GAO 

United States Government Accountability Office

Report to Congressional Requesters

BUDGET ISSUES

Electronic Processing 

of Non-IRS 

Collections Has 

Increased but Better 

Understanding of Cost 

Structure Is Needed 

November 2009 

GAO-10-11 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

November 2009

BUDGET ISSUES

Electronic Processing of Non-IRS Collections Has

Increased but Better Understanding of Cost Structure 

Highlights of GAO-10-11, a report to Is Needed 

congressional requesters 

The Department of the Treasury’s 

Financial Management Service 

(FMS) collections program 

provides services to agencies to 

collect, deposit, and account for 

collections through a variety of 

methods. Electronic collection 

methods can reduce government 

borrowing costs and agency 

administrative costs, while 

improving compliance and security. 

GAO was asked to identify (1) the 

extent to which agencies other 

than IRS use various collection 

methods, (2) ways to maximize the 

benefits of and overcome any 

barriers to agency use of the 

various collection methods, and (3) 

issues that FMS should consider in 

its plans to improve the efficiency 

and security of collections. GAO 

analyzed collections data, plans, 

and documents from FMS and five 

case-study agencies in the 

Departments of the Interior and 

Commerce that use a variety of 

collection methods, observed fee 

collection methods, and 

interviewed FMS and case-study 

agency officials. GAO also 

interviewed selected payer groups 

for case study agencies. 

What GAO Recommends

GAO is making recommendations 

to the Secretary of the Treasury to 

facilitate transition to more costeffective collection methods and to 

the Secretaries of the Interior and 

Commerce to consider all 

collection costs, including FMS’s, 

as available, in managing their 

programs. All three agencies 

generally agreed with GAO’s 

findings and recommendations. 

Over the past 5 years, more than 80 percent of funds collected by agencies 

other than the Internal Revenue Service (IRS) were collected using fully 

electronic methods, including wire transfers and credit cards. As shown in the 

figure below, from fiscal year 2005 through 2009 there was a significant shift 

from nonelectronic collection methods to partly electronic methods. This shift 

was largely a result of a growth in electronic check-processing capacity. 

Moving to electronic collection methods can reduce costs and mitigate risks, 

such as theft, but the specific circumstances of individual agencies and payers 

have affected agencies’ ability to fully adopt these methods. Use of electronic 

methods can result in cost savings, increased processing speed and accuracy, 

and improved security of staff and deposits. Specifically, FMS reports that on 

average the government saves 78 cents for each electronic transaction. 

Additionally, case-study agencies and payer groups GAO spoke with reported 

reduced costs when using electronic collection methods. Despite the 

advantages, payer characteristics, other agency considerations, and set-up 

costs or required system changes have limited agencies’ adoption of electronic 

collection methods. Also, agencies may not have enough information to make 

cost-effective decisions about their choice of collection method. 

FMS is implementing a plan to improve the efficiency and effectiveness of 

federal collections, but the plan excludes important cost considerations and 

does not use all available incentives. Specifically, the plan does not consider 

the cost differences among different electronic methods or ensure the 

consistent application of policies on reimbursement for certain services. The 

FMS plan also does not include a strategy for incorporating key lessonslearned from agency reviews into its guidance and communicating that 

information to agencies. With such information, agencies not scheduled for 

review until later years could begin to transition to more efficient methods. 

Growth in Use of Partly Electronic Collection Methods, Fiscal Years 2005-2009 

View GAO-10-11 or key components.

For more information, contact Susan J. Irving 

at (202) 512-6806 or irvings@gao.gov. 
Page i GAO-10-11 

Contents 

Letter 1

Background 3 

Use of Electronic Collection Methods Has Increased 8 

Movement to Electronic Collection Methods Can Reduce Costs and 

Mitigate Some Risks, but Agency-Specific Circumstances Have 

Affected Adoption of These Methods 11 

FMS Is Working to Improve the Efficiency of Collections, but 

Reviews Exclude Important Considerations and Do Not Make 

Full Use of Available Incentives 18 

Conclusions 23 

Recommendations for Executive Action 24 

Agency Comments and Our Evaluation 25 

Appendix I Objectives, Scope, and Methodology 27 

Appendix II Minerals Management Service Collections 29 

Appendix III National Park Service Collections 30 

Appendix IV United States Geological Survey Collections 32 

Appendix V U.S. Patent and Trademark Office Collections 34 

Appendix VI National Oceanic and Atmospheric Administration 

Collections 35 

Appendix VII Comments from the Department of the Treasury’s 

Financial Management Service 37 

 Federal Collections 
Appendix VIII Comments from the Department of the Interior 38 

Appendix IX Comments from the Department of Commerce 39 

Appendix X GAO Contact and Staff Acknowledgments 41 

Tables 

Table 1: Federal Collection Methods 4 

Table 2: Case-Study Agency Collections—Percent of Dollars 

Collected, by Collection Method, Fiscal Year 2008 6 

Table 3: Collection Processing Times, by Collection Method 13 

Figures 

Figure 1: Collection Methods Flowchart 5 

Figure 2: Growth in Use of Partly Electronic Collection Methods by 

Agencies other than IRS, Fiscal Years 2005–2009 9 

Figure 3: MMS Collections by Type and Method 29 

Figure 4: NPS Collections by Type and Method 31 

Figure 5: USGS Collections by Type and Method 33 

Figure 6: USPTO Collections by Type and Method 34 

Figure 7: NOAA Collections by Type and Method 36 

Page ii GAO-10-11 Federal Collections
Abbreviations 

ACH PAD automated clearing house pre-authorized debits 

CCC Commodity Credit Corporation 

ECP electronic check processing 

FMS Financial Management Service 

FRB Federal Reserve Bank 

IOAA Independent Offices Appropriation Act of 1952 

IRS Internal Revenue Service 

ITGA International Treasury General Account 

MMS Minerals Management Service 

NESDIS National Environmental Satellite, Data, and Information 

 Service 

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration 

NPS National Park Service 

OMB Office of Management and Budget 

PCC paper check conversion 

TGA Treasury General Account 

Treasury Department of the Treasury 

USGS U.S. Geological Survey 

USPTO United States Patent and Trademark Office 

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

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately. 

Page iii GAO-10-11 Federal Collections
Page 1 GAO-10-11 

 

United States Government Accountability Office

Washington, DC 20548 

 

November 20, 2009 

The Honorable Richard J. Durbin 

Chairman 

Subcommittee on Financial Services and General Government 

Committee on Appropriations 

United States Senate 

The Honorable José E. Serrano 

Chairman 

Subcommittee on Financial Services and General Government 

Committee on Appropriations 

House of Representatives 

The Department of the Treasury’s (Treasury) Financial Management 

Service (FMS) collected almost $509 billion in funds received by agencies 

other than the Internal Revenue Service (non-IRS collections) in fiscal 

year 2009. In prior work we found that the method used to collect 

payments can affect compliance with payment requirements as well as 

administrative costs for both agencies and fee payers.1

 Although certain 

FMS collections services can reduce government borrowing costs, reduce 

agency/payer administrative costs, and improve the security of collections, 

some agencies do not use these services for collections, relying instead on 

agency deposit of paper-based collections. As a result we reported there 

were delays between the time payments were received and the time they 

were deposited into the Treasury, thus increasing government borrowing 

costs.2

This report responds to your request that we examine opportunities to 

improve the efficiency of federal collections governmentwide. Specifically, 

we examined (1) the extent to which agencies other than IRS use 

collection methods in FMS’s collections program, (2) how FMS and these 

agencies can maximize the benefits of and overcome any barriers to use of 

the various collection methods, and (3) issues FMS should consider as it 

1

See GAO, Federal User Fees: A Design Guide, GAO-08-386SP (Washington, D.C.: May 29, 

2008). 

2

See GAO, Federal User Fees: Additional Analyses and Timely Reviews Could Improve 

Immigration and Naturalization User Fee Design and USCIS Operations, GAO-09-180 

(Washington, D.C.: Jan. 23, 2009). 

 Federal Collections 
 

implements its plans for improving the efficiency and security of these 

collections. As agreed with your offices, we did not review IRS collections. 

Also excluded from the review are collections of the Commodity Credit 

Corporation (CCC), a federal corporation within the U.S. Department of 

Agriculture.3

To assess the extent to which agencies use various collection methods, we 

analyzed FMS data on collections received by agencies other than IRS for 

fiscal years 2005 through 2009, by collection method.4

 We reviewed FMS 

guidance and interviewed FMS officials to gather operational information 

on each collection method and understand why use of the various 

collection methods changed over time. To identify ways FMS and selected 

agencies can maximize the benefits of and overcome any barriers to the 

use of collection methods, we conducted case-study reviews of five 

agencies within two departments: the Minerals Management Service 

(MMS), the National Park Service (NPS), and the U.S. Geological Survey 

(USGS) in the Department of the Interior; and the United States Patent and 

Trademark Office (USPTO) and the National Oceanic and Atmospheric 

Administration (NOAA) in the Department of Commerce. The case-study 

agencies selected permitted us to cover the variety of collection methods 

and payer characteristics, however the findings cannot be generalized 

across the government. For each case-study agency, we analyzed 

collections data; observed agency collection processes; reviewed relevant 

legislation, regulations, agency guidance, and audit reports; and 

interviewed agency officials. We also reviewed FMS regulations and 

guidance, analyzed FMS data related to the costs and benefits of the 

various collection methods, and interviewed FMS officials. We also met 

with four payer groups identified by case-study agencies to gain an 

understanding of the effects of the shift to electronic collections on 

payers. These payer groups were trade organizations, one private-sector 

company, and representatives from state governments. To identify the 

issues FMS should consider in implementing its plans for improving the 

efficiency and security of collections, we reviewed legislation and FMS 

plans and agency agreements, applied relevant findings from our case 

 

3

According to FMS officials, CCC does not use the FMS collections program in the same 

way as other agencies. CCC uses its own network of banks to process collections 

(generally loan repayments), which totaled over $4 billion in fiscal year 2009. For the 

purposes of this report, non-IRS collections also exclude CCC collections. 

