TRAVEL PROMOTION

Brand USA Needs 

Plans for Measuring 

Performance and 

Updated Policy on 

Private Sector 

Contributions 

Report to the Ranking Member, 

Committee on Homeland Security, 

House of Representatives

July 2013

GAO-13-705

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-705, a report to the 

Ranking Member, Committee on Homeland 

Security, House of Representatives

July 2013

TRAVEL PROMOTION

Brand USA Needs Plans for Measuring Performance 

and Updated Policy on Private Sector Contributions

Why GAO Did This Study

In 2012, 67 million international 

travelers visited the United States, 

spending a total of $168 billion and 

supporting 7.7 million U.S. jobs. 

However, the U.S. market share of 

global spending by international 

travelers has fallen over the last 

decade. In 2010, Congress passed 

TPA, establishing the Corporation for 

Travel Promotion—which conducts 

business as Brand USA—as a 

nonprofit public-private partnership to 

promote international travel to the 

United States. TPA requires that Brand 

USA’s annual budget consist of private

sector cash and in-kind contributions, 

with federal matching funds. 

Commerce reviews Brand USA’s 

requests for federal matching funds 

and directs Treasury to disburse the 

funds. For fiscal year 2012, Brand USA 

received about $50 million in privatesector funding and $100 million in 

federal matching funds. 

This report addresses (1) Brand USA’s 

programs and activities, (2) efforts to 

measure performance, and (3) certain 

policies and procedures. GAO 

reviewed Brand USA documents and 

data and interviewed officials from 

Brand USA, Commerce, and private 

firms as well as academic experts.

What GAO Recommends

GAO recommends that Brand USA 

(1) develop a performance plan, 

(2) competitively select its media 

consultant for the development of 

valuation methodologies, and 

(3) formalize procedures for revising 

the in-kind contributions policy. Brand 

USA concurred with the 

recommendations.

What GAO Found

Brand USA’s global campaign promotes travel to all 50 states through various

television, print, billboard, Internet, and social media advertising activities, and its 

targeted campaigns conduct similar promotions in selected countries. To select 

countries for targeted campaigns, Brand USA uses several criteria, including 

volume of visitors and tourism revenue from the country. Brand USA launched 

targeted campaigns in 2012 in Canada, Japan, and the United Kingdom during 

each country’s peak travel-planning periods, and it plans to launch targeted 

campaigns in these and additional countries in 2013. Brand USA contracts with

overseas firms to plan and coordinate marketing activities in targeted countries. 

In addition, partners help Brand USA promote travel to specific U.S. destinations 

and establish a campaign presence outside targeted countries. 

Brand USA has taken some steps to measure its performance but has not yet 

developed a plan to monitor and evaluate its promotional campaign’s impact 

regarding two key long-term goals—increasing travel to, and travelers’ spending 

in, the United States. Brand USA has developed metrics to monitor its Internet 

and social media activity and contracted with a firm to evaluate the campaign’s

effects on traveler perceptions, which found positive results. These metrics and 

evaluations do not measure the campaign’s impact on international traveler visits 

or spending. Brand USA officials said that isolating the campaign’s impacts from 

other factors would be difficult, although the corporation is considering 

approaches for doing so. Without a plan that identifies the specific timeframes, 

methods, and data sources for evaluating its progress toward its long-term goals,

Brand USA may be missing opportunities to optimize its resources. 

Brand USA has established policies for personnel, procurement, and in-kind 

contributions consistent with applicable Travel Promotion Act (TPA) 

requirements. Brand USA’s personnel policies address discrimination and equal 

opportunity, while its procurement policy requires Brand USA to generally follow 

competitive procedures to acquire goods and services. However, Brand USA did 

not competitively award a contract to develop valuation methodologies for in-kind 

contributions. Experts whom GAO interviewed found the methodologies 

reasonable but noted that other approaches may provide more accurate 

assessments. Brand USA officials said the corporation may competitively award 

another contract after the current contract expires in December 2013. Brand USA 

and the Department of Commerce established the in-kind contributions policy in 

November 2011 and have revised it three times since then, most recently in 

March 2013. However, GAO found that Brand USA and Commerce disagree 

regarding whether certain types of in-kind contributions that are eligible under the 

policy qualify for federal matching funds. Brand USA returned nearly $1.1 million 

in federal matching funds that Commerce had previously approved, but Brand 

USA noted that it reserved the right to resubmit these types of contributions. 

GAO’s recent work on organizations that receive both federal and nonfederal 

resources found that formalizing and documenting a process for resolving 

disagreements between partners, such as Brand USA and Commerce, can 

enable productive interactions and facilitate collaboration. View GAO-13-705. For more information, 

contact Timothy J. DiNapoli at (202) 512-3665 

or dinapolit@gao.gov.
Page i GAO-13-705 Travel Promotion

Letter 1

Background 3

Brand USA’s Global and Targeted Campaigns Promote 

International Travel throughout the United States 9

Brand USA Has Taken Steps to Monitor and Evaluate Its Program 

but Lacks a Plan for Measuring Its Long-Term Impact on Travel 

to the United States 15

Brand USA Established Policies Consistent with Applicable TPA 

Requirements, but Did Not Competitively Award a Key Contract 

and Lacks Formal Procedures for Revising In-kind Contributions 

Policy 20

Conclusions 35

Recommendations for Executive Action 36

Agency Comments and Our Evaluation 36

Appendix I Objectives, Scope and Methodology 38

Appendix II Brand USA In-kind Contributions Approved for Federal Matching 

Funds, Fiscal Year 2012 41

Appendix III Comments from Brand USA 43

Appendix IV GAO Contact and Staff Acknowledgments 44

Tables

Table 1: Results of Selected Brand USA Internet and Social Media 

Metrics 17

Table 2: Results of Surveys Evaluating Perceptions among 

Travelers in Canada, Japan, and the United Kingdom 

before and after Brand USA’s Targeted Campaign 

Launches, 2012 19

Table 3: Number and Value of Brand USA Purchases, by 

Procurement Method, November 2010–May 2013 24

Contents
Page ii GAO-13-705 Travel Promotion

Figures

Figure 1: Brand USA Organization 6

Figure 2: Locations of Brand USA’s Targeted Campaigns and 

Representative Offices 12

Figure 3: Overview of Procedures for Brand USA’s Submission of 

In-kind Contributions for Federal Matching Funds 29

Figure 4: Private Sector Donations of Cash and In-kind 

Contributions to Brand USA, Fiscal Year 2012 30

Figure 5: Brand USA’s Approved Submissions of In-kind 

Contributions, Fiscal Year 2012 31

Figure 6: Categories of In-kind Contributions to Brand USA, Fiscal 

Year 2012 32

Abbreviations

CEO Chief Executive Officer

DMO Destination Marketing Organization

FASB Financial Accounting Standards Board

OMB Office of Management and Budget 

TPA Travel Promotion Act

USTTA U.S. Travel and Tourism Administration 

USTTAB United States Travel and Tourism Advisory Board

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 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-705 Travel Promotion

441 G St. N.W.

Washington, DC 20548

July 25, 2013

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

Dear Mr. Thompson:

International travel and tourism to the United States are important to the 

U.S. economy. In 2012, 67 million international travelers visited the 

United States, spent a total of $168 billion, and supported 7.7 million jobs. 

However, from 2000 to 2010, the U.S. market share of total global 

spending by international travelers fell from 17 percent to 11 percent. 

Concern about this decline led Congress to explore efforts to reinvigorate 

international travel and tourism to the United States. The Travel 

Promotion Act of 2009 (TPA) established the Corporation for Travel 

Promotion, which conducts business as Brand USA, to create and 

execute a national coordinated travel promotion program.1

You asked that we review several aspects of Brand USA’s operations. 

This report (1) describes Brand USA’s programs and activities; (2) 

evaluates Brand USA’s efforts to measure program performance; and (3) 

examines the extent to which Brand USA established policies and 

procedures for personnel, procurement, and in-kind contributions 

consistent with TPA requirements.

