shooting range), may have to be negotiated in the higher end of the 

market rate. However, the market rate data GSA has does not consider 

these requirements, and therefore may underestimate the value of the 

rental rate negotiated. The converse is also true, and it is possible that 

the market rate data can overstate a rental rate negotiated for an office 

space with few special requirements. The officials said that this makes 

comparison of negotiated rental rates difficult because even if both of the 

example leases were in the same market, one rate may be overvalued 

while the other is undervalued based on its unique requirements. This 

limitation notwithstanding, officials told us they still believe it is probable 

that brokers are negotiating lower rates.

In April 2013, GSA began requiring regional officials to use different 

market rental-rate data, which they expect will allow them to better 

compare the rental rates achieved by brokers to market rates in the 

future. For all broker projects greater than 10,000 square feet, regional 

officials are to obtain an in-house research report at the beginning of the 

leasing process referred to as “Bullseye.”

16 A Bullseye report is 

specifically tailored for each lease transaction and includes market 

information, analysis, and insight regarding the local submarket. The 

officials stated that the new reports would provide more specific data to 

 

15 GSA officials told us that commission credits were factored into the rental rate prior to 

the comparison with in-house negotiated rates. This means any commission credit given 

by a broker to GSA was taken into consideration and lowered the rental rate before it was 

compared to the in-house negotiated rental rates. 

16 These reports are already used for all leasing projects run by in-house staff. GSA 

regional officials are strongly encouraged to obtain a “Bullseye” report for projects above 

2,000 square feet.
 

Page 9 GAO-14-14 Federal Real Property

gauge the effectiveness of the broker program by comparing negotiated 

rental rates to the average for the submarket rate at the time of lease 

award. According to GSA officials, this new reporting will improve their 

comparison of rental rates negotiated by brokers to market rental rates 

but will probably still not allow them to definitively determine whether 

brokers are negotiating better deals than in-house staff. Because this 

effort is relatively new, data were not available at the time of our review to 

conduct further analysis. GSA headquarters officials noted the only way 

to ideally compare one lease to another is to acquire space for similar 

agencies, in the same market at the same time. In previous attempts by 

GSA to perform comparison analysis, GSA determined there were not 

enough data points with these characteristics to draw a meaningful 

conclusion. 

GSA initially set goals under NBC to have brokers conduct a high 

percentage of its leases, but beginning in fiscal year 2013 began 

deemphasizing the importance of annual percentage goals for broker 

usage. GSA set yearly goals based on the number of leases in the 

portfolio they determined could be handled by brokers and originally 

anticipated that 80 percent of the leasing workload would be assigned to 

brokers by fiscal year 2009. GSA lowered its broker usage goals for fiscal 

years 2011 and 2012 from 80 percent to 55 percent, and reported that in 

fiscal year 2012 it used brokers for 33 percent, or 220, of its expiring 

leases.17 GSA officials told us that they began lowering usage goals after 

2010 because more leases needed to be handled in-house for training 

purposes.

GSA officials told us they did not meet their broker usage goal for a 

variety of reasons. First, there are some leases with sensitivities such as 

internal conflict within an agency or the space is for a high-profile public 

official that they prefer to handle in-house. Second, some work is 

purposefully kept in-house for training purposes and to maintain staff

 

17 NBC1 goals were based on the average number of leases expiring annually over the 

next two fiscal years, minus non-commissionable leases. NBC2 goals were based on the 

average number of leases expiring annually over the next four fiscal years, minus noncommissionable leases. Fiscal year 2012 goals are based on the average of leases 

expiring in fiscal year 2013 through fiscal year 2016 minus non-commissionable leases for 

Transportation Security Administration or other leases located on-site at airports, Indian 

Health Services, Bureau of Indian Affairs, United States Postal Service, Border Stations, 

Renewals and Parking.

GSA Recently Changed 

Goals for Use of Brokers
 

Page 10 GAO-14-14 Federal Real Property

expertise. (This was also a reason the officials gave for why they began 

lowering usage goals in 2011.) Third, some GSA regional officials have 

not always found it advantageous to send leases to brokers because it 

can be time consuming. Specifically, officials from 6 of the 11 regions 

expressed concern that the NBC program is administratively burdensome 

and adds time to leasing procurement. Officials in one region stated that 

they essentially run “shadow procurements” for all NBC leases. That is, 

even though the broker is doing a significant amount of paperwork and 

finding lessors, the work completed by brokers must be closely monitored 

and reviewed to ensure that the process is in accordance with 

government standards.18 In addition, GSA officials are required to conduct 

performance evaluations at multiple points throughout the process, which 

officials told us is more time consuming than the evaluation process for 

in-house personnel.19

In 2010, the GSA Office of the Inspector General (IG) reported20 that due 

to a number of steps unique to NBC projects, there was an average of 1.6 

months added to the total time for the leasing process for the data in its

sample. Representatives from one broker firm we spoke with told us that 

NBC leases can take longer because GSA personnel can be less 

responsive on a broker-negotiated lease than leases they are personally 

negotiating. They noted that there are many approval points that the 

 