4

The almost $509 billion of non-IRS collections was about 18 percent of the $2.9 trillion 

collected through FMS’s collections program in fiscal year 2009. 

Page 2 GAO-10-11 Federal Collections
 

studies, and interviewed FMS and case-study agency officials. We assessed 

the reliability of the data we used for this review and determined that they 

were sufficiently reliable for our purposes. Appendix I provides additional 

details about the scope and methodology of our review. 

We conducted this performance audit from October 2008 through 

November 2009 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 the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

As the government’s financial manager, FMS establishes and implements 

collections policies, regulations, standards, and procedures for the federal 

government.5

 Through its collections program, FMS also provides services 

to federal agencies to collect, deposit, and account for federal collections.6

Its collections program provides a means for individuals and 

organizations, including businesses, state and local governments, and 

nonprofit organizations, to remit funds such as taxes, duties, fees, sales, 

leases, and loan repayments to the government. FMS offers a range of fully 

electronic, partly electronic,7

 and nonelectronic collection methods (see 

table 1 and fig. 1). 

Background 

 

5

The Secretary of the Treasury has authority to designate fiscal agents and depositaries of 

the U.S. government and to promulgate regulations implementing that authority. See 12 

U.S.C. § 90. FMS implements Treasury regulations pertaining to the designation of such 

fiscal agents and depositaries. See 31 C.F.R. Pt. 202. 

6

The FMS collections program is a centralized, consolidated governmentwide service with 

one national infrastructure operated by a network of commercial financial institutions and 

Federal Reserve Banks designated by FMS. 

7

FMS tracks collections in two categories: (1) electronic methods and (2) nonelectronic 

methods. 

Page 3 GAO-10-11 Federal Collections
 

Table 1: Federal Collection Methods 

Collection type Collection method Description 

Wire transfers Fedwire: The payer initiates a real-time transfer of funds from its bank to the Treasury’s 

account in the Federal Reserve Bank (FRB). 

ACH Remittance Express: The payer electronically sends an ACH credit through its 

financial institution to a unique routing number at the FRB. 

ACH pre-authorized debits (ACH PAD): An electronic transfer of funds from the payer’s 

bank through the ACH network to the Treasury’s account, authorized in advance by the 

payer. 

Automated clearing 

house (ACH) transfersa

Lockbox ACH: The payer sends payment information to a designated lockbox bank 

through its financial institution. The lockbox bank then deposits funds into the Treasury’s 

account using the payer’s financial information. 

Fully electronic 

Credit or debit cardsa

Credit/debit card: Agencies collect credit or debit card payments through a Web 

interface, at the point of sale, or by mail, phone, or fax and transmit the data through a 

designated financial agent, which transfers the funds to the Treasury’s account. 

Agency paper check conversion (PCC): Agencies collect paper checks over-thecounter at the point of sale or by mail, which are then converted on site to an electronic 

transaction or substitute checkb and deposited into the Treasury’s account. 

Partly electronic Electronic check 

processing 

Lockboxc

 electronic check processing (ECP): Paper checks received through the 

general lockbox network are converted into an electronic transaction or substitute check 

for deposit into the Treasury’s account. 

Federal Reserve Bank deposits: Checks and cash received by the agency are mailed or 

taken by courier or armored car to the nearest FRB for deposit to the Treasury’s account. 

Treasury General Account (TGA) and International Treasury General Account 

(ITGA) deposits: Agencies collect cash and checks and deposit them at a local TGA 

bank (if domestic) or an ITGA bank (if international). The bank then transfers the funds to 

the Treasury’s account. 

Nonelectronic Paper checks and cash 

Lockboxc

 General: Paper checks are mailed to a post office box designated by the 

collecting agency and FMS, where they are picked up by a courier and delivered to a 

lockbox bank, and then processed and deposited into the Treasury’s account. 

Source: GAO analysis of FMS information. 

a

Pay.gov, FMS’s Web-based, governmentwide collections portal, processes collections made by ACH 

transfer and credit card. 

b

A substitute check is a paper copy of an image of the front and back of the original check. 

c

FMS enters into lockbox service agreements with commercial banks to collect certain payments on 

behalf of federal agencies. FMS uses two lockbox networks: the general network for all payments 

except federal taxes and the Internal Revenue Service (IRS) lockbox network for federal tax 

payments. The banks establish post office boxes and electronic accounts to receive payments. 

Page 4 GAO-10-11 Federal Collections
 

Figure 1: Collection Methods Flowchart 

Source: GAO analysis of FMS information.

Electronic check

processing

Agency

Lockbox banka

Physically

transported to bank

To Treasury 

accounts in Federal 

Reserve Banks

To Treasury 

accounts in Federal 

Reserve Banks

To Treasury 

accounts in Federal 

Reserve Banks

Fully electronic

Partly electronic

Nonelectronic

Card

processor

Credit or debit 

card payments

Paper

checks Lockbox bank

Mailed to post office box, then 

physically transported to lockbox bank

Agency

Agency

Lockbox bank

Mailed to post office box, then 

physically transported to lockbox bank

Paper checks

or cash

TGA or ITGA bankb

$

or

or

ACH transfers

Pay.gov

Pay.gov

Wire transfers

or

a

A few lockbox accounts also accept and process payments by wire transfer, credit/debit cards, or 

both. 

b

Some TGA and ITGA banks process checks using electronic check processing. 

Page 5 GAO-10-11 Federal Collections
 

The agencies we examined for our case studies use a variety of these 

collection methods (see table 2). 

Table 2: Case-Study Agency Collections—Percent of Dollars Collected, by Collection Method, Fiscal Year 2008 

Fully electronic 

collection methods 

Partly electronic 

collection methods

Nonelectronic 

collection 

methods

Agency Collections 

Wire 

transfers

ACH 

transfers

Credit/debit 

cards

Electronic check 

processing

Paper checks 

and cash

Minerals 

Management 

Service (MMS) 

Rents, royalties, lease sales, 

other cost recovery services 

and payments 

93 5 < 1 0 2

National Park 

Service (NPS) 

Recreation, special park use, 

concessions, and commercial 

use fees; other reimbursables 

14 13 12 0 61

U.S. Geological 

Survey (USGS) 

Payments for cooperative 

water programs, reimbursable 

programs, product sales 

2 0 5 73 21

U.S. Patent and 

Trademark Office 

(USPTO) 

Patent fees, trademark fees 28 15 24 9 24

National Oceanic 

and Atmospheric 

Administration 

(NOAA) 

Data sales, inspection fees, 

permit fees, civil monetary 

penalties, other reimbursables 

8 9 4 45 35

Source: GAO analysis of FMS data and agency information. 

Note: Totals do not always sum to 100 because of rounding. 

FMS manages the services through which all federal collections are 

deposited in the Treasury and strives to minimize the time between when 

funds are collected and when they are deposited in the Treasury. Treasury 

regulations state that when it is cost effective, practicable, and consistent 

with current statutory authority, electronic transfers of funds are the 

optimal method for federal collections, especially when fees are recurring 

or of large dollar amounts.8

 Accordingly, FMS may require an agency 

wishing to use a collection method other than electronic transfer to 

provide a cost-benefit analysis to justify this selection. In past work, we 

highlighted the benefits of electronic collection processing. Specifically, 

we reported that electronic collections provide better accuracy, lower 

 

8

31 C.F.R. § 206.4(a). 

Page 6 GAO-10-11 Federal Collections
 

mailing and processing costs, and fewer delinquencies and defaults.9 When 

the Federal Reserve moved to electronic conversions of paper checks, 

work hours spent on check processing decreased by almost half and 

transportation costs associated with check processing decreased by about 

11 percent. In recent years FMS has made it a priority to increase the use 

of electronic collection methods and reduce collection costs.10 FMS has 

begun an initiative, called the Holistic Approach, to further these goals. 

Selection of the best collection mechanism is a joint responsibility of 

agencies and FMS.11 Agencies have responsibility for working with FMS to 

conduct cash-management reviews, gathering volume and dollar data 

relative to the operation of the systems, and funding any implementation 

and operational costs above those normally funded by Treasury. FMS 

provides guidance to agencies in its Treasury Financial Manual regarding 

the selection and cost-effective use of collection mechanisms. Agencies 

must provide FMS with a recommended mechanism for any new or 

modified cash flows. FMS reviews the recommendations, approves a 

mechanism, and assists with implementation. 

FMS’s oversight of federal agencies’ cash-management activities includes 

review of collections.12 FMS uses findings from such reviews to develop 

initiatives to improve an agency’s collections and set and monitor dates by 

which the agency must implement changes. Moreover, FMS may charge 

agencies that do not meet the implementation deadlines for the amount of 

interest savings that would have been realized by timely implementation.13

 

9

GAO, Tax Administration: Increasing EFT Usage for Installment Agreements Could 

Benefit IRS, GAO/GGD-98-112 (Washington, D.C.: June 10, 1998). Specific to 

governmentwide efforts to transition to electronic conversions of paper checks, we 

reported that the efforts had not yet resulted in economic efficiencies, but that officials 

expected greater efficiencies in the future. See GAO, Check 21 Act: Most Consumers Have 

Accepted and Banks Are Progressing Toward Full Adoption of Check Truncation, 

GAO-09-8 (Washington, D.C.: Oct. 28, 2008). 