Brand USA’s 

mission is to promote increased international leisure, business, and 

scholarly travel to the United States to help drive economic growth and 

job creation. Brand USA is not a federal agency but a nonprofit 

corporation that operates as a public-private marketing entity. Because 

TPA requires that both private and public sources fund the corporation, 

Brand USA receives private funding, through cash and in-kind 

contributions, as well as federal funds matching the private funding.

To describe Brand USA’s programs and activities, we reviewed Brand 

USA’s annual reports, strategic plans, and documentation outlining 

strategies and efforts to identify overseas markets for promotional 

 1

Pub. L. No. 111-145, § 9 (Mar. 4, 2010).
Page 2 GAO-13-705 Travel Promotion

campaigns and to promote specific U.S. travel destinations. We also 

interviewed its staff regarding the promotional activities that Brand USA 

has planned and undertaken. To evaluate Brand USA’s approach to 

measuring performance, we interviewed Brand USA staff and 

representatives of the firm contracted to evaluate the effectiveness of 

Brand USA’s promotional campaign in overseas markets. We also 

reviewed and assessed the reliability of Brand USA’s performance data 

and evaluations of its promotional campaign in targeted overseas 

markets. We assessed Brand USA’s performance measures against 

GAO’s and others’ evaluation standards.2 To examine the extent to which 

Brand USA established policies and procedures for personnel, 

procurement, and in-kind contributions consistent with TPA requirements, 

we reviewed and evaluated documentation outlining Brand USA’s 

personnel, procurement, and in-kind contributions policies and 

procedures and compared these policies with relevant laws and 

guidelines, including TPA, GAO standards for internal control in federal 

agencies,3

 2

GAO, Designing Evaluations, 2012 Revision, 

and generally accepted accounting standards. We also 

interviewed Brand USA staff and officials at the Department of 

Commerce’s (Commerce) International Trade Administration who are 

responsible for reviewing Brand USA’s requests for federal matching 

funds. In addition, we analyzed and assessed the reliability of the data 

and analyzed supporting documentation for Brand USA’s submissions of 

in-kind contributions for federal matching funds for fiscal year 2012 and 

analyzed the policy and procedures that Brand USA uses to value its 

private sector in-kind contributions. We interviewed representatives of 

Brand USA’s independent auditor and an independent accounting firm 

that verifies the corporation’s in-kind contribution valuations regarding 

their opinions of Brand USA’s policy and procedures, and we examined 

documentation of their review of its valuation of in-kind contributions. We 

also interviewed representatives of the firm contracted by Brand USA to 

develop methodologies for valuing in-kind contributions. Further, we 

reviewed documentation to determine the development and application of 

GAO-12-208G (Washington, D.C.: Jan. 31,

2012); Effectively Implementing the Government Performance and Results Act, 

GAO/GGD-96-118 (Washington, D.C.: June 1, 1996); GAO, Performance Measurement 

and Evaluation: Definitions and Relationships, GAO-11-646SP (Washington, D.C.: May 2,

2011); and American Evaluation Association, An Evaluation Roadmap for More Effective 

Government (Washington, D.C.: September 2010).

3

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

GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 15, 1999).
Page 3 GAO-13-705 Travel Promotion

these valuation methodologies and we interviewed academic experts in 

the field of media and marketing to obtain their opinions of these 

methodologies. We determined the data we obtained to be sufficiently 

reliable for the purposes of our review. Appendix I provides additional 

details of our scope and methodology.

We conducted this performance audit from November 2012 to July 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 the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The U.S. travel and tourism industry has gone through a series of 

declines and recoveries over the past decade. After a steep 3-year 

decline following the terrorist attacks of September 11, 2001, the number 

of international visitors to the United States generally increased by about 

6 percent annually from 2004 through 2012.4 However, from 2000 to 

2010, the U.S. market share of total global spending by international 

travelers fell from 17 percent to 11 percent. According to a report by the 

U.S. Travel Association—an advocacy organization for the U.S. travel 

industry—failure to maintain global market share in international travel 

cost the United States an estimated $606 billion in traveler spending and 

467,000 jobs.5

Federal efforts to promote travel and tourism to international travelers 

have varied over the years. In 1961, Commerce established the U.S. 

Travel and Tourism Administration (USTTA) to promote U.S. tourism to 

international travelers through coordinated advertising campaigns 

conducted by USTTA’s overseas offices. Congressional appropriations 

 4

During this period, international travel to the United States declined only in 2009.

5

U.S. Travel Association, Ready for Takeoff: A Plan to Create 1.3 million U.S. Jobs by 

Welcoming Millions of International Travelers, (Washington, D.C.: May 12, 2011).

Background

International Travel 

to the United States

Federal Travel 

Promotion Efforts
Page 4 GAO-13-705 Travel Promotion

for travel promotion increased until 1977, when Congress and the 

administration began reducing the government’s role in travel promotion. 

Continuous federal funding for travel promotion was eliminated in 1996, 

when Congress abolished USTTA.6

Following USTTA’s closure, the federal government has undertaken 

several efforts to promote tourism. For example, the United States 

National Tourism Organization Act of 1996 established the Interagency 

Tourism Policy Council. Chaired by the Secretary of Commerce, the 

council has responsibility for coordinating national policies and programs 

relating to international travel and tourism among 9 federal agencies 

through subcommittees that examine various travel-related topics. 

Additionally, the fiscal year 2003 Consolidated Appropriations Resolution 

established the United States Travel and Tourism Advisory Board 

(USTTAB). The USTTAB consists of up to 32 senior travel and tourism 

executives who advise the Secretary of Commerce on government 

policies and programs affecting the travel and tourism industry and 

propose solutions to industry-related current and emerging problems. For 

example, USTTAB advised Commerce about the development of tourism 

promotion programs in the United Kingdom and Japan in fiscal years 

2004 and 2005 and about the creation of a travel promotion website 

targeting key countries in fiscal year 2006.

TPA defines Brand USA’s purpose as being, in part, to execute a national 

travel promotion program to encourage travel to the United States and to 

provide equal international exposure for both rural and urban areas of the 

United States that lack the resources to promote themselves overseas.7

TPA required that Brand USA be governed by a Board of Directors, 

comprising 11 members who have knowledge and experience in 

international travel promotion and marketing. The Secretary of Commerce 

appoints the board’s members in consultation with the Secretaries of 

Conceived as a public-private partnership, Brand USA was incorporated 

as a nonprofit organization in Washington, D.C. in November 2010.

 6

The Omnibus Consolidated Rescissions and Appropriations Act of 1996 (Pub. L. No. 

104-134) did not include funding for USTTA, which closed in April 1996.

7

TPA also requires Brand USA to provide useful information to foreign tourists concerning 

entry requirements to the United States.

Brand USA Governance, 

Organization, and Funding
Page 5 GAO-13-705 Travel Promotion

Homeland Security and State. The board’s members broadly represent 

various regions of the United States as well as private and public travel 

and tourism sectors, including the lodging sector, city and state

conventions and visitors’ bureaus, small businesses, travel distributors, 

airlines, and others. The Board of Directors is responsible for appointing 

the corporation’s Chief Executive Officer (CEO) and other staff officers 

and approving its annual budget and policies, among other duties. Brand 

USA’s management apprises board members of the corporation’s general 

business activities, including personnel and procurement decisions, 

during monthly meetings that are open to the public. Board members 

discuss confidential personnel, commercial, and financial matters in 

closed meetings.

In addition, Brand USA’s Board of Directors and its advisory groups help 

the corporation plan its advertising programs and activities. For example, 

the board helps Brand USA establish its annual objectives each year and 

provides input into the selection of overseas markets for campaign 

activities and approves any expansion of the campaign into these 

markets. Brand USA’s three advisory groups, each comprising 

representatives from the travel and tourism industry, assist Brand USA 

and the board in planning its advertising activities.