18 GSA headquarters officials told us that running a “shadow procurement” is a choice 

made by regional officials. These officials stated that this level of review is unnecessary 

and that the training requirements outlined in Section H.7 of the NBC2 contract, as well as 

the performance evaluation results of the firms clearly demonstrate a “shadow 

procurement” is unnecessary.

19 According to GSA headquarters officials, as with any performance-based contract, 

regional officials are required to evaluate contractors’ performance. They noted that if the 

contractor’s work is not correct upon initial submission, if properly documented, officials 

have the ability to request the removal of personnel. 

20 Office of Inspector General, General Services Administration, Audit of the PBS National 

Broker Contract, Report Number: A0700228/P/W/R11004 (Dec. 22, 2010). This report 

was originally issued as for Official Use Only, but was subsequently released to the public 

on July 3, 2012, pursuant to a Freedom of Information Act request. 
 

Page 11 GAO-14-14 Federal Real Property

broker cannot pass without approval from a GSA official and that 

significant time can elapse before GSA officials review the paperwork.21 

In fiscal year 2013, GSA deemphasized the importance of annual 

percentage goals for broker usage. Instead, GSA headquarters officials 

told us they reviewed each regional portfolio for fiscal year 2013 through 

fiscal year 2015 procurements and developed a list of leases that they 

determined should be sent to brokers. The list consists of leases that are 

viewed by the officials as having a “high to moderate value” and having 

the greatest potential for brokers to negotiate lower rental rates than inhouse personnel.22 GSA officials stated that they believe NBC provides 

the greatest value with large complex leases in large metropolitan areas, 

where brokers have a strong commission incentive. According to GSA 

headquarters officials, these areas have the highest potential for cost 

savings if brokers are able to negotiate lower rental rates as a result of 

private-sector market knowledge and negotiation skills. The officials told 

us that, after they compiled the list, regional officials were given an 

opportunity to comment, resulting in some changes, and that the resulting 

list of leases is what GSA plans to have brokers handle. For example, 

regional officials said that they removed some of the leases on the list 

because they had already been sent to a broker or begun in-house, or as 

stated previously, officials wanted to keep some larger projects in-house 

for training and maintaining in-house expertise. According to GSA 

headquarters officials, they plan to move forward with these new goals. 

They noted that the focus is now on managing the workload and not on

meeting a specified utilization number. GSA headquarters officials told us 

that they believe they are now using the NBC program for its intended 

purpose, i.e., workload management and driving savings by using broker 

 

21 GSA headquarters officials indicated they believe a new online system they are 

implementing will add transparency to the review process, and will allow headquarters 

officials to identify bottlenecks. According to these officials, anticipated changes to the 

internal staffing structure used to support the broker contract in NBC3 will also help to 

address this issue by increasing transparency.

22 GSA does not have a standard dollar amount to define “high-to-moderate value” and 

instead bases this classification on the leases type, location, and size. GSA defines as 

“high value” those new leases that are in the top 100 metropolitan statistical areas (MSA) 

and are in excess of 2,000 square feet. GSA defines as moderate those (1) new leases in 

the top 100 MSAs and less than 2,000 square feet, (2) new leases beyond the top 100 

MSA in excess of 10,000 square feet, and (3) those succeeding leases in the top 100 

MSA in excess of 5,000 square feet. 
 

Page 12 GAO-14-14 Federal Real Property

expertise in more difficult markets and working the more complex, highto-moderate value leases.