10Treasury’s fiscal year 2009 budget justification outlines several performance goals for the 

collections program, such as the unit cost to process a collection transaction and the 

percent of the dollar amount of receipts collected electronically. These goals were 

reiterated in Treasury’s fiscal year 2010 budget justification. 

1131 C.F.R. § 206.4(c). 

1231 C.F.R. § 206.6 (d); 1 TFM 6-8075.30. 

13Any noncompliance charges are required by law to be deposited into the Cash 

Management Improvement Fund and are available to develop systems for the collection 

and timely deposit of federal funds. 31 U.S.C. § 3720(a). According to FMS officials, to date 

Treasury has not imposed any such charges. 

Page 7 GAO-10-11 Federal Collections
 

According to Treasury regulations, when funds are not collected 

electronically, agencies generally must deposit funds into the Treasury or 

a designated depositary on the day of receipt.14

FMS’s collections program is funded in part by permanent and indefinite 

appropriations for all financial agent (banking) services required or 

directed by Treasury.15 In some cases federal agencies reimburse FMS for a 

part or all of these costs. For fiscal year 2009, FMS obligated $568 million 

for banking services, an 8 percent increase over the $528 million obligated 

in fiscal year 2008.16 Fiscal year 2009 reimbursements for these banking 

services were $92 million. Such reimbursements are deposited in the 

Treasury’s general fund. 

Since 2005, agency use of collection methods has reflected FMS’s 

increased focus on electronic payments. Fully electronic payments 

accounted for more than 80 percent of dollars collected by agencies other 

than IRS for fiscal years 2005 through 2009, with $441 billion of the almost 

$509 billion collected using fully electronic methods in fiscal year 2009. 

While the percentage of funds collected through nonelectronic methods in 

2009 was low, it constituted over $36 billion. Nor does it represent a 

similarly low percentage of transactions. For example, in fiscal year 2008, 

MMS’s Minerals Revenue Management program collected over $23 billion 

in federal rents and royalties from the public; while payments by check 

represented only 2 percent of the dollars collected, they represented 77 

percent of the total number of its transactions. 

Use of Electronic 

Collection Methods 

Has Increased 

 

1431 C.F.R. § 206.5. Under federal law, federal officials in custody of public money must 

deposit it no later than the third day after receiving the money. 31 U.S.C. § 3302(c)(1). 

However, the Secretary of the Treasury is authorized by law to prescribe by regulation a 

different time frame than the one established by statute. 31 U.S.C. § 3302(c)(2). 

1512 U.S.C. § 391a and 12 U.S.C. § 5018, note. Section 218 of the Transportation, Treasury, 

and Independent Agencies Appropriation Act, 2004, Pub. L. No. 108-199, Div. F, 118 Stat. 

279, 321 (Jan. 23, 2004), established a permanent, indefinite appropriation for Treasury to 

reimburse financial institutions for depository and financial services. Before 2004, Treasury 

reimbursed banks for these services with compensating balances—noninterest-bearing 

balances deposited in banks to compensate them for collecting tax and nontax receipts. 

See GAO, Debt Management: Backup Funding Options Would Enhance Treasury’s 

Resilience to a Financial Market Disruption, GAO-06-1007 (Washington D.C.: Sept. 26, 

2006). 

16According to FMS, the increase was primarily related to lockbox collection services for 

passport and immigration programs as well as implementation of an enterprise 

architecture. 

Page 8 GAO-10-11 Federal Collections
 

In fiscal year 2009, of the almost $509 billion in non-IRS collections, about 

$68 billion was collected as cash or checks and processed using either 

partly electronic or nonelectronic collection methods. As shown in figure 

2, there was a significant shift from nonelectronic to partly electronic 

methods from 2005 to 2009. In 2005, partly electronic collection methods 

accounted for just under 2 percent of cash and check collections, but by 

2009 this share had increased to over 46 percent. Given the significant 

process and cost differences between fully electronic and partly electronic 

collection methods, we distinguish between them in this analysis. 

Figure 2: Growth in Use of Partly Electronic Collection Methods by Agencies other 

than IRS, Fiscal Years 2005–2009 

Percent

Source: GAO analysis of FMS data.

Fiscal year

Partly electronic collection methods

Nonelectronic collection methods

0

10

20

30

40

50

60

70

80

90

100

2005 2006 2007 2008 2009

Note: Consistent with FMS’s data-collection methods, the chart represents dollars collected, not 

number of transactions. According to FMS officials, FMS does not have reliable data on the number 

of transactions for most collection methods but they plan to collect these data. 

The data do not contain any dollars collected through methods designed for the IRS to collect taxes. 

IRS collections may be included in other categories if the agency or taxpayer used nontax methods to 

collect or pay fees. The data may contain taxes that are not collected by the IRS, such as customs 

excise taxes. 

The growth in partly electronic payments largely represents a change in 

agency processes rather than in payer behavior: the shift is largely the 

Page 9 GAO-10-11 Federal Collections
 

result of a growth in electronic check processing capacity both at agencies 

and through lockbox banks. In fiscal year 2008 almost $24 billion in 

collections settled as paper checks at lockbox banks, but in fiscal year 

2009 less than $2.4 billion was settled this way.17 Conversely, collections 

through electronic check processing were about $27 billion in fiscal year 

2008, but were over $31 billion in fiscal year 2009. FMS attributes this 

growth to a large marketing effort and new electronic check processing 

locations (according to FMS officials, 209 new locations—185 agency PCC 

and 24 lockbox ECP locations—were added in fiscal year 2009). 

FMS plans to discontinue some current electronic collection methods and 

shift programs that use those methods to Pay.gov—a Web-based portal 

that processes collections made through ACH transfer and credit card—

which will consolidate and simplify the number of collection methods 

available through FMS. FMS officials told us that they expect ACH preauthorized debits will be phased out and replaced by Pay.gov by the end of 

calendar year 2009. In addition, FMS plans to shift most of the existing 32 

lockbox ACH accounts to Pay.gov or other electronic collection methods, 

leaving only 2 such accounts in existence at the end of calendar year 2010. 

There are also plans to shift certain collections from nonelectronic 

methods to Pay.gov; for example, MMS is currently shifting its rent 

collections from paper checks to Pay.gov and, according to MMS officials, 

will continue to expand its use of Pay.gov in 2010. 

 

17According to FMS, as of August 2009, 99 percent of checks and dollars collected through 

lockbox banks are settled using electronic check processing. According to FMS officials, a 

few lockbox accounts have not converted to ECP either because the collection will soon 

move to a different collection method and the lockbox contract will end or because some 

aspect of the collection makes conversion to ECP exceptionally complicated. 

Page 10 GAO-10-11 Federal Collections
 

FMS, case-study agencies, and the payer groups we interviewed have 

identified a variety of cost savings stemming from the use of electronic 

collection methods. These savings stem from more efficient agency 

processing, expected lower future costs for system changes, the 

acceleration of deposits to the Treasury, and a lower administrative 

burden for payer groups. The shift to electronic methods has also 

mitigated some security and accuracy risks for agencies. Nevertheless, 

some organizations identified agency-specific circumstances that make 

full adoption of electronic collection methods less beneficial. These 

circumstances were determined by the characteristics of an agency’s 

payer base, other agency considerations, and the initial system or 

equipment costs related to the transition. 

Movement to 

Electronic Collection 

Methods Can Reduce 

Costs and Mitigate 

Some Risks, but 

Agency-Specific 

Circumstances Have 

Affected Adoption of 

These Methods 

Electronic Collection 

Methods Have Reduced 

FMS’s, Agencies’, and 

Customers’ Costs 

Officials from all five case-study agencies cited a decrease in current or 

estimated future costs resulting from the use of electronic collection 

methods but none of the agencies could fully quantify these savings. 

• In some cases, agencies increased the efficiency of internal processing 

operations. For example, officials at USGS said their 2008 move from 

nonelectronic check processing to partly-electronic paper check 

conversion increased process efficiency. Specifically, according to 

officials in one USGS office that underwent the transition,18 the change 

reduced the time it takes staff to process checks, thus freeing up staff to 

undertake additional tasks. This office disseminates USGS products such 

as maps and books and processes checks, credit card payments, and small 

amounts of cash from its sales. Prior to the transition, the nonelectronic 

check process required manual preparation of the deposit and a staff 

member to take the deposit to the bank each day. The new partly 

electronic process permits a Web-based deposit process and reduces the 

need to physically go to the bank. 

• In another case, a decrease in agency processing costs has the potential to 

reduce the size of cost-recovery fees. A NOAA regional permit official said 

that an upcoming shift from using a lockbox bank to Pay.gov for its fee 

collections is expected to increase staff efficiency and reduce payment 

processing costs such as the office’s mailing costs. If these cost savings 

are realized, the cost reductions may be passed along to the payers of the 

fee. 

 

18USGS’s Central Region Geospatial Information Office in Denver, Colorado. 