• The Business Development Advisory Group offers ideas and 

suggests approaches for Brand USA’s partnership activities.

• The Global Insights Advisory Group provides expertise on the 

development of evaluations and metrics to measure the corporation’s 

performance.

• The Marketing Advisory Group assists with the selection of 

countries where Brand USA will expand its campaign. This group also 

conducts research to overcome challenges of marketing travel to 

certain overseas markets—for example, a lack of direct flights, which 

can help to attract foreign tourists to less-known and rural 

destinations.

The CEO has organized Brand USA staff into three teams responsible for 

meeting the corporation’s objectives in the areas of global marketing, 

communications, and business operations. The global marketing team is 

responsible for overseeing and coordinating the development and 

implementation of a marketing strategy designed to attract increased 

international travelers to the United States. The communications team is 

tasked with maintaining communications with stakeholders, including 
Page 6 GAO-13-705 Travel Promotion

Congress, the private sector, and the general public. The operations team 

is responsible for general administrative activities, including budget 

operations. As of June 2013, Brand USA staff consisted of 48 full-time 

employees in its office in Washington, D.C. Brand USA also relies on 

contractors and vendors in various other domestic locations and countries 

to carry out its business operations and complete its mission. Figure 1 

provides an overview of Brand USA’s organizational structure.

Figure 1: Brand USA Organization

TPA requires that Brand USA finance its efforts through a combination of 

public funds and private-sector cash and noncash, or “in-kind,”

contributions of goods and services, with in-kind contributions comprising 

no more than 80 percent of total private-sector contributions for any fiscal 

year. The source of Brand USA’s public funding is a TPA-established 

U.S. Treasury fund, known as the Travel Promotion Fund, which contains 

user fees from the Electronic System for Travel Authorization 
Page 7 GAO-13-705 Travel Promotion

administered by the Department of Homeland Security.8 For fiscal year 

2011, the Department of the Treasury (Treasury) made available $10 

million in funding for Brand USA’s initial expenses and activities, in 

accordance with TPA. For fiscal year 2012—the first year in which, 

according to TPA, Brand USA could obtain federal matching funds—

Brand USA received $100 million in public funding, the maximum amount 

provided by TPA, matching private-sector funding at a 2-to-1 ratio. For 

fiscal years 2013 through 2015, Brand USA may receive a maximum of 

$100 million annually, matching private-sector funding at a 1-to-1 ratio.

TPA assigned Commerce and Treasury responsibilities related to Brand 

USA’s operations. For example, Commerce’s responsibilities include, 

among other things, approving Brand USA’s annual objectives. In 

December 2010, Commerce, Treasury, and Brand USA signed a 

memorandum of understanding to confirm each entity’s roles and 

responsibilities related to implementing TPA requirements with regard to 

funding. Commerce is responsible for reviewing Brand USA’s requests for 

federal matching funds and the associated documentation of the 

corporation’s private-sector contributions, including the fair market value9

 8

The Department of Homeland Security collected approximately $111 million in these fees 

in fiscal year 2011 and approximately $121 million in fiscal year 2012. Currently, the fee is 

$14 for each foreign visitor traveling to the United States from countries participating in the 

U.S. Visa Waiver Program; $10 of this fee is available to fund Brand USA, while the 

remaining $4 is used to cover DHS’s costs of administering the system. The Visa Waiver 

Program allows eligible nationals from 37 member countries to travel to the United States 

for tourism or business for 90 days or less without a visa. The 37 countries currently 

participating in the Visa Waiver Program are Andorra, Australia, Austria, Belgium, Brunei, 

Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, 

Ireland, Italy, Japan, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Monaco, the 

Netherlands, New Zealand, Norway, Portugal, San Marino, Singapore, Slovak Republic, 

Slovenia, Republic of Korea, Spain, Sweden, Switzerland, Taiwan, and the United 

Kingdom. The United Kingdom only refers to British citizens who are unrestricted 

residents of England, Scotland, Wales, Northern Ireland, the Channel Islands, and the Isle 

of Man. Taiwan, designated consistent with the Taiwan Relations Act of 1979, refers to 

individuals who are unrestricted residents of Taiwan and have electronic passports 

bearing a personal identification number. 

of in-kind goods and services. Treasury maintains the Travel Promotion 

Fund and disburses federal matching funds to Brand USA. After 

9

Brand USA has adopted the Financial Accounting Standards Board definition of fair 

market value, and defines fair value as the price that property would sell for on the open 

market, agreed to between a willing buyer and a willing seller, with neither being required 

to act.

Responsibilities of 

Departments of 

Commerce and Treasury
Page 8 GAO-13-705 Travel Promotion

reviewing and approving Brand USA’s requests for matching funds and its 

valuations of in-kind contributions, Commerce directs Treasury to 

disburse the requested funds to Brand USA. 

In March 2012, we reported on the status of Brand USA’s establishment 

and the activities it had planned and undertaken to promote travel and 

tourism to the United States.10 We found that Brand USA was in the early 

stages of planning and was beginning to implement major programmatic 

activities to promote travel to the United States. We also found that Brand 

USA was not required to, and had not determined whether it would, adopt 

federal policies and procedures designed to facilitate program 

accountability and evaluation. We recommended that, as a good practice, 

Brand USA consider adopting federal policies and procedures, such as 

those outlined in Office of Management and Budget (OMB) circulars A11011 and A-133.12 In response to our recommendation, Brand USA 

stated that it was seeking a legal opinion regarding whether it is subject to 

federal regulations, including the OMB circulars.

 10GAO, Corporation for Travel Promotion: Establishment and Planned Programmatic 

Activities, GAO-12-485R (Washington, D.C.: Mar. 21, 2012).

11OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements 

with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations

(11/19/1993, as further amended 9/30/1999), codified at 2 CFR, Part 215. The circular 

sets forth standards for obtaining consistency and uniformity among federal agencies in 

the administration of grants to, and agreements with, institutions of higher education, 

hospitals, and other nonprofit organizations.

12OMB Circular A-133, Audits of States, Local Governments and Non-Profit Organizations

(includes revisions published in the Federal Register 6/27/2003 and 6/26/2007). This 

circular is issued pursuant to the Single Audit Act of 1984, Pub. L. No. 98-502 (Oct. 18, 

1984), and the Single Audit Act Amendments of 1996, Pub. L. No. 104-156 (Jul. 5, 1996). 

The circular sets forth standards for obtaining consistency and uniformity among federal 

agencies for the audit of states, local governments, and nonprofit organizations expending 

federal funds.

Prior GAO Findings and 

Recommendations 

regarding Brand USA
Page 9 GAO-13-705 Travel Promotion

Brand USA promotes international travel to all 50 states through its global 

campaign, which relies on media such as Internet, television, and 

billboard and print advertisements, as well as through targeted campaigns 

that promote U.S. tourism in selected overseas markets. To help 

coordinate these efforts, Brand USA contracts with firms that establish 

international representative offices to plan and coordinate programmatic 

activities in various countries, including some of the countries its 

campaign targets. Brand USA’s domestic and international partners, such 

as U.S. travel industry representatives, play a key role in helping the 

corporation promote travel to specific U.S. destinations and in 

establishing a presence in countries that the campaign does not target.

To promote foreign travel to the United States, Brand USA has developed 

a global promotional campaign that relies on Internet, television, billboard, 

and print advertisements as well as social media pages,13

www.discoveramerica.com

public relations, 

and trade events. As part of these efforts, Brand USA launched a 

promotional campaign in April 2012 to increase its online and social 

media presence to foreign travelers worldwide, including developing a 

website— —as an online informational and 

travel planning tool for foreign tourists and the Discover America Channel 

on YouTube. The website, which is available in English, French, 

Japanese, Korean, and Portuguese, provides travel information and trip 

suggestions for potential travelers.14

 13Social media pages include Facebook, Twitter, and Pinterest web pages along with 

country-specific developed social media pages. Pinterest is a content sharing service that 

also includes social networking features. 