The two goals GSA uses to evaluate the NBC program are not closely 

linked to the anticipated cost savings used to justify the program. GSA 

headquarters officials told us that when they attempted to determine if 

brokers were negotiating lower rates than in-house staff, they found that 

the data they had were insufficient for this purpose. The program has 

evolved over the years, and reduced rental rates from using brokers are 

the only expected savings that remain. However, GSA lacks data on 

whether using brokers results in cost savings. Furthermore, GSA officials 

stated that they do not believe the Bullseye data will necessarily allow for 

comparison of broker- and in-house-negotiated rental rates. Without data 

on the cost benefits of using brokers relative to using in-house staff, the 

value of the NBC program will continue to be unclear. Federal internal 

control standards state that a key factor in helping agencies achieve their 

missions better and program results is the use of appropriate internal 

controls. Among other things, agencies need to compare actual 

performance to planned or expected results, monitor performance 

measures, and collect operational and financial data to ensure that 

agencies are meeting their goals for effective and efficient use of 

resources.23 This is particularly important because as programs change, 

as the NBC program has, and agencies strive to improve operational 

processes, agencies would be better equipped to assess results by

continually assessing and evaluating whether the control activities being 

used are effective and updated when necessary. By not having adequate 

data, GSA cannot assess the effectiveness of activities conducted under 

the NBC program or know if adjustments are needed to the program.

 

23 GAO, Internal Control: Standards for Internal Control in the Federal Government, 

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

Cost Savings from Using 

the NBC Program Are 

Unclear
 

Page 13 GAO-14-14 Federal Real Property

According to GSA officials, they have made changes to the NBC program 

since the first contracts were signed in 2004. Based on experiences with 

the first contracts (NBC1), GSA made changes to the current contracts 

(NBC2) in three key areas, as described below.

Implementation of Commission Cap: According to GSA officials, NBC2 

brokers were required to submit caps on the amount of commission they 

would retain for any given transaction.24 Under NBC1, brokers were 

required to submit the percentage of any commission they received that 

they would give back to GSA in the form of a rent credit. In our 2007 

report we found that allowing brokers to represent the government while 

negotiating their commissions creates an inherent conflict of interest 

between the brokers’ interest in promoting and negotiating higher 

commissions and their responsibility to effectively represent GSA’s 

interest in selecting properties that best meet the government’s needs, 

including its cost needs.25 Under NBC2, GSA believes this issue has been 

addressed, because the brokers have committed to a cap on the amount 

of commission the brokers retain. Using commissions paid by building 

owners to compensate brokers is typical in the commercial real estate 

industry. However, brokers could still have an incentive to seek 

 

24 Commission caps vary based on the type of lease and the size of the procurement, and 

brokers submitted different rates for full lease acquisition, extensions, competitive, and 

non-competitive. GSA requires brokers to negotiate a “market rate commission,” and 

tenant agencies are to receive a credit to the rent for any difference between the market 

commission and the cap.

25 GAO-07-17. 

GSA Has Made 

Changes to the NBC 

Program, and 

Stakeholders Have 

Suggested Additional 

Actions That Can 

Improve the Program

GSA’s Changes to the NBC 

Program Implementation
 

Page 14 GAO-14-14 Federal Real Property

government approval of a higher rent in order to increase the overall 

amount of their commission.26

Changes in Broker Performance Evaluations: According to GSA officials, 

GSA made two major changes to broker performance evaluations for 

NBC2. First, under NBC2, GSA reduced the number of mandatory broker 

performance evaluations from seven to four for each lease. In addition to 

receiving a final overall evaluation, brokers are now evaluated at the 

market-survey, lease-award, and post-award-services steps. GSA 

officials stated these changes were made to streamline the process and 

decrease the administrative burden on the in-house staff overseeing the 

brokers. Second, under NBC2, GSA awards tasks to brokers based on 

price and performance data.27 For NBC1 task orders were based on 

equitable distribution—i.e., brokers received equitable square-footage 

distributions in each of GSA’s 11 regions. Under both contracts, brokers 

are evaluated and scored on a scale from 1 to 5 on document quality, 

timeliness, cost control, business relations, and personnel technical 

quality.28 These evaluations are used to derive a score for each task that 

is compiled into a report and sent to GSA headquarters officials on a 

quarterly basis. GSA officials use these scores to determine a national-

 

26 GSA headquarters officials stated that negotiation objectives are agreed to between the 

Lease Contracting Officer and the broker prior to initiating negotiations with the landlord. 

The performance evaluation of the brokers includes a “cost control” on every transaction. 

As all tasking is based on performance evaluations, if brokers perform badly on this 

measure, they are at risk for not receiving future task orders.

27 The National Broker Services Contract signed in 2010 state that: for task orders or

groups of task orders estimated to yield a net commission to the contractor in excess of 

$3,000 but less than or equal to $5,000,000, all contractors will be provided a fair 

opportunity to be considered based on price or price and one or more, or all of the 

following: (1) price, based on the contractor’s pricing structure; (2) past performance; (3) 

workload capacity; and (4) workload distribution.