Page 11 GAO-10-11 Federal Collections
 

• In addition, fully electronic collection methods may incorporate electronic 

submission of remittance data, enabling automatic transfers of payment 

and remittance data to the agency’s accounting system. For example, to 

account for ACH transfers after funds are deposited in the Treasury, MMS 

prints out detailed payment information from FMS, matches payment 

information to the correct payer, and manually enters the detailed data 

into MMS’s internal accounting system. MMS officials told us that they are 

planning to update their accounting software to make this process 

automatic. They also said they expect that the implementation of Pay.gov 

will be designed to automate this process and thus reduce costs. 

• In May 2008 USPTO shifted its credit card processing function to Pay.gov 

both to decrease current costs and avoid future system costs for the 

agency. Adopting Pay.gov enabled USPTO to discontinue the lease of a 

line to a credit card authorization provider, a monthly savings of about 

$1,000. Agency officials also said they expect that costs associated with 

future agency system changes stemming from a change in the FMS credit 

card processor will be eliminated because Pay.gov will manage the 

transition. Potential exists for similar savings at other agencies; according 

to officials at NPS and USGS, they also incurred costs for system and 

equipment changes that were required after FMS changed its credit card 

processor. 

Some payer groups also cited benefits of a shift towards electronic 

collection methods. Three of the four payer groups we spoke with 

reported that the increased use of electronic methods has improved 

efficiency and saved money for their organizations or members by 

reducing administrative time, costs, or both. For example, state 

government representatives agreed that for many organizations, paying by 

ACH transfer is preferred because paying by check is expensive in terms 

of the cost and time of printing, mailing, and reconciling payments. More 

specifically, a representative of the state of Mississippi said that the state 

requires all vendors, besides federal agencies, to accept payments from the 

state electronically. The specific challenges faced by these payers when 

using federal agency collection methods is discussed later in this report. 

As we have previously reported, the acceleration of deposits to the 

Treasury can reduce the amount Treasury needs to borrow each day to 

pay government obligations.19 According to FMS, moving to electronic 

check processing reduces processing time by 1 day on average, whether 

done at the agency or at a lockbox bank. These total times range from 1 

 

19See GAO, IRS Lockbox Banks: More Effective Oversight, Stronger Controls, and Further 

Study of Costs and Benefits Are Needed, GAO-03-299 (Washington, D.C.: Jan. 15, 2003). 

Page 12 GAO-10-11 Federal Collections
 

day to 6 days depending on the collection method selected and whether 

mail time is included (see table 3). In the case of paper check conversion, 

this improvement brings check processing on par with some fully 

electronic collection methods such as ACH transfers and credit cards. 

Table 3: Collection Processing Times, by Collection Method 

Collection type Collection method Description 

Average total 

processing time 

(in days) 

Average settlement 

timea

Fully electronic Wire transfers Fedwire 1 Varies 

Automated clearing house 

(ACH) transfers 

ACH Remittance Express 2 Varies 

ACH PAD 2 Next day 

Lockbox ACH 2 Next day 

Pay.gov ACH 2 Next day 

Credit or debit cards bCredit/debit card 2 Next day 

Partly electronic Electronic check processing Agency paper check conversion 2 Next day 

Lockbox electronic check 

processing 

5c Next day 

Nonelectronic Paper checks and cash Lockbox General 6c Next day 

Federal Reserve Bank deposits 1 to 2 days Checks—next day; 

cash—same day 

Treasury General Account and 

International Treasury General 

Account deposits 

3 to 6 days Next day 

Source: GAO analysis of FMS information. 

a

Settlement cut off times may vary. Later cut off times permit more collections to be processed in a 

given day. 

b

Amounts collected by credit card may also be processed by Pay.gov. 

c

Includes typical mailing time estimate of 3 days. 

Case-Study Agencies Make 

Collection Decisions 

without Full Information 

Although the shift to electronic collection methods has increased 

efficiencies and decreased costs, agencies are generally unable to consider 

the full range of the federal government’s expenses—specifically FMS’s 

total collection costs—when analyzing program costs and setting fee rates. 

This is because FMS generally does not provide these cost data to 

Page 13 GAO-10-11 Federal Collections
 

agencies, although according to officials, it could.20 FMS officials stated 

that FMS does not track cost of collection information by agency, but 

instead by collection method and bank. FMS has this cost information and 

could provide it, but based on past practices, it generally has not. As we 

have previously reported, reliable information on the costs of federal 

programs and activities is crucial for effective management of government 

operations.21 Currently, agencies make decisions about collection methods 

without the benefit of this information. Moreover, agencies could 

determine whether such costs should be considered in the design and level 

of full-cost recovery fees. To the extent such cost data are provided, 

agencies that are authorized to charge full-cost recovery fees—for 

example, fees charged under the Independent Offices Appropriation Act of 

1952 (IOAA)—could, in some cases, include FMS’s cost of collections in 

their fee rates and deposit these funds into the Treasury.22

eral Collections

Officials from all five case-study agencies and FMS stated that use of 

electronic collection methods have reduced the risk of either security 

problems or processing errors. Four of the five case-study agencies stated 

that electronic collection methods alleviated security concerns for staff 

members, reduced the risk of theft, or both. 

• As noted above, prior to the move to paper check conversion, USGS staff 

drove deposits to a local bank, exposing staff to risk of theft or injury. 

Electronic Collection 

Methods Mitigate Security 

Concerns and Risks of 

Inaccuracy, Potentially 

Decreasing Collection 

Losses 

 

20FMS officials told us that they have provided collection cost information upon an agency’s 

request. 

21As discussed in Statement of Federal Financial Accounting Standards No. 4, Managerial 

Cost Accounting Concepts and Standards for the Federal Government (July 31, 1995). See 

GAO-08-386SP. 

22Whether an agency can recover certain costs will be limited by the statute providing 

authority to charge a particular fee and the application of federal case law regarding the 

proper scope of fee-setting authority. For a discussion on the legal parameters of setting 

fees and other user charges, see GAO, Principles of Federal Appropriations Law, Vol. III, 

3rd ed., Ch. 12D. Office of Management and Budget (OMB) Circular No. A-25 specifies that 

“full cost” includes all direct and indirect costs to any part of the federal government (such 

as collection costs). User fees may be assessed under specific statutory authority or under 

the broad authority of the IOAA, 31 U.S.C. § 9701. OMB Circular No. A-25 provides 

guidance regarding assessments of user charges not only under IOAA, but also under other 

more specific fee statutes to the extent permitted by law—that is, the provisions of a more 

specific user fee statute take precedence over the circular’s guidance, and indeed over the 

more general provisions of IOAA itself (see GAO, Federal User Fees: Substantive Reviews 

Needed to Align Port-Related Fees with the Programs They Support, GAO-08-321 

(Washington, D.C.: Feb. 22, 2008). 

Page 14 GAO-10-11 Fed
 

USGS officials said that the move to paper check conversion reduced 

these safety concerns. Alternatively, some agencies reduced concerns 

about staff safety by making bank deposits by means of a courier service. 

However, using couriers poses other security risks and adds costs to the 

collections process.23 For example, MMS officials said that courier costs at 

its Denver office are approximately $80,000 a year for two daily mail 

deliveries and one daily bank deposit. 

• NPS guidance also deals with security concerns pertaining to cash 

collections and the use of personnel to collect fees. For example, this 

guidance notes that parks’ implementation of a type of ACH transfer that is 

primarily used for commercial tour groups reduces the amount of cash 

handled by staff and therefore improves security.24 In addition, officials at 

the Rocky Mountain National Park said that permitting unattended 

entrance stations to accept only credit cards, rather than both cash and 

credit cards, reduced collection costs and made the machines less 

vulnerable to attempted theft. 

Officials from three of our case-study agencies stated that the electronic 

collection or provision of payment data has lowered the risk of processing 

errors, reducing repeated work and lost time and effort. 

• USGS staff said that using paper check conversion has reduced the errors 

in the process because the system confirms deposit totals before 

completing a deposit. 

• Similarly, MMS officials reported a decrease in administrative errors 

stemming from the use of Pay.gov for a selection of its fees. 

• USPTO’s adoption of an automated method for uploading remittance 

information for organizations making multiple payments also reduced 

errors. In some cases, USPTO may receive several thousand patent 

renewals in one submission from a single company that manages these 

renewals for multiple customers. In the past, these renewals would be sent 

to a lockbox bank and remittance information would be entered manually. 

This new system allows maintenance fee payment information to be 

submitted on a single compact disc and the data file on the disc to be 

uploaded directly into USPTO’s internal accounting system. 

 

23Recently we reported instances of couriers not properly safeguarding IRS receipts in 

transit to depositary institutions. See GAO, Management Report: Improvements Are 

Needed to Enhance IRS’s Internal Controls and Operating Effectiveness, GAO-09-513R 

(Washington, D.C.: June 24, 2009). 

24NPS recently replaced this type of ACH transfer with transfers through Pay.gov. 

Page 15 GAO-10-11 Federal Collections
 

An agency’s payer base characteristics and other issues can influence 

collection method selection, sometimes causing agencies to leave 

nonelectronic collection methods in place and incur costs associated with 

maintaining separate collection methods. In its work with agencies, FMS 

recognizes the importance of considering an agency’s payer base and 

whether those payers are likely to accept electronic collection methods. 

All five of our case-study agencies stated that payer characteristics and 

customer needs affected the selection of collection methods. In some 

cases, customer preferences as well as customer access to banks and 

online banking systems have influenced the different payment methods 

that agencies offer. 

Agency-Specific 

Circumstances Can Affect 

Adoption of Electronic 

Collection Methods 

• MMS said that its customers, while typically large companies, also include 

smaller operations that may not be amenable to electronic collections. 