The Discover America Channel

features videos highlighting a variety of U.S. travel experiences. In spring 

2012, Brand USA also developed global pages on Facebook, Twitter, and 

Pinterest as well as country-specific pages on Facebook and Twitter for 

Brazil, Canada, Japan, South Korea, and the United Kingdom. In addition, 

Brand USA has a presence on social media websites in Australia, China, 

Germany, and Mexico. Brand USA also relies on its presence at trade 

shows and events and on outreach to tour operators and travel agents. 

For example, in May 2013, Brand USA organized a promotional “MegaFamiliarization Tour” that showcased different parts of the United States 

for about 100 travel agents and tour operators from the United Kingdom 

and Ireland who book trips for travelers from these countries. Further, 

14Brand USA also has plans to develop country-specific websites for additional countries, 

including China.

Brand USA’s Global 

and Targeted 

Campaigns Promote 

International Travel 

throughout the 

United States

Brand USA’s Global 

Campaign Promotes 

Travel to All 50 States
Page 10 GAO-13-705 Travel Promotion

Brand USA communicates U.S. entry policies both on its website and 

through joint informational campaigns with Commerce and the 

Departments of State and Homeland Security. Brand USA also works 

with a number of federal agencies, including Commerce and the 

Departments of State, Interior, and Agriculture, on campaigns to promote 

federal lands and waterways.

As mandated by TPA, Brand USA has developed advertisements and 

media content to promote travel to all 50 states and the District of 

Columbia. For example, content on Brand USA’s website provides travel 

information on all 50 states, the District of Columbia, and five U.S. 

territories, and Brand USA’s social media pages cover different parts of 

the United States over the course of the year. The website markets 

specific events and experiences—focused, for example, on the outdoors, 

food and wine, and family travel—in various parts of the United States to 

indirectly market urban and rural areas, including those not traditionally 

visited by international travelers. For example, Brand USA’s website 

promotes “Frontier Days” in Cheyenne, Wyoming, and the “Country Music 

Highway” in Kentucky. According to Brand USA, it promotes less-known 

destinations in geographic proximity to those more popular with 

international travelers. For example, the Mega-Familiarization Tour that 

Brand USA organized for travel representatives offered seven different 

itineraries—for instance, “The Beautiful South,” featuring New Orleans, 

Atlanta, and Nashville, and “Meet the Midwest,” featuring Chicago, 

Milwaukee, and Minneapolis.

In addition to conducting its global campaign, Brand USA promotes U.S. 

tourism to travelers in specific countries through targeted campaigns that 

include strategically planned television, print, billboard, Internet, and 

social media advertisements, as well as partnership programs and trade 

shows and events. To select the overseas markets for its targeted 

campaigns, Brand USA relies primarily on six criteria: (1) annual volume 

of visitors; (2) total annual tourism revenue; (3) year-over-year growth in 

travel volume and tourism revenue; (4) cost of buying media in the 

country; (5) travelers’ ease of entry into the United States; and (6) 

infrastructure, including the availability of representative firms and social 

Brand USA’s Targeted 

Campaigns Focus on 

Specific Overseas Markets
Page 11 GAO-13-705 Travel Promotion

media in the country.15

When launching targeted campaigns in selected markets, Brand USA first 

establishes a social media and website presence in those markets. 

During the campaign launches, Brand USA concentrates its media 

spending so that an array of television, print, billboard, Internet, and social 

media advertisements are released during each country’s peak travel 

planning periods throughout the year. To support the campaigns, Brand 

USA’s international partners in the targeted market’s travel industry, such 

as hotels, airlines, and tour operators, also help promote travel through a 

variety of activities, including developing and contributing joint 

advertisements and planning travel events.

According to Commerce data, the overseas 

markets that Brand USA has targeted in fiscal year 2013 generated 

almost 49 million international travelers to the United States in 2011—78 

percent of international travel to the country that year.

Brand USA launched targeted campaigns in Canada, Japan, and the 

United Kingdom in 2012 and 2013 and plans launches in Australia, Brazil, 

China, Germany, Hong Kong, Mexico, South Korea, and Taiwan for 2013. 

For its fiscal year 2013 targeted campaign launches, Brand USA reports 

that as of April 30, 2013, it had spent $2.6 million on advertising in 

Canada, $2.0 million in Japan, and $8.5 million in the United Kingdom. To 

help coordinate and support its targeted campaigns, Brand USA contracts 

with firms overseas to establish and operate international representative 

offices in the countries where it has launched, or plans to launch, its 

 15According to Brand USA, ease of entry into the United States refers to an assessment of 

barriers to travel from the country to the United States, such as existing visa requirements, 

waiting period, and political climate. “Infrastructure” refers to Brand USA infrastructure in 

the country, including the presence of a representation firm, social media and website in 

the country and the presence and strength of trade and media support.
Page 12 GAO-13-705 Travel Promotion

campaigns.16

Figure 2: Locations of Brand USA’s Targeted Campaigns and Representative Offices

Figure 2 shows the locations of Brand USA’s current and 

planned targeted campaigns and its representative offices.

Note: Although the United States does not have diplomatic relations with Taiwan, we have listed it as 

a separate country in this report because whenever U.S. law refers or relates to foreign countries, 

nations, states, governments, or similar entities, such terms shall include and shall apply to Taiwan. 

Hong Kong is a special administrative region of China, but we have included it in this report as a 

 16As of June 2013, Brand USA’s overseas representative offices were located in London, 

covering the United Kingdom and Ireland; in Frankfurt, covering Germany, Austria, and 

Switzerland; in Tokyo, covering Japan; in Sydney, covering Australia and New Zealand; in 

Shanghai and Beijing, covering China; in Hong Kong, covering Hong Kong and Taiwan; in 

New Delhi, covering India; and in Seoul, covering South Korea. Brand USA plans for 

additional representative offices to cover Brazil and the rest of South America and for 

Canada, France, and Mexico in fiscal year 2013. To support the launches planned for 

Brazil and Canada, Brand USA has a trade representative in São Paulo, Brazil, and a 

contractor based in Chicago who focuses on establishing partnerships with the travel 

industry in Canada. 
Page 13 GAO-13-705 Travel Promotion

separate country because it is an economic entity separate from the rest of China and is able to enter 

into international agreements on its own behalf in commercial and economic matters.

According to Brand USA, it selects international representative firms 

through a competitive bidding process. Brand USA outlines each office’s 

scope of work, which generally includes, among other things, developing 

and executing a marketing plan for the country and coordinating and 

conducting promotional activities, market research, public relations, and 

some media buying. The marketing plan that each office develops lays 

out the country-specific strategies and the promotional programs and 

activities that the office will help coordinate and implement. The offices’

defined scopes of work also include responsibilities for developing and 

maintaining partnerships with key members of the travel industry 

overseas, including travel agents and airlines, among others. According 

to Brand USA, developing partnerships is an important role of these 

offices. For example, an international representative office might identify 

partners in the country who are interested in donating advertising space 

for Brand USA’s campaign or a trade show booth to showcase Brand 

USA.

Brand USA’s domestic and international partners play an important role in 

helping the corporation to promote travel to the United States and 

establish a campaign presence overseas, particularly in countries that 

Brand USA has not selected for its targeted campaigns. These partners 

include representatives of the travel industry, such as state and local 

destination marketing organizations (DMO),17

Brand USA has developed a number of programs that allow partners to 

work with the corporation to develop or contribute print, Internet, 

television, and billboard advertisements to promote travel to the United 

States. For example, Brand USA’s partners, including travel publications 

and travel industry websites, have donated print, television, or Internet 

hotels, airlines, and travel 

websites. According to Brand USA, as of May 2013, it had developed 

partnerships with 280 domestic and international entities in the private 

travel sector, including DMOs.