28 According to GSA headquarters officials, the Contracting Officer’s Technical 

Representative (COTR) is responsible for evaluating the brokers for each task they 

complete and giving them a numerical score ranging from 1 to 5. A score of 1 indicates 

“unsatisfactory” performance and a score of 5 represents “exceptional” performance. The 

contract defines the minimum level of acceptable performance, and performance 

exceeding the definitions is to be evaluated “appropriately.” For example, for business 

relations the broker is evaluated on how they represent GSA at all times when dealing 

with all parties and complies with GSA standards to achieve an acceptable solution for all 

parties.
 

Page 15 GAO-14-14 Federal Real Property

level rating for each broker. For NBC2, GSA regional officials29 determine 

which factors (document quality, timeliness, cost control, business 

relations, and personnel technical quality) are the most important for a 

lease and then use the national-level performance rating, along with cost, 

to determine which broker will be awarded a task order.30

Earlier Broker Involvement: According to GSA officials, under NBC2 GSA 

included the option of bringing brokers into the process earlier, at the 

requirements development process. “Requirements development”

31 is the 

process by which GSA works with an agency to obtain the specific 

requirements for a lease—such as the amount of space needed and the 

preferred location—at the beginning of the leasing process. Under NBC1, 

the contract allowed for the broker to assist with requirements 

development, but GSA policy was to have in-house staff assist the 

agency. GSA officials stated that brokers could add value by being 

involved in requirements development because they can bring in market 

data information and other expertise, which can better inform GSA on 

how much space might be needed and options for where it can be 

located.

GSA officials told us that they are considering additional changes as they 

plan for the third generation of contracts. According to the officials, they 

are reconsidering the structure and administration of the NBC program 

with the goal of improving its effectiveness. At the time of our review, we 

were told GSA was assessing potential changes using a range of tools, 

including those below:

• Collecting lessons learned, such as using brokers for new leases, 

which may provide better value, and working projects with short 

timelines in-house to allow for greater control over project timelines.

 

29 The Contracting Officer’s Representative (COR) or the COTR assigned to work the 

project selects the criteria GSA deems to be important given the nature of the 

procurement, and forward this criteria to the Regional Contracting Officer to be used as a 

basis for award. 

30 Regional task order evaluations that are completed in a given quarter are reviewed by 

the broker prior to being finalized. These evaluations are then consolidated at the National 

level to be used for the following quarter’s task order selections. 

31 During the requirements development phase, the tenant agency determines, among 

other things, the necessary square footage, circulation requirements, parking 

requirements, and the number of personnel to be housed.
 

Page 16 GAO-14-14 Federal Real Property

• Incorporating new approaches and strategies, such as examining 

alternatives to the current commission and rent structure and 

developing new methods for evaluating broker performance.

• Creating and gathering input via a dedicated members only 

discussion group for real estate stakeholders on the LinkedIn 

networking website.

• Exploring the feasibility of conducting a pilot program prior to full 

contract launch.

• Using the previously mentioned contractor review of the NBC 

program’s effectiveness and changes the officials and industry 

stakeholders thought would improve the program.

GSA plans to issue a request for proposals in 2014, and to award new 

contracts in fiscal year 2015.

Officials in 7 of the 11 GSA regions expressed dissatisfaction with the 

current broker performance-evaluation system. As mentioned previously, 

past performance is one of the factors regional officials use to select a 

broker. However, GSA regional officials noted some challenges 

associated with the process for evaluating broker performance. For 

example, GSA regional officials told us that under the current system, the 

same level and quality of work can receive very different ratings across 

regions. The officials noted that the ratings are largely at the discretion of 

regional officials and that the standards for scores are not necessarily 

applied uniformly.32 Regional officials suggested additional training or 

guidance for officials who do the ratings could help address these 

problems. GSA headquarters officials indicated that in addition to training, 

the changes to the internal structure used to support the contract that are 

being considered under NBC3 will help address these concerns. 

However, officials in four regions told us the broker performanceevaluation process worked well and allowed them to accurately represent 

each brokers’ performance. GSA headquarters officials said they are 

looking at ways to make the performance evaluation process more 

 

32 GSA headquarters officials noted that both the brokers and the regional officials have 

two opportunities in the process to review and provide comments on each evaluation.

Additionally, the brokers have opportunity to appeal their rating. 