When MMS mandated electronic submission of royalty collections, it 

granted waivers for those that appealed the requirement—approximately 

100 of the 2,100 entities for which it processes royalty revenues. Although 

a small percentage, such accommodation requires that the agency manage 

a waiver system and requires the maintenance of a nonelectronic or partly 

electronic collection method alongside the new fully electronic collection 

method. In the case of MMS, the agency maintained its nonelectronic 

check processing for collections other than royalties, so the nonelectronic 

processes were not solely maintained for those customers with waivers. 

• A representative of a commercial tour operator industry group stated that 

smaller operators in his membership would prefer the maintenance of a 

more flexible method of payment for NPS entrance fees than that 

preferred by larger operators. NPS is considering adopting Pay.gov to 

allow customers to use a Web portal to make online purchases. The tour 

representative recommended that NPS continue to accept credit cards 

from commercial operators at its entrances in order to accommodate 

smaller operators as the agency shifts to Pay.gov. While credit cards are an 

electronic collection method, the desire to maintain this alternative 

payment option in order to better serve its customers imposes costs on the 

agency, such as the purchase of necessary equipment.25

Other agency considerations also influence the selection and adoption of 

collection methods. MMS officials told us that they decided to pursue 

Pay.gov for MMS’s rent collections rather than selecting a commercial 

lockbox because a lockbox service would not meet their internal process 

 

25In all of the case studies done for this engagement, we found no evidence that the cost 

associated with maintaining separate collection methods eliminated the net benefit of even 

a partial move to electronic collection methods. 

Page 16 GAO-10-11 Federal Collections
 

needs. Although the shift to Pay.gov is underway, officials acknowledge 

there will always be some paper check collections to manage. In another 

case, NPS officials told us that the services provided by those performing 

collection activities go beyond the collection itself. They explained that 

they do not wish to remove all representatives from entrance fee 

collection stations—even if it were possible—because fee collectors are 

often “ambassadors” for the park and provide an important public service. 

Nonetheless, it requires that NPS incur some level of labor costs related to 

collections. 

For two case-study agencies the setup costs or required system changes 

necessary to implement electronic collection methods affected the ability 

or the extent to which the agency or program office could adopt or 

maintain electronic collection methods. 

• In 2002 and 2003, one NOAA regional permit office used Pay.gov as a 

payment method. The office discontinued the use of Pay.gov because of 

changes to the office’s database system and lack of information 

technology support required to establish the new system’s connection to 

Pay.gov. Nonetheless, a current project aims to reestablish the link to 

Pay.gov. 

• NPS reports that at some remote park locations the telephone and Internet 

access necessary to support electronic collection methods may be difficult 

to establish. Even in less remote areas, geographic dispersion may create 

challenges, such as the need to maintain and purchase equipment for 

multiple collection or processing points within one park. For example, 

Rocky Mountain National Park, which covers 265,800 acres and has four 

entrances, maintains two remittance offices to prepare collections for 

deposit because the road crossing the park also crosses the continental 

divide and is impassable during winter months. Therefore, collections 

cannot be transported from one side of the park to the other and must be 

prepared for deposit separately. 

Finally, meeting the varying system requirements for some electronic 

collection methods can also be a barrier for customer use. Officials from 

three state governments that submit payments to USGS told us that, while 

they prefer electronic collection methods such as ACH transfers, the 

differing technical requirements and data formats at each federal agency 

can make such transfers a burdensome, manual process. Our prior work 

has found a similar lack of standardization across federal grant-making 

agencies. For example, the use of multiple payment systems has resulted 

Page 17 GAO-10-11 Federal Collections
 

in an excessive administrative burden for grantees.26 FMS officials stated 

that limited funding is often cited as a barrier to agency adoption of new 

collection methods. 

FMS Is Working to 

Improve the 

Efficiency of 

Collections, but 

Reviews Exclude 

Important 

Considerations and 

Do Not Make Full Use 

of Available 

Incentives 

FMS Reviews of Agency 

Collections Exclude 

Important Considerations 

As the financial manager and principal fiscal agent for the federal 

government, FMS is responsible for planning and managing federal 

collections and has oversight responsibilities to ensure that agencies are 

making adequate progress in improving their cash-management practices. 

Consistent with these responsibilities, FMS developed a 5-year “Holistic 

Approach” plan, which establishes a framework for increasing the use of 

electronic collection mechanisms governmentwide; streamlining the 

collections process; offering collection mechanisms that are easy to use, 

convenient, and secure; managing depositary services that banks provide 

to federal agencies; and providing timely collection of federal receipts.27 To 

implement this plan, FMS ranked agencies for review based largely on 

 

26See GAO, Grants Management: Grantees’ Concerns with Efforts to Streamline and 

Simplify Processes, GAO-06-566 (Washington, D.C.: July 28, 2006). 

27For prior work related to FMS efforts to increase the use of electronic collections and 

payments, see GAO, Credit and Debit Cards: Federal Entities Are Taking Actions to 

Limit Their Interchange Fees, but Additional Revenue Collection Cost Savings May 

Exist, GAO-08-558 (Washington, D.C.: May 15, 2008) and GAO, Electronic Payments: Many 

Programs Electronically Disburse Federal Benefits, and More Outreach Could Increase 

Use, GAO-08-645 (Washington, D.C.: June 23, 2008). 

Page 18 GAO-10-11 Federal Collections
 

their dollar volume of collections using nonelectronic methods. It plans to 

review the collections of and draft Strategic Cash Management 

Agreements with 112 agencies spread about evenly over fiscal years 2009 

through 2013.28 During the development of the agreements, FMS reviews 

all agency collections, including those already using electronic methods, to 

see if a more efficient method could be adopted. According to FMS 

officials and as described above, the payer and type of collection are key 

factors in choosing a collection method. Each interagency Strategic Cash 

Management Agreement will outline the methods currently used by the 

agency for each of its collections; recommend electronic collection 

mechanisms; set conversion timelines, agencywide goals, and metrics; and 

estimate savings from conversion. The agreements commit both FMS and 

the agencies to implement improvements to agencies’ overall cashmanagement practices. 

As laid out in its Holistic Approach plan, FMS estimates savings of 

conversion from nonelectronic to electronic collection methods as part of 

each agency review. FMS estimates that average per transaction collection 

costs are $1.679 for nonelectronic methods and $0.897 for electronic 

methods.29 Using these figures, FMS estimates that shifting to electronic 

collections will save an average of $0.78 per transaction.30 However, there 

are significant differences in cost per transaction between different 

electronic collection methods which may be obscured by using only these 

two broad categories to estimate savings. For example, FMS estimates 

that, on average, ACH transfers processed through Pay.gov cost $0.64 per 

transaction, credit card transactions cost $1.30 per transaction, and 

lockbox ECP costs $0.58 per transaction.31

Although the cost of using different collection methods also can vary by 

the dollar amount of the transaction, FMS officials said they do not use 

volume threshold guidelines when working with agencies to select 

payment methods. Specifically, credit card merchant fees are, in part, a 

 

28As of September 30, 2009, FMS had signed agreements with 10 agencies and draft 

agreements were under review by an additional 6 agencies. 

29FMS groups partly electronic transactions—electronic check processing—with other 

electronic methods. 

30FMS’s estimates include only costs borne by FMS, not any potential savings realized by 

federal agencies. 

31The average cost of lockbox ECP processing reflects costs of both electronic and paper 

services provided by the banks. 

Page 19 GAO-10-11 Federal Collections
 

percentage of the value of the transaction. Though it may be less costly to 

process a small collection by credit card than by check, the reverse may be 

the case for large-dollar-value collections. We recently reported that the 

average merchant discount rate FMS paid in fiscal year 2007 was 1.43 

percent.32 In a hypothetical example using this rate, the total fees for a 

$100 transaction would be $1.43 and the fees for a $10,000 transaction 

would be $143. FMS limits individual credit card transactions to under 

$100,000 in order to limit merchant fees. 

FMS’s Holistic Approach plan does not provide for all available incentives 

to encourage agencies to increase the use of more cost effective collection 

methods. By using FMS services, agencies can reduce their own costs of 

collection. Specifically, as noted earlier, agencies that collect credit card 

payments through Pay.gov would be able to avoid the costs of future 

system changes because with Pay.gov those changes would be handled by 

FMS. The Holistic Approach plan includes a provision for an inefficiency 

charge of $1.00 per transaction for any collection not converted by the 

deadline as outlined in the agreement. Although FMS has the authority to 

assess inefficiency charges against agencies regardless of an agreement, 

according to FMS officials, the charge is only assessed on agencies that 

voluntarily sign an agreement and then only if the agency misses agreedupon and likely flexible deadlines. Furthermore, FMS officials said they 

are not using the Holistic Approach to review whether agencies are paying 

for certain collection services as required. FMS guidance—Treasury 

Bulletin 94-07—requires that agencies reimburse FMS for ancillary 

services and for standard lockbox collection services unless lockbox 

processing provides a net financial benefit to the Treasury’s general fund.33

In one case, we found that charges for a NOAA lockbox were initiated by 

FMS and then halted for an unknown reason. In the past, NOAA 

reimbursed FMS for services on one of its lockboxes. However, when the 

lockbox was moved to a different bank in 2005, the reimbursement charge 

 

32The type of card, the method in which it is accepted, and other factors affect the rate 

charged for any particular transaction. See GAO-08-558. 