 17DMOs are usually funded primarily by the private travel sector and promote travel to 

specific states, cities, and local destinations in the United States. For example, Visit 

California is a state DMO that works to promote travel to California.

Brand USA’s Domestic and 

International Partners 

Help It Promote Travel to 

Specific U.S. Destinations 

and Establish a Presence 

Outside Targeted Markets
Page 14 GAO-13-705 Travel Promotion

advertising space to Brand USA. Partners may also work with Brand USA 

through joint media buying, e-mail campaigns, and trade and travel 

events, among other promotional activities. For example, British Airways 

donated flights for the Mega-Familiarization Tour that it organized for 

travel agents and tour operators from the United Kingdom and Ireland. 

One of Brand USA’s partnership programs coordinates media buying and 

overseas marketing by Brand USA and DMOs and other travel sector 

partners. Through this program, the partners provide a cash contribution 

to Brand USA, which it uses for media purchases and other advertising 

efforts to promote the United States along with a specific U.S. destination 

or brand. Along with using a partner’s cash contribution, Brand USA might 

provide an additional investment to help promote a specific destination 

supported by the partner, allowing greater exposure for the destination 

than if the partner had independently funded its own media purchases. 

For example, the Louisiana Office of Tourism provided a cash 

contribution to Brand USA, which, in turn, developed and executed a 

digital and print advertising campaign to promote both the United States 

and New Orleans. According to Brand USA, as of May 2013, at least 20 

local and state DMOs and 10 brands had made use of this program.

International and domestic partners’ donations of advertising space and 

their market expertise help support Brand USA’s marketing and trade 

activities, according to Brand USA staff. In particular, state and local DMO 

partners’ donations of cooperative advertising—that is, advertising with 

marketing objectives shared by Brand USA and one or more partners—

help support Brand USA’s efforts to promote U.S. destinations and extend 

the overseas presence of the campaign’s advertisements. For example, 

the DMO Coastal South Carolina included Brand USA’s logo on its 

billboard advertisements in London promoting travel to Charleston, South 

Carolina—a destination that might not be familiar to some British 

travelers—and Brand USA has worked with Visit California and Air New 

Zealand to develop advertisements that promote flights and travel to 

California. As of April 2013, Brand USA had received donated advertising 

space from at least 55 partners. In addition to supporting Brand USA’s 

campaign via donated advertising space, its DMO partners provide 

information on promoting aspects of specific less-known U.S. 

destinations, while its international partners help determine the types of 

places that will appeal to visitors from specific countries. Brand USA’s 

partners also help determine the countries, other than those targeted for 

Brand USA’s campaigns, where the corporation’s advertisements will 

appear. For example, New York City’s DMO donated advertising by 

including the Brand USA logo on its billboard advertisements in Italy, 

which Brand USA has not targeted for a campaign.
Page 15 GAO-13-705 Travel Promotion

Brand USA has outlined its performance goals, such as increasing the 

number of traveler visits and spending, but it has not yet fully developed a 

plan laying out the specific timeframes, evaluation methodologies, and 

data sources it will use to monitor and evaluate the campaign’s results 

and long-term effects on travel. Brand USA has developed metrics to

monitor its Internet and social media activity, which indicate increasing 

awareness of Brand USA’s efforts. Further, Brand USA’s evaluations of 

its campaign’s effect on traveler perceptions found a positive impact. 

Although these metrics and evaluations allow Brand USA to track online 

activity and specific campaigns in targeted overseas markets and may 

serve as interim measures, they do not measure Brand USA’s progress in 

achieving its key long-term goals of increased traveler visits to, and 

spending in, the United States.

Brand USA has outlined a number of performance goals, such as 

increasing travel to, and travel-related spending in, the United States; 

increasing travelers’ intent to travel to the United States; and increasing 

activity on Brand USA’s Internet and social media websites.18 However, 

Brand USA has not yet developed a plan for measuring performance that 

clearly identifies the specific timeframes, methodologies, and data 

sources it will use to monitor and evaluate results and progress toward its 

long-term mission and campaign goals of increased traveler visits and 

spending. The GPRA Modernization Act of 2010 requires that federal 

agencies develop annual performance plans that include performance 

goals and performance measures that are tied to these goals.19 Although 

Brand USA is not subject to these requirements, such a plan can, as a 

best practice, provide strategies for measuring performance that inform 

critical program management and budget decisions. Such a plan can also 

identify methods for periodically and systematically evaluating how well a 

program is working or how to improve it.20

 18Brand USA’s fiscal year 2013 marketing plan lists 12 goals. Some of these goals, for 

example, relate to increased travel to the United States, Internet and social media activity,

traveler perceptions in overseas markets, generating cash and in-kind contributions, and 

expanding Brand USA’s presence at trade shows.

Moreover, a well-developed 

19Pub. L. No. 111-352 (Jan. 4, 2011). The act updates the Government Performance and 

Results Act of 1993 (GPRA) (Pub. L. No. 103-62). See also GAO/GGD-96-118. 

20American Evaluation Association, An Evaluation Roadmap for More Effective 

Government, (Washington, D.C.: Sept. 2010); and GAO-11-646SP. 

Brand USA Has Taken 

Steps to Monitor and 

Evaluate Its Program 

but Lacks a Plan for 

Measuring Its LongTerm Impact on 

Travel to the United 

States

Brand USA Has Not Yet 

Developed a Performance 

Plan for Measuring 

Its Campaign’s Long-Term 

Impact 

on Traveler Visits 

and Spending
Page 16 GAO-13-705 Travel Promotion

performance plan can, among other things, help an organization to 

develop evaluations for use in monitoring and reporting on program 

performance relative to pre-established goals and assessing whether 

existing programs are still needed or effective.21

Brand USA staff noted that, because of the numerous factors that affect 

international travel, it would be difficult to isolate the impact of the 

corporation’s activities to demonstrate the extent to which the global 

campaign has directly led to increased travel to the United States. The 

corporation, however, has begun to develop a plan to measure its 

performance. For example, according to Brand USA staff, the recent 

hiring of a director responsible for, among other things, developing and 

executing an ongoing metrics and evaluation program could lead to the 

development of such a plan by 2014. As of July 2013, Brand USA has 

outlined some metrics and general methodologies, such as tracking visits 

and spending from travelers from overseas markets, that it plans to use to 

assess progress towards its goals. Brand USA has also outlined general 

timelines for some of these metrics, including the dates it plans to begin 

collecting data and plans to provide monthly, semi-annual, or annual 

reports on its metrics. However, Brand USA has not identified the specific 

timeframes, methodologies, and data sources it will use to measure the 

impact of its campaign on traveler visits and spending.

Without a performance 

plan, Brand USA is missing opportunities to collect data that it could use 

to optimize its media and advertising spending and to demonstrate the 

long-term effectiveness of its campaign.

Metrics that Brand USA uses to monitor user activity on its global Internet 

and social media activity websites indicate growth in Brand USA’s online 

exposure. The metrics track online activity, such as views of Brand USA’s 

website, views of its Discover America Channel on YouTube, downloads 

of its Land of Dreams song, and activity on its social media pages.22

 21

To 

compile results for these metrics, Brand USA collects data for the global 

Internet metrics, and works with a U.S. advertising firm whose overseas 

GAO-12-208G and American Evaluation Association, An Evaluation Roadmap for More 

Effective Government.

22Brand USA collects data on activity on its Facebook, Twitter, and other country-specific 

social media pages. These data include, among others, numbers of Facebook “fans,”

“likes,” “shares,” and “comments” and numbers of Twitter “followers,” “tweets,” “retweets,”

and mentions.