All Brokers and Several 

GSA Regions Report That 

Changes to Performance 

Evaluation Are Needed
 

Page 17 GAO-14-14 Federal Real Property

consistent. They noted that in a performance-based contract, they are 

required to evaluate the contractors’ performance and need regional 

support to ensure this practice is enforced. According to the headquarters 

officials, in some instances, milestones are evaluated months or up to a 

year after the completion date and that evaluations deemed “untimely” 

are discarded. Officials emphasized that in order to accurately reflect a 

contractor’s performance, the evaluations must be completed once all 

tasks associated with that milestone are completed.

Representatives from all four national broker firms participating in the 

NBC program expressed dissatisfaction or concern with the broker 

performance-evaluation system. Representatives from one broker firm 

told us they believed the evaluations are subjective because the 

standards for numerical performance evaluation scores are ambiguous. 

For example, the same work could receive a rating of 3 in one region and 

a rating of 5 in another region, presenting a challenge when attempting to 

determine the better value to the government. Brokers from another firm 

said there needs to be greater consistency between regions on how they 

conduct broker evaluations. All four brokers also suggested that providing 

more detailed guidance for GSA officials who do the rating would make 

the ratings less subjective and more consistent across regions.

GSA regional officials and brokers also suggested using region-specific 

broker performance-evaluation data to award tasks. Officials from 10 of 

11 GSA regions told us that this change would help them award the task 

order to the broker that performed the best in the region. As officials in 

one region explained, the brokers’ national scores—which combine the 

scores from all regions—are not helpful, because these scores do not 

always reflect the performance of a specific broker that works well in a 

region. The officials in this region told us that, with 11 regions, the 

combined national score loses effectiveness, because brokers have 

different strengths and weaknesses in various markets. For illustrative 

purposes, in figure 3, we present actual data from a 2012 quarterly 

performance report to show how using national scores may result in 

assigning a task to a broker that does not perform as well in a specific 
 

Page 18 GAO-14-14 Federal Real Property

region as the broker firm’s overall national performance score.33 In this 

region, officials conducted two evaluations and rated this broker firm as 

“marginal” in every category, while the overall national scores for the 

same broker firm are primarily “very good” and “exceptional,” except for 

cost control.

Figure 3: Comparison of One Broker Firm’s 2012 Single Regional and Overall 

National Broker Performance Evaluation Scores

In the example shown in figure 3, if officials in this region identified 

“Timeliness” as the most important factor when awarding a task order, 

under the current contract, they would have to use the national scores to 

determine the broker with the best performance in timeliness. Thus, the 

task order could be awarded to this broker whose past performance was 

rated as marginal by regional officials. According to GSA headquarters 

officials, they are considering using regional past performance for task 

order selection. They noted that they would make this decision after they 

are confident that GSA staff are adequately trained and have a clear 

understanding of the contract requirements. Additionally, they said that 

they place a priority on making sure the contract is administered fairly and 

properly before they begin using regional past performance.

 

33 GSA headquarters officials stated that GSA considers this a positive reason for using 

the national scores. They noted that the region with a marginal rating had only two 

milestone evaluations for that broker and that this is not enough volume to make a 

reasonable determination of broker performance. The officials also noted that if regions 

award all work to the best regional performer, other firms would never be awarded tasks 

and therefore never have an opportunity to improve performance in that region.
 

Page 19 GAO-14-14 Federal Real Property

Of the 10 regions where officials suggested using region-specific broker 

performance evaluation data to award tasks, officials in 3 regions 

suggested developing a hybrid approach for performance evaluation data, 

wherein they could have the option of combining national scores with 

region-specific scores and using the combined score to choose a broker. 

Officials in one region told us this would allow for assignments to be 

made based on work completed in that region which would help the 

officials make better decisions. Similarly, officials in another region told us 

they would prefer to use a combination of both the regional and national 

level scores because each region has different needs, and brokers have 

different strengths and weaknesses. GSA headquarters officials told us 

they are considering using regional performance evaluation scores, but 

want to determine if the performance evaluation processes are working 

properly before they make a change. These officials also stated that there 

is concern that if regions with less attractive portfolios (fewer and less 

valuable leases) are not factored into a national score used to determine 

assignments, brokers may have less incentive to perform well in smaller 

markets.