33Examples of ancillary services are special handling of remittances including notation, 

date stamping, document matching, assembly, and stapling as well as special or detailed 

sorting. Reimbursements to the Treasury for ancillary services may be authorized under 

The Economy Act (31 U.S.C. § 1535) or 31 U.S.C. § 327. 31 U.S.C. § 327 authorizes Treasury 

to be reimbursed or advanced costs for services for which the Treasury does not receive an 

appropriation. 

Page 20 GAO-10-11 Federal Collections
 

was discontinued.34 FMS officials do not have any records of why they 

ceased to charge NOAA; NOAA officials were also not aware of the reason 

why the charges were discontinued. By not reviewing agency 

responsibility to pay for collection services, FMS does not make use of an 

available incentive to agencies to move to more efficient collection 

methods. FMS officials stated that as part of the review, FMS negotiates 

the collections proposals with the agency, but that agencies may have 

other, higher priorities than making the investments needed for a change. 

If FMS also reviewed whether the agency should reimburse FMS for the 

collection services and charged the agency based on the findings of that 

review, the agency would have a financial incentive to adopt the more 

cost-effective method. 

FMS Plan Does Not 

Include Strategy for 

Communicating and 

Incorporating Lessons 

Learned from Agency 

Reviews as It Proceeds 

with Expanded 

Implementation 

The Holistic Approach plan does not include a strategy for communicating 

lessons-learned from earlier reviews to agencies. Without such 

information, agencies not scheduled for review until later years35 might not 

have an opportunity to correct common problems. As part of the reviews, 

FMS assesses whether the agencies use unauthorized or inefficient cash 

management practices. In its reviews to date, FMS found that two agencies 

were holding funds outside of TGA banks and is aware of some inefficient 

collection practices that do not rise to the level of being unauthorized 

cash-management practices.36 In our case-study reviews we also found 

examples of inefficient collection practices, including the following: 

• On a few occasions, USPTO accepted credit cards as payment for multiple, 

individual sale transactions processed on the same day to the same credit 

card account number. This resulted in the sum of the payments to the 

same credit card account number to be at or near the dollar limit for credit 

card transactions. Because credit card fees are based in part on a 

percentage of the dollar amount charged, the cost of processing large 

collections by credit card may be more than by other methods. 

 

34The current lockbox agreement states that NOAA will be responsible for paying the costs 

of the lockbox account. 

35FMS plans to review the collections of approximately 22 agencies per year in fiscal years 

2009 through 2013. 

36FMS officials stated that they work with agencies to immediately eliminate unauthorized 

practices and negotiate with agencies to change inefficient practices when developing 

Strategic Cash Management Agreements. 

Page 21 GAO-10-11 Federal Collections
 

• NOAA maintains some lockbox accounts with volumes below what FMS 

officials told us was their rule-of-thumb for lockbox services. FMS does 

not have an official volume threshold for lockboxes, but officials stated 

that processing checks through a lockbox might be a good choice for a 

program collecting a minimum of 1,000 checks and $1 million per month. 

Of the eight NOAA lockboxes,37 all had calendar year 2008 collections 

volume that averaged less than 1,000 checks per month and only one 

processed over $1 million per month on average; one lockbox processed 

208 checks totaling less than $5,000 that year. Check volume affects the 

per-transaction cost of lockbox services because some lockbox bank 

charges are fixed (e.g., monthly account maintenance charges). 

• As a standard practice for one NOAA regional permit office, payers mailed 

checks to the office and then NOAA mailed the checks to the lockbox 

bank for processing on a weekly basis. This practice delays deposit of the 

collections. 

Agencies not scheduled for review until later years also may lack 

information on how to overcome barriers to the use of electronic 

collection methods or invest in more cost-effective collection methods. 

Such barriers include agency regulations that define the methods an 

agency uses to make collections, and payers that are less amenable to 

electronic collection methods. With better information about the 

capabilities and benefits of the various collection methods, agencies could 

in turn communicate that information to their payer groups. According to 

payer groups we spoke with, their members would be more likely to adopt 

electronic collection methods if agencies encouraged them. According to 

FMS, existing agency collection contracts and systems can be a barrier to 

adoption of more efficient collection methods. 

Some FMS collections guidance is outdated, but the Holistic Approach 

plan does not include a strategy for updating guidance based on lessonslearned from the agency reviews. The primary guidance to agencies on the 

various options for collection methods—FMS’s Cash Management Made 

Easy—was last updated in April 2002 and includes outdated descriptions 

of some methods. FMS’s guidance for the situations in which agencies 

must reimburse FMS for costs of lockbox services—Treasury Bulletin 94-

 

37NOAA maintains nine lockboxes, but the collections for two of the lockboxes are 

processed together. 

Page 22 GAO-10-11 Federal Collections
 

07—is, in some respects, also outdated.38 It bases the responsibility to pay 

for the costs of standard lockbox services on the net benefit to the 

Treasury’s general account of accelerated deposits. However, since the 

time the bulletin was issued, electronic processing of checks has become 

an option for agencies. In some cases, this new option may be a more costeffective choice. 

FMS has made important progress helping the federal government 

improve the efficiency and effectiveness of non-IRS collections; in fiscal 

year 2009, almost 87 percent of these funds were collected using fully 

electronic methods. As work continues to overcome barriers to electronic 

collection methods, several benefits continue to accrue: the cost of 

government borrowing is decreased as the time to process collections is 

reduced; agencies, customers, and FMS may enjoy lower costs of 

collection; and security of collections and staff are improved. 

Conclusions 

Reliable information on the costs of federal programs and activities is 

crucial for effective management of government operations. However, it 

can be difficult for agencies to effectively manage their programs or make 

informed choices among collection options because FMS generally does 

not provide agencies data or information on FMS’s costs of collections for 

a given agency, program, or collection method. FMS has cost information 

by collection method but generally does not provide it to agencies. While 

FMS officials said that they could and have provided cost information 

upon request, we believe provision of such data should not be ad hoc. 

Rather, data should be distributed systematically to facilitate agency 

program management. The lack of information on FMS’s costs of 

collections means that agencies do not have complete information for 

analysis of their fee structure and level. For some full-cost recovery fees 

this means that the federal government may be inappropriately foregoing 

revenues. 

FMS’s ongoing initiative to analyze and review the collection activity in 

each agency through implementation of its Holistic Approach plan 

facilitates growth in the use of electronic collection methods. However, 

two aspects of the approach may lead to decisions that are not the most 

 

38In commenting on a draft of this report, FMS said that it was in the process of rewriting 

the Cash Management Made Easy guidance and updating Treasury Bulletin 94-07. 

According to FMS officials the updated guidance will set criteria for determining what FMS 

collection services are ancillary and should be reimbursed by agencies. 

Page 23 GAO-10-11 Federal Collections
 

cost-effective. First, FMS groups all fully and partially electronic methods 

together when developing an estimate of the cost savings of shifts from 

nonelectronic to other collection methods. Second, FMS does not make 

use of all available financial incentives—including enforcing its own 

guidance by requiring agencies to reimburse it for certain collection 

services. 

Finally, some inefficient agency collection practices may persist longer 

than necessary because FMS’s Holistic Approach plan does not include 

either a strategy to communicate key lessons-learned from early agency 

reviews to other agencies whose reviews are scheduled for future years or 

a way to use the information to update FMS guidance to agencies. Interim 

updates of collections guidance and regulations could allow agencies to 

benefit from key lessons-learned during FMS reviews. 

We are making five recommendations in this report. 

To strengthen oversight of the costs of collecting federal fees and other 

receipts, we recommend that the Secretary of the Treasury direct the FMS 

Commissioner to take the following four actions: 

Recommendations for 

Executive Action 

(1) Provide each agency with information on FMS’s annual costs of 

processing related to that agency’s collections by, for example, providing 

information on the agency’s total collections, by collection method, and 

FMS’s costs by collection method. 

(2) Revise FMS’s Holistic Approach plan to assure that the reviews of 

agency collections will consider the differences in costs of the various 

electronic collection methods. 

(3) Enforce FMS guidance by 

a. specifying criteria for determining whether FMS collection 

services are either ancillary or are lockbox services not providing a 

net benefit to the Treasury’s general account and so should be 

reimbursed by the agency; and 

b. using these criteria during Holistic Approach plan reviews to 

determine whether each agency should reimburse FMS for services 

and document that decision. 

Page 24 GAO-10-11 Federal Collections
 

(4) Establish a process for updating collections guidance and regulations 

based on key lessons-learned from its reviews and communicating that 

information to all agencies so that agencies whose review is scheduled for 

later years can begin to implement changes. 

We recommend that the Secretaries of the Interior and Commerce include 

FMS’s costs of collection, as available, in analyzing MMS, NPS, USGS, 

USPTO, and NOAA programs and, as appropriate, the design and level of 

user fees. 

We provided a draft of this report to the Secretaries of the Treasury, the 

Interior, and Commerce for review. We received written comments from 

the Department of the Treasury’s Financial Management Service, the 

Department of the Interior, and the Department of Commerce, which are 

reprinted in appendixes VII, VIII, and IX, respectively. In addition, 

Treasury provided technical comments, which we incorporated as 

appropriate. We also provided portions of the report to nonfederal 

stakeholders for their review and made technical corrections as 

appropriate. 

Agency Comments 

and Our Evaluation 

FMS agreed with our recommendations and stated that it will develop an 

action plan to address each recommendation. Initially, the draft’s third 

recommendation said that, while implementing the Holistic Approach 

reviews, FMS should specify criteria for determining whether its collection 

services are ancillary and should therefore be reimbursed by the agency. 