Brand USA’s Metrics 

Measure Online Exposure
Page 17 GAO-13-705 Travel Promotion

staff collect data for the country-specific social media metrics. Brand USA 

then consolidates these results in one data system for analysis. The 

metrics show increases in online activity on Brand USA’s website, social 

media pages, and YouTube channel after the Brand USA campaign was 

launched (see table 1). For example, Brand USA reported that its website 

had more than 467,000 page views in June 2013, compared with about 

77,000 page views in April 2012. Brand USA issues monthly social media 

reports that include information about its social media activity, including 

the Facebook and Twitter posts that have attracted the most attention 

globally and in some of its targeted markets.23

Table 1: Results of Selected Brand USA Internet and Social Media Metrics

These reports also provide 

recommendations on ways that Brand USA can enhance its social media 

strategy to better promote travel to the United States. 

Description of 

performance metric Type of metric Goal Results reported by Brand USA

Number of 

www.discoveramerica.coma Global internet

page views

Not specified 467,000 in June 2013 vs. 77,201 in April 2012 

Number of Discover America 

Channel views on YouTube

Global internet a Not specified 1,376,000 from April 1, 2012 to July 11, 2013

Number of downloads of Brand 

USA’s Land of Dreams song

Global internet a Not specified 27,000 as of July 2013

Number of Brand USA 

Facebook fans

Global social 

media

Increase by 

15% annually 

2,005,000 as of July 11, 2013 vs. 78,672 as of 

September 2012

Number of Brand USA 

Twitter followers

Global social 

media

Increase by 

15% annually

42,000 followers as of July 11, 2013 vs. 8,469 as of 

September 2012

Source: GAO review of Brand USA documents.

Note: The table shows metrics described in Brand USA’s fiscal year 2013 marketing plan that relate 

to online activity. We included only metrics for which we could assess the data’s reliability. Brand 

USA also reported that 99 percent of sentiments expressed by users on its social media web pages 

were positive; however, we could not verify the reliability of these data.

a Brand USA developed www.discoveramerica.com, the Discover America Channel on YouTube, and 

the Land of Dreams song as part of its global advertising campaign.

 23In addition to providing information about Brand USA’s global social media activity, 

these reports provide information about its social media activity for Brazil, Canada, Japan, 

South Korea, and the United Kingdom.
Page 18 GAO-13-705 Travel Promotion

Brand USA contracted with a market research firm to conduct evaluations 

of its targeted campaigns’ effects on travelers’ perceptions in markets 

where it launched these campaigns in 2012—Canada, Japan, and the 

United Kingdom. The evaluations used online surveys to track changes in 

travelers’ awareness of the campaign, intent to travel to the United 

States, and perceptions of the United States, among other factors.24

According to the market research firm, it developed the survey questions 

in collaboration with Brand USA and another contracted firm. The market 

research firm chose the survey respondents from a pool of individuals 

whom it had recruited to participate in market research panels and who, 

according to demographic criteria, had a strong likelihood of travelling to 

the United States.25 Online links to the surveys were sent in an e-mail to 

respondents both before and after the campaigns were launched, to 

identify any shifts in traveler perceptions following the launches.26

 24The firm contracted by Brand USA to evaluate its promotional campaigns plans to 

conduct additional evaluations of travelers in the three markets where Brand USA initially 

launched its campaign in 2012 and in the eight new markets where Brand USA plans to 

launch its campaign in 2013. 

According to Brand USA, the survey results suggested that the campaign 

had a positive impact on intent to visit the United States and led to 

positive shifts in perceptions of the United States among respondents. In 

addition, more than 25 percent of post-launch survey respondents 

reported that they were aware of Brand USA’s campaign in each of the 

three markets, exceeding the target of 15 percent for each country (see 

table 2). However, the survey results are not generalizable and the 

25The market research firm selected these respondents to meet its survey definition of 

“global affluent travelers,” on the basis of the following demographic criteria: (1) 25 years 

or older, (2) top 25 percent of household income within respective country, (3) traveled 

within the past year and plans to travel within the next 2 years, and (4) willing to travel to 

the United States. The survey relied on databases of respondents created by the market 

research firm. In accordance with a standard advertising survey methodology that it 

employed, the firm selected different respondents for the surveys that it sent before and 

after the campaign launches. 

26The surveys sent before the campaign launches were designed to reach about 300 

potential travelers from each of the three countries, while the surveys sent after the 

campaign launches were designed to reach about 400 potential travelers from each 

country. The pre-campaign-launch surveys had 311 Canadian respondents, 307 

Japanese respondents, and 304 United Kingdom respondents. The post-campaign-launch 

surveys had 403 Canadian respondents, 400 Japanese respondents, and 408 United 

Kingdom respondents.

Evaluations Show Brand 

USA Campaigns’ Effect 

on Traveler Intentions 

but Do Not Measure 

Impact on Travel
Page 19 GAO-13-705 Travel Promotion

analysis did not take into account other factors that might have influenced 

perceptions of the United States.27

Table 2: Results of Surveys Evaluating Perceptions among Travelers in Canada, Japan, and the United Kingdom before and 

after Brand USA’s Targeted Campaign Launches, 2012

Description of

performance metric Goal Results reported by Brand USA

Travelers’ awareness of 

Brand USA campaign

Raise campaign awareness 

levels to 15% 

More than 25% awareness among survey respondents considered to 

be potential travelers in all three countries.

Travelers’ intent to travel 

to the United States

Increase intent to travel to 

the United States by 5% 

Respondents to the post-launch surveys in Canada reported an intent 

to travel to the United States that was 22% higher than that reported by 

respondents to the pre-campaign launch surveys.

Respondents to the post-launch surveys in Japan and in the United 

Kingdom reported an intent to travel to the United States that was 14% 

higher than that reported by respondents to the pre-campaign launch 

surveys. 

Travelers’ perceptions 

of the United States

Improve awareness and 

perceptions of the United 

States by 3 points or more

Respondents to the post-launch surveys reported levels of awareness 

and perceptions of the United States that were 4%-15% higher than 

those reported by respondents to the pre-launch surveys.

Source: GAO review of Brand USA documents.

Notes:

The results shown are based on surveys of potential travelers in Canada, Japan, and the United 

Kingdom in 2012. The surveys were sent to the respondents both before and after Brand USA’s 

campaign launches in those countries. Brand USA has outlined goals for additional countries where it 

plans to launch its campaign in 2013. According to Brand USA, it will report results for these goals

after launching the campaigns.

The table shows metrics described in Brand USA’s fiscal year 2013 marketing plan that related to the 

promotional campaign in targeted markets. We included only metrics for which we could assess the 

reliability of the data.

Although these evaluations indicate progress in targeted markets against 

some of Brand USA’s stated goals, the evaluations were not designed to 

provide information on Brand USA’s progress in achieving its primary 

objectives—increased travel to, and travel-related spending in, the United 

States. The results observed in the evaluations could have occurred in 

response to external influences, such as economic conditions or currency 

exchange rates, rather than in response to the Brand USA campaign. 

Additionally, the evaluation results are specific to the respondents in the 

 27Compared with pre-campaign launch results, traveler intent to visit increased by 14 

percent in Japan and the United Kingdom, and 22 percent in Canada following the launch 

of the campaigns.
Page 20 GAO-13-705 Travel Promotion

three targeted markets only at one point in time. Furthermore, the 

evaluations focused on perceptions of intent to travel to the United States 

and did not include an analysis of data measuring actual travel and travelrelated economic activity. Brand USA staff and the market research firm 

that conducted the surveys noted that developing an evaluation that 

would measure Brand USA’s targeted campaigns’ direct impact on 

traveler visits and spending would be a complex and lengthy endeavor. 

According to Brand USA staff, the corporation is currently considering 

methods to better measure its campaigns’ impact on travel, but as a 

newly formed organization, it has not yet had sufficient opportunity to do 

so.