Representatives from two broker firms suggested using region-specific 

broker-performance- evaluation data to award tasks. For example, one 

broker told us that since work is being distributed using the national 

average performance-evaluation scores, this overlooks the benefit that 

some regions may have developed strong working relationships not 

captured under a national score. They also noted that the way work is 

assigned does not seem to take into account “logical follow-on” or unique 

experience.34

GSA officials in three regions expressed concerns about the current 

commission structure and made suggestions for improvement. These 

regional officials were generally concerned that the commission-based 

system did not guarantee that brokers had an incentive to negotiate a 

lower rental rate for the government. Officials in one region told us that 

under the current system, brokers benefit from higher rental rates 

because their commission is a percentage of the total rental rate. They 

suggested that if commission rates were a specified amount instead of a 

 

34 GSA headquarters officials stated that Section C.4.3. (1) of the contract does allow

logical follow-on work. The COTR or COR can provide a justification to the RCO if they 

desire to task the follow-on project to the broker.

All Brokers and Some GSA 

Regions Report Challenges 

with the Commission 

Structure 
 

Page 20 GAO-14-14 Federal Real Property

variable percentage, GSA would be better assured that the broker was 

not trying to get a larger commission than is appropriate in that market. 

GSA headquarters officials told us that they are reexamining the 

commissions and are actively looking at alternatives to the current 

commission and rent structure.

All four brokers participating in the NBC program told us that the change 

to the commission structure GSA implemented in 2011 has decreased 

commissions and potentially could reduce the quality and quantity of 

brokers’ staff. In 2011, GSA modified the contracts to incorporate 

changes to the Federal Acquisition Regulation (FAR)35 as a result of the 

Duncan Hunter National Defense Authorization Act for Fiscal Year 2009 

(Duncan Hunter Act).36 As explained by GSA, these changes require that 

every task order or group of task orders estimated to yield a commission 

in excess of $150,000 be sent to all brokers, who then have an 

opportunity to be awarded the task order. Brokers were unanimous in 

their concern that this requirement, which they call “re-bidding” or “recompeting,” would ultimately result in lower value for the government. 

They told us that their commissions or initial contract pricing were based 

on the assumption that the profitability of the larger leases (including 

those with commissions in excess of $150,000) would help offset the 

potential losses on smaller leases, which they say are generally not 

profitable to the brokers. The brokers also told us that although this may 

result in short-term savings for the government by encouraging broker 

bidding and reducing commissions, ultimately it is not financially 

sustainable for them. Two brokers provided examples in which decreased 

revenue negatively affected staffing. For example, one broker told us 

these requirements were forcing commissions lower and that they would 

eventually have to compensate by laying-off staff or hiring staff with less 

experience; and another broker told us that decreased revenues resulted 

in a loss of employees and difficulty replacing them. Representatives 

from 3 of the 4 broker firms stated the changes to the FAR did not require 

contract modifications. These brokers stated that in their opinion, the 

 

35 48 C.F.R. § 16.505.

36 Pub. L. No. 110-417, § 863, 122 Stat. 4356, 4547-4548 (2008).
 

Page 21 GAO-14-14 Federal Real Property

changes to the FAR do not apply to the NBC program and recommended 

that changes be made that reflect this.37

Officials in the majority of regional offices (8 of the 11) suggested that 

greater flexibility in applying the NBC program would allow them to make 

better use of the brokers. Currently, when a broker is awarded a task 

order, as we described previously, it is a full service lease acquisition, 

which means the broker handles the majority of the work for a task. 

Regional officials described a preferred “menu of services” that would 

allow them to use the brokers more selectively for the specific tasks 

where GSA wants assistance as opposed to working with the broker 

throughout the entire lease procurement. For example, regional officials 

told us this would allow officials to involve brokers at crucial points—such 

as by conducting market analysis—and then allow GSA to handle the 

other parts of the procurement process in-house. The officials said that 

this would benefit GSA, because it would allow GSA to harness the 

brokers’ market expertise, which, in their opinion, is how brokers add the 

most value. According to GSA headquarters officials, they are reviewing 

the contract on an on-going basis and making the changes that will offer 

greater flexibility. They said that they have enhanced the requirements 

development, allowing the broker to perform most of the duties 

associated with requirements development process and are removing 

unnecessary requirements that delay task-order issuance.

The current NBC program allows for brokers to have only a limited role in

working with the agency requesting space during the earliest part of a 

leasing procurement—the requirements development phase —but 

according to both GSA regional officials and brokers early broker 

involvement seldom occurs.38 In some cases, it does not occur because a 

region has a group dedicated to the requirements development phase, so 

the region uses in-house expertise. However, all four brokers suggested 

that earlier involvement in the procurement process would improve the 

 

37 It is too early to determine whether GSA’s application of this provision affects GSA’s 

ability to use the NBC program, or will affect the satisfaction with the work being 

performed under this program.