FMS commented that it is working on establishing such criteria in an 

initiative separate from the Holistic Approach. In describing this initiative 

to us, FMS officials explained that by separating the two initiatives they 

expect to be able to review and update the policy on reimbursement more 

quickly. They expect to complete the review of the reimbursement policy 

by April 2010. The officials also noted that enforcement of the policy may 

need to be phased-in over time as agencies will need to ensure that their 

appropriations allow reimbursement to FMS for certain collection 

services. In response to these comments, we revised the recommendation 

to clarify that the reimbursement criteria need not be developed as part of 

the Holistic Approach plan, only that, to consistently enforce FMS policies, 

the criteria should be applied as part of the reviews. 

The Department of the Interior concurred with our findings and 

recommendation and stated that the report accurately depicts their efforts 

to implement electronic collection methods. 

Page 25 GAO-10-11 Federal Collections
 

The Department of Commerce also agreed with our recommendation and 

expressed its commitment to implementing the recommendation and to 

working with Treasury to improve the efficiency and effectiveness of 

collection processes. It also provided technical comments specifically with 

regard to the USPTO, which we incorporated as appropriate. 

We are sending copies of this report to the Honorable Timothy F. 

Geithner, Secretary of the Treasury; the Honorable Ken Salazar, Secretary 

of the Interior; and the Honorable Gary Locke, Secretary of Commerce. 

This report is also available at no charge on the GAO Web site at 

http://www.gao.gov. 

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

contact me on (202) 512-6806 or irvings@gao.gov. Contact points for our 

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

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

Susan J. Irving 

report are listed in Appendix X. 

Director for Federal Budget Analysis, Strategic Issues 

Page 26 GAO-10-11 Federal Collections
Appendix I: Objectives, Scope, and 

Methodology 

Page 27 GAO-10-11 

Appendix I: Objectives, Scope, and 

Methodology 

To analyze opportunities to improve the efficiency of federal collections 

governmentwide we examined (1) the extent to which agencies other than 

the Internal Revenue Service (IRS) use collection methods in the Financial 

Management Service’s (FMS) collections program, (2) how FMS and these 

agencies can maximize the benefits of and overcome barriers to use of the 

various collection methods, and (3) issues FMS should consider as it 

implements its plans for improving the efficiency and security of these 

collections. 

To assess the extent to which agencies use various collection methods, we 

analyzed data on governmentwide collections by collection method from 

FMS’s Total Collections Report for fiscal years 2005 through 2009. We 

worked with FMS to group collection methods consistently over time and 

to categorize them as fully electronic, partly electronic, and nonelectronic. 

In order to focus our analysis on nontax collections, we excluded 

collections FMS identified as IRS collections. However, according to FMS, 

some IRS collections may nonetheless be included in the remaining data. 

We also excluded collections of the Commodity Credit Corporation 

(CCC)—a federal corporation within the U.S. Department of Agriculture—

because, according to FMS officials, CCC does not use the FMS collections 

program in the same way as other agencies. CCC uses its own network of 

banks to process collections. We reviewed FMS guidance and interviewed 

FMS officials to gather operational information on each collection method 

and understand why use of the various collection methods changed over 

time. 

To analyze ways FMS and selected agencies can maximize the benefits of 

and overcome barriers to the use of collection methods, we conducted 

case-study reviews of five agencies: the Minerals Management Service 

(MMS), the National Park Service (NPS), the United States Geological 

Survey (USGS), the United States Patent and Trademark Office (USPTO), 

and the National Oceanic and Atmospheric Administration (NOAA). We 

selected this set of case-study agencies to cover the use of the variety of 

collection methods, a variety of payer and payment characteristics, 

programs with significant collection totals, representation of at least two 

departments, potential for improved efficiency, and instances of a recent 

change in collection method. These case studies are not intended to be 

representative and therefore the information gleaned from them cannot be 

generalized across the government. We used fiscal year 2006 OMB data on 

fee collections and fiscal year 2008 FMS data on collections by method to 

identify the case-study agencies. For each case-study agency, we analyzed 

collections data, interviewed agency officials, and reviewed relevant 

legislation, regulations, agency guidance, and audit reports. We performed 

 Federal Collections 
Appendix I: Objectives, Scope, and 

Methodology 

site visits at NPS’s Rocky Mountain National Park in Estes Park, Colorado, 

and USGS’s Central Region Geospatial Information Office and MMS’s 

Minerals Revenue Management office both in Denver, Colorado. At each 

site-visit location, we observed collection processes and interviewed 

agency officials. We also observed the lockbox process and interviewed 

bank officials at a U.S. Bank lockbox location in St. Louis, Missouri that 

provides lockbox services to NOAA and USPTO. We also interviewed 

representatives or members from four payer organizations—the American 

Petroleum Institute, the National Tour Association, Computer Packages 

Inc., and the National Association of State Auditors, Comptrollers and 

Treasurers—to gain an understanding of the effects of the shift to 

electronic collections on payers. We selected these organizations from 

stakeholder or payer organizations suggested by each case-study agency. 

We also reviewed FMS regulations and guidance, analyzed FMS data 

related to the costs and benefits of the various collection methods, and 

interviewed FMS officials. 

To identify the issues FMS should consider in implementing its plans for 

improving the efficiency and security of collections, we reviewed relevant 

legislation and FMS plans and agency agreements, applied relevant 

findings from our case studies, and interviewed FMS and case-study 

agency officials. 

We assessed the reliability of the data we used for this review and 

determined that it was sufficiently reliable for our purposes. We 

conducted this performance audit from October 2008 through November 

2009 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 the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

Page 28 GAO-10-11 Federal Collections
A

C

ppendix II: Minerals Management Service 

ollections 

Page 29 GAO-10-11 

Appendix II: Minerals Management Service 

Collections 

The Minerals Management Service (MMS), a bureau in the Department of 

the Interior, manages the nation’s natural gas, oil, and other mineral 

resources on the outer continental shelf. The agency also collects, 

accounts for, and disburses more than $8 billion per year in revenues from 

federal offshore mineral leases and from onshore mineral leases on federal 

and Indian lands. 

Agency Description 

MMS’s Minerals Revenue Management collects rents, royalties, and 

proceeds from lease sales by means of automated clearing house (ACH) 

transfers, wire transfers, and Federal Reserve Bank deposits. Although 

most of the payments MMS receives are transmitted electronically, as of 

October 2008 MMS still received nearly 50,000 checks per year. In fiscal 

year 2008, rents and royalties totaled $13.4 billion and lease sales totaled 

$10.2 billion. Royalty payments are typically high-dollar payments, while 

onshore and offshore rent payments can range from a few hundred to 

several thousand dollars. 

Types of Collections 

MMS’s Offshore Energy and Minerals Management program also collects 

fees for cost-recovery services and payments, public-information service 

fees, and linear rental fees, totaling $11.2 million in fiscal year 2008. These 

collections are solely made through Pay.gov. MMS fee-paying customers 

are often large companies, but also include smaller organizations and 

individuals. 

Figure 3: MMS Collections by Type and Method 

98%

Source: GAO analysis of FMS data.

2%

Nonelectronic

Fully electronic

Fedwire 93 22,190,869,435

5 1,205,198,009

Pay.gov ACH 0 1,762,200

Lockbox ACH 0 58,601,307

Credit/debit card 0 9,472,223

Federal Reserve Bank 2 361,526,550

TGA and ITGA 0 360,820

Total 100 23,827,790,543

Fully electronic

Nonelectronic

Collection method

Percent 

of total

Fiscal year 2008

collection amount 

(dollars)

ACH remittance 

express

Note: Amounts collected by credit card may also be processed by Pay.gov. 

 Federal Collections 
Appendix III: National Park Service Appendix III: National Park Service Collections 

Collections 

The National Park Service (NPS) is a bureau of the Department of the 

Interior. The national park system is comprised of 391 areas covering more 

than 84 million acres. These areas include national parks, monuments, 

battlefields, military parks, historical parks, historic sites, lakeshores, 

seashores, recreation areas, scenic rivers and trails, and the White House. 

Agency Description 

NPS collects funds from the public for recreation fees, special park use 

permits and fees, transportation fees, and other collections such as 

payments from concessionaires and commercial use fees and other forms 

of debt collection. Recreation fees include park entrance fees and special 

recreation permit fees. Recreation fees range from $5 to $25, or more for 

large group purchases. Special use fees are charged for the use of park 

lands or facilities for activities that occur in a park and provide benefit to 

an individual, group, or organization rather than the public at large. These 

administrative fees are intended to recover full costs and are calculated on 

a case-by-case basis, but range from $50 to $50,000. Transportation fees 

are collected to recover costs associated with an NPS-provided 

transportation system. 

Types of Collections 

In fiscal year 2008 NPS collected approximately $179 million in recreation 

fees through credit cards, automated clearing house (ACH) transfers, 

Federal Reserve Bank (FRB) deposits, Treasury General Account (TGA) 

deposits, and Pay.gov. Fiscal year 2008 special park use fees totaled 

$12,938,317 and were collected predominantly through TGA deposits and 

some credit card collections. Transportation fees totaled $13,883,451 in 

fiscal year 2008. NPS fee-paying customers include individuals, tour 

operators, concessionaires, and commercial operators. 

Page 30 GAO-10-11 Federal Collections
Appendix III: National Park Service 

Collections 

Figure 4: NPS Collections by Type and Method 

61%

39%

Source: GAO analysis of FMS data.