38 GSA modified the NBC2 contract in July 2013 to significantly expand the brokers’ role in 

requirements development.

Most GSA Regions 

Suggested More Flexibility 

in Using Brokers

Brokers Suggested Earlier 

Involvement and Increased 

Access
 

Page 22 GAO-14-14 Federal Real Property

program’s effectiveness by allowing the brokers to assist in determining 

space needs or identifying other means of cost savings. Brokers from one 

firm noted that they have considerable experience in reducing costs for 

private sector clients by helping them plan and implement space-saving 

arrangements, and that they could provide added benefit to GSA if they 

were involved earlier in the process. Brokers from another firm said that 

GSA and the agency requesting space will sometimes develop 

requirements that will result in higher costs, but that changes could result 

in significant savings. They said that they would like to start with a blank 

slate and help determine how to save money for multiple sets of 

circumstances, including broader space planning for a single agency, 

planning across agencies, multiple leases in the same area, or 

negotiating multiple leases at the same time in the same building.

In addition to earlier involvement in the leasing process, all four brokers 

participating in the NBC program suggested that allowing them increased 

access to agencies requesting space would expedite the process.

Brokers indicated that the procurement process generally slows down 

when they have limited direct interaction with tenant agencies because 

the extra layer of communication can cause miscommunications. This 

situation can result in the broker’s trying to secure a lease with bad 

information, which can delay the process until the broker determines 

exactly what the agency wanted. Two brokers said that if they had more 

access to the agencies, the process would move more quickly and they 

would have better information on which to make decisions.

GSA’s goals and metrics for evaluating the NBC program have not been 

linked to the cost savings in rental rates GSA anticipated when proposing 

the program. As a result, GSA does not have a means of evaluating and 

reporting on this aspect of the program and the value of the NBC program 

in terms of cost savings continue to be unclear. While GSA has taken 

steps to better assess how its rental rates compare to market rates, these 

changes will not necessarily be sufficient for determining the overall costs 

and benefits of the NBC program. Accordingly, GSA will continue to lack 

the data needed to assess whether the use of brokers’ results in the 

expected cost savings through overall rental rate reduction. Clarifying its 

goals for the program and linking them to cost savings would also serve 

as a way to be transparent to the Congress and other stakeholders about 

the purpose of the program and how GSA plans to monitor and achieve 

the program’s goals. Such transparency is especially important given that 

GSA is planning to seek a third generation of broker contracts in fiscal 

year 2015.

Conclusion 
 

Page 23 GAO-14-14 Federal Real Property

To promote transparency and fully reflect the expectations GSA used to 

justify the NBC program, we recommend that the Administrator of GSA 

ensure the program’s goals are linked to cost savings achieved through 

the use of NBC brokers and develop and implement a means of 

evaluating and reporting results.

We provided a draft of this report for review and comment to GSA. GSA 

concurred with the report’s recommendation and provided technical 

clarifications, which we incorporated as appropriate. GSA’s comments are 

discussed in more detail below. GSA’s letter is reprinted in appendix II.

39

GSA stated that it will take action to implement the recommendation as 

well as address the challenges and suggested improvements noted in the 

report. GSA stated, with respect to the use of “shadow procurements” 

reported, that this practice was an extraordinary and unnecessary 

scrutiny of broker work that was limited to one GSA region and is not 

reflective of the NBC program in its totality. This point raised by GSA is 

reflected in the report, and the report does not imply that this was 

indicative of the program as a whole. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Director of the Office 

of Management and Budget and the Administrator of General Services. In 

addition, the report will be available at no charge on GAO’s website at 

http://www.gao.gov.

If you or your staff have any questions, please contact me at (202) 512-

2834 or wised@gao.gov. Contact points for our Offices of Congressional 

 

39 GSA’s letter also included an enclosure that contained the agency’s technical 

comments. The enclosure is not reprinted in appendix II. 

Recommendation for 

Executive Action

Agency Comments 
 

Page 24 GAO-14-14 Federal Real Property

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 

III. 

David J. Wise

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-14-14 Federal Real Property

Our objectives were to examine (1) the General Services Administration’s 

(GSA) National Broker Contract (NBC) program goals and the extent to 

which they are being realized; and (2) the changes GSA has made to the 

program and what challenges and suggestions for improvement, if any, 

key stakeholders identified.

To identify the goals of the NBC program, we reviewed GSA’s 2003 

analysis used to recommend the program as well as the subsequent 

goals and policies used to implement the program. From these sources 

and interviewing GSA officials, we identified expected savings and goals 

for the NBC program. The expected savings of the program include 

reducing rental rates for GSA leases of private sector space and lower 

administrative expenses as compared to the previous, mainly regionally 

based, contracts with private brokers. The goals that we identified for the 

project are for brokers to negotiate rental rates in line with overall GSA 

lease portfolio goals, and a yearly goal for using the broker program. We 

also conducted interviews with GSA headquarters officials managing the 

NBC program concerning the expected savings and goals of the program. 

To examine the extent to which benefits and goals have been realized we 

reviewed available GSA data and data analysis, GSA internal reports, 

GSA Office of Inspector General reports, and prior GAO work. We 

reviewed GSA broker data from the first year of the contract in 2005 

through 2013. We analyzed GSA’s in-house and broker-negotiated rental 

rates, and discussed with GSA headquarters officials the methodology 

used and the limitations of their analysis and findings. In consultation with 

an economist and social science analyst at GAO, we determined that 

performing our own analysis would be limited by the same factors 

identified by GSA. We reviewed internal and external reports on the NBC 

program, which provided information about program outcomes. In 

addition, we obtained data from GSA on the NBC program including 

information on commissions and credits and on use of brokers. To 

determine the reliability of this data we reviewed relevant documentation 

including internally published reports, and we interviewed agency officials 

about their processes for reviewing the data and ensuring their accuracy. 

We found the broker-related leasing data generally reliable for the 

purposes of this report. We interviewed officials from all 11 GSA regions 

and representatives from all four broker firms currently on contract about 

the use and perceived benefits of the program. We asked officials to 

identify challenges and suggestions that could help improve the program. 

Therefore, we could not always determine whether these challenges or 

suggestions were applicable in other regions or with other broker firms 

unless other officials brought them to our attention. We also identified 

federal guidance on standards for internal controls—plans, methods, and 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-14-14 Federal Real Property

procedures used to meet missions, goals, and objectives—that are key to 

helping agencies better achieve their missions and desired program 

results.1

To identify stakeholder suggestions for improving the NBC program we 

conducted interviews with the major stakeholders of the program 

including: GSA headquarters officials, all 11 GSA regional office officials, 

and representatives from all four broker firms. Each of the stakeholders 

was asked to speak about the changes between the first and second 

broker contract, and whether they felt that benefits had resulted because 

of these changes, and what further improvements, if any, they would 

suggest for the program. We reviewed modifications GSA made to the 

contract in response to the Duncan Hunter National Defense 

Authorization Act for Fiscal Year 2009 2 and to the Federal Acquisition 

Regulation. 3 We compared the first and second signed national brokercontract documentation, and analyzed the reasons for the changes 

between the two contracts. We reviewed the project plan for reviewing the 

NBC program and spoke with officials concerning their plans for making 

changes for the next generation of contracts. We also identified federal 

guidance on standards for internal controls—plans, methods, and 

procedures used to meet missions, goals, and objectives—that are key to 

helping agencies better achieve their missions and desired program 

results and assessed GSA’s efforts to set goals and objectives to achieve 

the desired results of the NBC program.4

We conducted this performance audit from September 2012 to October 

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.

 

1 GAO, Internal Control: Standards for Internal Control in the Federal Government, 

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

2 Pub. L. No. 110-417, § 863, 122 Stat. 4356, 4547-4548 (2008).

3 48 C.F.R. § 16.505.

4 GAO/AIMD-00-21.3.1.
Appendix II: Comments from General Services 

Administration

Page 27 GAO-14-14 Federal Real Property

Appendix II: Comments from General 

Services Administration

Note: Page numbers in 

the draft report reviewed 

by GSA may differ and 

have moved in the 

publication process.
Appendix II: Comments from General Services 

Administration

Page 28 GAO-14-14 Federal Real Property
Appendix III: GAO Contact and 

Staff Acknowledgments

Page 29 GAO-14-14 Federal Real Property

David Wise, (202) 512-2834 or wised@gao.gov

In addition to the contact named above, the following individuals made 

important contributions to this report: David Sausville (Assistant Director), 

Kenneth Bombara, Lorraine Ettaro, Bert Japikse, Aaron Kaminsky, Josh 

Ormond, Amy Rosewarne, and Jade Winfree.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(542210)
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