Fully electronic

Nonelectronic

Fedwire 14 53,336,733

2 7,118,224

Pay.gov ACH

ACH PAD 11 39,519,488

0 80,290 

Credit/debit card 12 45,358,940 

Federal Reserve Bank

TGA and ITGA 46 171,487,947

14 52,280,800

Total 100 369,182,422

Fully electronic

Nonelectronic

Collection method

Percent 

of total

Fiscal year 2008

collection amount 

(dollars)

ACH remittance 

express

Note: Amounts collected by credit card may also be processed by Pay.gov. 

Page 31 GAO-10-11 Federal Collections
A

C

ppendix IV: United States Geological Survey 

ollections 

Page 32 GAO-10-11 

Appendix IV: United States Geological Survey 

Collections 

The U.S. Geological Survey (USGS), a Department of the Interior agency, 

is the nation’s largest water, earth, and biological science and civilian 

mapping agency. The USGS collects, monitors, analyzes, and provides 

scientific understanding about natural resource conditions, issues, and 

problems. 

Agency Description 

USGS collects funds for products sales (mostly relating to mapping 

products), cooperative water program agreements, and fully-reimbursable 

programs. Under the cooperative water program, cooperators partner with 

USGS and reimburse USGS for a portion of the costs of specific USGS 

data-collection activities, investigations, or studies. Payments under these 

agreements vary, with 40 percent of agreements yielding $25,000 per year 

or less and the largest agreement falling between $2 million and $3 million. 

These funds make up the majority of USGS collections and are mostly 

collected by lockbox electronic check processing (ECP). Other 

collections, including those for product sales and reimbursable 

agreements, are made via agency paper check conversion (PCC), Treasury 

General Account (TGA) deposits, International Treasury General Account 

(ITGA) deposits, credit cards, and wire transfers. 

Types of Collections 

Fiscal year 2008 collections totaled $217 million, with the majority of this 

amount ($215 million) stemming from reimbursables. Reimbursables 

include reimbursements from nonfederal sources such as states, tribes, 

and municipalities for cooperative efforts and proceeds from the sale of 

photographs and record copies; reimbursements for permits and licenses 

of the Federal Energy Regulatory Commission; and reimbursements from 

foreign countries and international organizations for technical assistance. 

 Federal Collections 
Appendix IV: United States Geological Survey 

Collections 

Figure 5: USGS Collections by Type and Method 

73%

21%

6%

Source: GAO analysis of FMS data.

Partly electronic

Fully electronic

Nonelectronic

Fedwire 2 3,733,919

5 10,008,197

TGA and ITGA

9 18,921,044 

Lockbox ECP

Agency PCC

64

1 2,793,893

138,515,030

Lockbox General 20 43,195,362

Total 100 217,167,445

Fully electronic

Partly electronic

Nonelectronic

Collection method

Percent 

of total

Fiscal year 2008

collection amount 

(dollars)

Credit/debit card

Page 33 GAO-10-11 Federal Collections
Appendix

C

 V: U.S. Patent and Trademark Office 

ollections 

Page 34 GAO-10-11 

Appendix V: U.S. Patent and Trademark 

Office Collections 

The U.S. Patent and Trademark Office (USPTO) is an agency of the 

Department of Commerce. The agency’s main functions are the 

examination and issuance of patents and the examination and registration 

of trademarks. 

Agency Description 

USPTO receives its funding through fees that are paid to obtain and renew 

patents and trademarks. Patent fees, for activities such as application 

filing, maintenance, and patent extensions, totaled $1.6 billion in fiscal 

year 2008. These fees can range from $3 for a patent copy to over $8,000 

for other services such as inter partes reexamination. Patent fee payments 

are accepted through credit cards, Pay.gov accepting credit cards or 

automated clearing house (ACH) transfers, lockbox electronic check 

processing (ECP) and Treasury General Account (TGA) deposits. 

Trademark fees, charged for services such as trademark processing and 

services, totaled $236 million in fiscal year 2008. Trademark fees range 

from $3 to $400 and are paid through credit cards, Pay.gov accepting 

credit cards or ACH transfers, and TGA deposits. USPTO also accepts 

replenishments to deposit accounts through wire transfers, lockbox ECP, 

and TGA deposits. Payments for some fees from foreign sources are sent 

through wire transfers. Payers for patent and trademark fees are 

individuals, attorneys, law firms, small businesses, nonprofits, and large 

corporations. Patent fees are also paid by annuity companies. 

Types of Collections 

Figure 6: USPTO Collections by Type and Method 

67%

24%

9%

Source: GAO analysis of FMS data.

Partly electronic

Fully electronic

Nonelectronic

Fedwire 28 571,996,867

15 299,738,355

TGA and ITGA

24 497,331,148

Lockbox ECP

Credit/debit card

9

16 336,842,585

192,208,448

Lockbox General 7 153,766,254

Total 100 2,051,883,657

Fully electronic

Partly electronic

Nonelectronic

Collection method

Percent 

of total

Fiscal year 2008

collection amount 

(dollars)

Pay.gov ACH

Note: Amounts collected by credit card may also be processed by Pay.gov. FMS and agency 

accounting of deposits may differ due to deposits in transit. Collections totals include normal fee 

collections, as well as other collections for deposit accounts and amounts provided to the USPTO that 

are passed through from and to other entities. 

 Federal Collections 
Appendix VI: National Oceanic and Appendix VI: National Oceanic and Atmospheric Administration Collections 

Atmospheric Administration Collections 

The National Oceanic and Atmospheric Administration (NOAA) is a 

science-based federal agency within the Department of Commerce with 

regulatory, operational, and information-service responsibilities. NOAA’s 

mission is to understand and predict changes in the earth’s environment 

and to conserve, protect, and manage coastal, marine, and Great Lakes’ 

resources to meet our nation’s economic, social, and environmental needs. 

NOAA offices include the National Environmental Satellite, Data, and 

Information Service (NESDIS), the National Marine Fisheries Service 

(NMFS), the National Ocean Service, National Weather Service, the Office 

of Marine and Aviation Operations, the Office of Oceanic and Atmospheric 

Research, and the Office of Program Planning and Integration. 

Agency Description 

NOAA offices receive collections for various programs using a wide range 

of collection methods. In fiscal year 2008, NESDIS received $1.7 million in 

revenue for its sales of data. These collections were made through a 

combination of lockbox electronic check processing (ECP), Pay.gov, 

lockbox general, and Treasury General Account (TGA) deposits. Pay.gov 

processed the largest amount of these collections at $1.2 million. NMFS 

receives fees for a variety of permits, penalties, and inspections, totaling 

over $48 million in fiscal year 2008. Seafood inspection fees, for example, 

averaged over $23,000 per fee collected and were collected by means of 

wire transfer, Federal Reserve Bank deposits, lockbox ECP, Pay.gov, 

lockbox general, and TGA deposits. Other NMFS collections averaged 

from $26 for tuna permits to over $6,000 for civil monetary penalties. Other 

NOAA collections include payments to the Damage Assessment and 

Restoration Revolving Fund, loan and buy back payments, and other 

reimbursables. Payer groups for NOAA fees vary, but include private and 

corporate customers for NESDIS data sales as well as individual fishermen 

and fishing companies for NMFS permit fees. 

Types of Collections 

Page 35 GAO-10-11 Federal Collections
Appendix VI: National Oceanic and 

Atmospheric Administration Collections 

Figure 7: NOAA Collections by Type and Method 

35%

45%

20%

Source: GAO analysis of FMS data.

Fully electronic

Nonelectronic

Partly electronic

Fedwire 8 10,030,891

4

9

5,113,032 

10,914,559 

Agency PCC 1 783,727

Lockbox ECP 44 55,821,557

Federal Reserve Bank 1 1,275,595

TGA and ITGA 28 35,173,788

Lockbox General 6 8,192,041

Total 100 127,305,190

Partly electronic

Fully electronic

Nonelectronic

Collection method

Percent 

of total

Fiscal year 2008

collection amount 

(dollars)

Pay.gov ACH

Credit/debit card

Note: Amounts collected by credit card may also be processed by Pay.gov. 

Page 36 GAO-10-11 Federal Collections
Appendix VII: Comments from the 

Department of the Treasury’s Financial Appendix VII: Comments from the Management Service 

Department of the Treasury’s Financial 

Management Service 

Page 37 GAO-10-11 Federal Collections 
Appendix VIII: Comments from the Appendix VIII: Comments from the Department of the Interior 

Department of the Interior 

Page 38 GAO-10-11 Federal Collections
Appendix IX: Comments from the Department Appendix IX: Comments from the of Commerce 

Department of Commerce 

Page 39 GAO-10-11 Federal Collections
Appendix IX: Comments from the Department 

of Commerce 

Page 40 GAO-10-11 Federal Collections
Appendix X: 

A

GAO Contact and Staff 

cknowledgments 

Page 41 GAO-10-11 

Appendix X: GAO Contact and Staff 

Acknowledgments 

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

In addition to the individual listed above, Carol Henn, Assistant Director; 

Mallory Bulman; Susan Etzel; Katherine Hamer; and Elizabeth Hosler 

made significant contributions to this report. Charles Fox, Cody Goebel, 

Christine Houle, Paul Kinney, Felicia Lopez, Julie Matta, Anu Mittal, Donna 

Miller, Robin Nazzaro, Jacqueline M. Nowicki, Melanie Papasian, Sheila 

Rajabiun, Thomas Short, and Jay Smale also made key contributions to 

this report. 

 Federal Collections 

GAO Contact 

Staff 

Acknowledgments 

(450690) 
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