Brand USA has established policies and procedures governing personnel, 

procurement, and in-kind contributions, which are consistent with

applicable TPA requirements. Brand USA’s personnel policies and 

procedures address issues such as equal employment opportunity and 

nondiscrimination, requesting employee accommodations, and reporting 

grievances, while its procurement policy generally requires competitive 

procurements of goods and services, among other elements. However, 

Brand USA did not competitively solicit bids for the media consulting firm 

that helped develop valuation methodologies for certain types of in-kind 

contributions. Brand USA’s policy governing in-kind contributions is 

consistent with TPA requirements, but Brand USA has not established 

and documented formal procedures with Commerce and Treasury 

specifying the timeframes and conditions for agreeing to revisions to the 

policy or for resolving differences between stakeholders. For example, 

although the in-kind policy allows Brand USA to submit requests for 

matching funds for in-kind contributions of certain types of media and 

uncompensated board member travel and staff time expenses, 

Commerce questioned whether these types of contributions qualified for 

federal matching funds. In turn, Brand USA returned approximately $1.1 

million in previously provided federal matching funds but reserved the 

right to resubmit these and similar contributions in the future.

Brand USA 

Established Policies

Consistent with 

Applicable TPA 

Requirements, but Did 

Not Competitively 

Award a Key Contract 

and Lacks Formal 

Procedures for 

Revising In-kind 

Contributions Policy
Page 21 GAO-13-705 Travel Promotion

TPA allows Brand USA to hire and set the compensation of its employees 

as necessary to carry out its purposes and prohibits Brand USA from 

using political qualifications to hire or take other personnel actions 

involving its employees.28 Brand USA’s personnel policy, established in 

the summer of 2012 with the assistance of its law firm and an external 

consultant, sets its standard for hiring and employment; outlines the laws 

applicable to its hiring and employment practices; and states its policies 

and procedures for promoting equal employment opportunity and 

nondiscrimination, requesting employee accommodations, and reporting 

grievances. The policy states that the corporation will comply with federal, 

state, and local laws pertaining to nondiscrimination and anti-harassment, 

immigration, substance abuse, and disability accommodation.29

Brand USA’s personnel policy is undergoing further development as part 

of a review of the corporation’s human capital management by a human 

capital consulting firm, according to Brand USA staff. The review is 

expected to lead to the development of comprehensive strategies for 

Brand USA’s recruitment and hiring of staff and for its employee appraisal 

and compensation practices. For example, the firm is expected to 

recommend processes for conducting pre-employment screenings and 

For 

example, with regard to equal opportunity and nondiscrimination, the 

policy details characteristics protected by applicable laws, such as age, 

race, religion, sex, national origin, and disability. The policy also notes 

that these protected characteristics apply to hiring, promotion, and 

termination. The policy also details the circumstances that would 

constitute discrimination and harassment as well as the conditions under 

which employees may receive disability and religious accommodations. In 

addition, the policy details procedures for reporting and resolving 

discriminatory or harassing treatment and for requesting 

accommodations. We found these policies to be consistent with TPA’s 

requirements.

 2822 U.S.C. § 2131(b)(3).

29According to Brand USA’s personnel policy, these nondiscrimination and antiharassment federal laws include the Age Discrimination in Employment Act of 1967 (Pub. 

L. No. 90-202, Dec. 15, 1967) and Title VII of the Civil Rights Act of 1964 (Pub. L. No. 88-

352, Jul. 2, 1964). Pertinent immigration, substance abuse, and disability accommodation 

federal laws include the Immigration Reform and Control Act of 1986 (Pub. L. No. 99-603, 

Nov. 6, 1986), the Drug Free Workplace Act of 1988 (Pub. L. No. 100-690, Nov. 18, 

1988), and Title I and Title V of the Americans with Disabilities Act of 1990, as amended 

(Pub. L. No. 101-336, Jul. 26, 1990), respectively.

Brand USA’s Personnel 

Policy Addresses Key 

Issues, Including Equal 

Opportunity and 

Nondiscrimination Issues
Page 22 GAO-13-705 Travel Promotion

implementing background checks. In addition, the firm is expected to 

develop policies and procedures for evaluating staff performance and to 

determine equitable and competitive compensation. In April 2013, the firm 

signed a master service agreement to begin the review, which Brand USA 

expects will be completed within 1 year.

TPA authorizes Brand USA to obtain grants and to enter into contracts to 

carry out its purposes but does not require Brand USA to follow federal 

procurement laws and does not prescribe specific procurement 

processes. TPA also requires Brand USA to be accountable for its funds 

by requiring Brand USA to submit its objectives and budget to Commerce 

for review and to submit an annual report to Congress on its operations, 

finances, obligations, and in-kind contributions, among other 

information.30

 3022 U.S.C. § 2131(b)(5)(B)(ii) and 22 U.S.C. § 2131(c).

Brand USA established its procurement policy in the 

summer 2012, which outlines the methods that the corporation may use 

to purchase goods and vendor services and generally requires 

competitive bidding. The policy specifies procedures for three methods of 

procurement—small purchases, competitive procurements, and 

noncompetitive procurements. For purchases of $25,000 or less, the 

policy requires three documented quotes or pricing, and if such 

documentation of pricing cannot be obtained, Brand USA requires a 

memorandum documenting the dates when calls were made, the parties 

contacted, and the prices obtained. For purchases totaling $25,000 or 

more, the policy requires competitive procurements and establishes the 

process for soliciting, evaluating, and awarding contracts. For example, 

requests for proposals, including a description of the goods or services 

needed and the factors used to evaluate competing proposals, must be 

solicited for these purchases. In addition, the policy requires that 

contracts be awarded to the bidder whose proposal is responsive to the 

solicitation and most advantageous in terms of price and quality. Brand 

USA allows noncompetitive procurement for advertising and media that 

support its programmatic activities. Brand USA also allows 

noncompetitive procurement under certain circumstances, such as for 

emergency needs or if the service may be procured from only one source, 

provided that the justification for the purchase is documented and the 

corporation’s officers approve.

Brand USA Procurement 

Policy Generally Requires 

Competition, but Brand 

USA Did Not Adhere to Its 

Policy When Selecting 

Media Consulting Firm
Page 23 GAO-13-705 Travel Promotion

In March 2012, before establishing the policy, Brand USA contracted with 

external legal counsel to conduct an analysis of applicable legal 

requirements, including an analysis of the OMB federal guidelines 

pertaining to the cost principles and restrictions that apply under the 

corporation’s agreements and contracts. According to Brand USA staff, 

the corporation undertook the legal determination in response to our 

March 2012 recommendation that, as a good practice, Brand USA should 

consider adopting federal policies and procedures, such as OMB circulars 

to the extent possible, for use in carrying out the corporation’s programs 

and activities. The external legal counsel concluded that the OMB circular 

guidelines do not apply to the corporation.31

Brand USA staff stated that although the corporation is not legally 

required to comply with OMB circular procurement guidelines, its policy 

generally reflects the principles in OMB circular A-110.32

 31According to the independent auditor that prepared the corporation’s fiscal year 2012 

financial statement, compliance with the OMB circulars would likely not uncover 

deficiencies in internal control that would not normally be uncovered during the course of 

the financial audit. Nevertheless, the independent auditor stated that Brand USA’s 

compliance with the OMB circulars would help ensure that the corporation’s transactions 

and business operations are transparent and in line with other nonprofit organizations 

receiving federal funds. 

For example, in 

setting criteria for purchases requiring competitive procurement, Brand

USA’s procurement policy defines a minimum dollar amount that is 

consistent with the circular. However, Brand USA staff also said that the 

OMB circular’s competitive procurement guidelines do not provide the 

flexibility that is necessary for purchases related to promotional activities 

in overseas markets. According to Brand USA staff, the corporation often 

requires the flexibility to quickly respond to opportunities to promote travel 

to the United States through its purchases of advertising and media 

services and of trade show sponsorships in foreign countries, which the 

length of time needed to conduct competitive bidding may hinder. Brand 

USA staff noted that although the corporation usually does not undertake 

a formal competitive procurement process for such purchases, the 

corporation’s staff assess whether any prospective purchase of 

advertising or media will further the corporation’s mission, and they 

negotiate, to the extent possible, the purchase terms with the media 

owners.

32OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements 

with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations

(11/19/1993 as further amended 9/30/1999), codified at 2 C.F.R., Part 215.
Page 24 GAO-13-705 Travel Promotion

Brand USA used competitive procurements for the majority of its 

purchases from November 2010, when it was established, through May 

2013 (see table 3). Competitive procurements comprised 64 percent of 

the total value of Brand USA’s procurements, and noncompetitive 

procurements comprised 35 percent. According to Brand USA staff, the 

corporation used noncompetitive procurements for overseas advertising 

and promotional media and for sponsorships for trade shows.

Table 3: Number and Value of Brand USA Purchases, by Procurement Method, November 2010–May 2013

Dollars in millions

Procurement method

Number of 

procurements

Percentage of total 

procurements Value

Percentage of total 

procurements’ value

Small purchases 91 37% $1.2 1%

Competitive procurements 41 17 55.4 64

Noncompetitive procurements 116 47 30.2 35

Total 248 100% $86.8 a 100%

Source: GAO analysis of Brand USA data.

a

Percentages do not sum to 100 because of rounding.

However, contrary to its procurement policy, Brand USA did not use a 

competitive procurement process to select the media consulting firm that 

assisted the corporation, Commerce, and Treasury in developing

methodologies for valuing in-kind contributions. In this case, Commerce 

had requested that Brand USA identify a qualified media consulting firm 

to develop valuation methodologies for contributions of cooperative 

advertising and trade show sponsorships because there was no set 

standard for the methods used to estimate the fair market value of these 

contributions, according to Commerce officials. These officials noted that 

Commerce and Treasury officials lacked the necessary expertise to assist 

the corporation in determining the fair market value for these types of inkind contributions. Brand USA, Commerce, and Treasury reviewed 

multiple methodologies that the media consulting firm proposed before

they accepted the valuation methodologies for cooperative advertising 

and trade show sponsorships, according to Commerce officials and Brand 

USA staff. Brand USA staff noted that because the corporation expected 

to receive a significant number of contributions of cooperative advertising 

and trade show sponsorship, the corporation believed it was important to 

quickly develop valuation methodologies that Commerce would approve.
Page 25 GAO-13-705 Travel Promotion

Brand USA finalized its contract with the media consulting firm in January 

2013 but did not follow a competitive procurement process to select the 

firm. Brand USA’s 1-year contract with the firm, valued at $384,000, 

exceeded the $25,000 minimum set by its procurement policy, which 

requires that the corporation either issue a request for proposal to solicit 

bids from multiple vendors or document the circumstances and approval 

for a noncompetitive procurement. According to Brand USA staff, the 

corporation did not follow these processes but instead, in consultation 

with Commerce and Treasury, selected the firm on the basis of an 

internal recommendation and a review of the firm’s past work with other 

clients. Brand USA staff stated that they plan to issue a request for 

proposal, in accordance with the procurement policy, when the contract 

expires in December 2013.33

Brand USA and Commerce revised the in-kind contributions policy to 

include the valuation methodologies for estimating Brand USA’s portion of 

the fair market value of in-kind contributions of cooperative advertising 

and for valuing contributions of trade show sponsorships recommended 

by the consulting firm. The methodology for valuing cooperative 

advertising assigns value to Brand USA’s share of donated advertising 

space on the basis of the prominence of the corporation’s message in the 

advertisement. For example, the media consulting firm uses estimates of 

the fair market value of the advertisement provided by the donor in the 

form of billboards, posters, or other media and the prominence of Brand 

USA’s message in that advertisement. The media consulting firm then 

weights the total value of the advertisement in set percentages reflecting 

whether Brand USA’s relevance in the advertisement is prominent,

 33The contract allows Brand USA and the media consulting firm to discuss a possible 

extension of the contract based on mutual agreement once the contract expires. 
Page 26 GAO-13-705 Travel Promotion

moderate, or shared.34 The methodology for valuing trade show 

sponsorships uses weighted categories to estimate Brand USA’s share of 

the total value of the donor’s investment in the trade show event.35

Experts in the field of media valuation with whom we spoke stated that 

the media consulting firm’s valuation methodologies are reasonable, but 

they noted that alternative methodologies developed by other firms could 

provide a more accurate estimate of the values of Brand USA’s in-kind 

contributions of cooperative advertising and trade show sponsorships. For 

example, these experts cited examples of methodologies that could more 

accurately value Brand USA’s share of cooperative advertising space by 

calculating the actual percentage of the space Brand USA occupied and 

the specific placement of its message in the advertisement, rather than by 

using—as the current method does—a set percentage of the total value 

of the cooperative advertising space.

 34The in-kind contributions policy includes examples of representative advertisements 

showing prominent, moderate, and shared placement and the applied weighting. 

Prominent placement means that Brand USA’s message has significant exposure and 

relevance to the advertisement’s message. For prominent placement, Brand USA is 

assigned a set 65 percent of the total value of the advertisement. Moderate placement 

means that Brand USA has subtle exposure and the advertisement’s message is not 

specific to any single brand. For moderate placement, Brand USA is assigned a set value 

of 40 percent of the total value. Shared placement means that Brand USA has minimal 

exposure in a secondary location within the advertisement. For shared placement, Brand 

USA is assigned a set value of 25 percent of the total value. If the advertisement includes 

five or more partners, Brand USA determines the fair market value attributable to the 

corporation by dividing the total value of the advertising space by the total number of 

partners.

35The scorecard methodology includes four major weighted categories—brand 

awareness, business building, target audience, and competitive environment—to measure 

the value to Brand USA of the donor’s investment in the trade show. Each of the four 

major categories is further divided into several subcategories, which are also weighted. 

The media consulting firm selected the categories and weights on the basis of its 

understanding of Brand USA’s business objectives for trade show participation.
Page 27 GAO-13-705 Travel Promotion

Brand USA and Commerce, in collaboration with Treasury, have

developed an in-kind contributions policy consistent with TPA 

requirements that includes guidelines regarding private sector in-kind 

contributions as well as cash contributions to be submitted for federal 

matching funds. In coordination with Commerce and Treasury, Brand 

USA has revised this policy several times since it was drafted in 

November 2011, to address new types of in-kind contributions eligible for 

federal matching funds. However, Brand USA has not established formal, 

documented procedures with Commerce and Treasury specifying the 

time frames and conditions for making and agreeing to such revisions or 

for resolving differences with regard to the policy.

Under TPA, Brand USA may meet the matching requirement for federal 

funding by submitting the fair market value of contributed goods and 

services.36 In November 2011, Brand USA, in collaboration with 

Commerce and Treasury, developed a policy that sets guidelines for 

determining the types of in-kind contributions that are eligible for federal 

matching funds and the procedures for determining the contributions’ fair 

market values.37

 36TPA requires Brand USA to provide matching funds from nonfederal sources for funds 

that are provided to Brand USA from the Travel Promotion Fund. 22 U.S.C. § 2131(d)(3). 

These matching funds from nonfederal sources are provided to Brand USA as either cash 

or in-kind contributions. TPA does not prescribe a method for determining fair market 

value. Brand USA states that it adheres to fair value measurements under Financial 

Accounting Standards Board guidelines for the in-kind contributions it submits for federal 

matching funds.

The policy states that Brand USA may accept a variety 

of in-kind contributions, including donations of services, supplies, 

equipment, office space, and media and advertising. In general, the policy 

specifies that the donor will provide an invoice or proof of payment, when 

available, for the good or service as proof of the fair market value. The 

policy also includes procedures for measuring the fair market value, 

particularly for contributions that have no supporting invoices, have 

limited or no pricing information, or represent only a portion of the goods 

or services’ total value. For example, for donations of media, 

advertisements, trade show participation, and promotional videos and 

photographs, the policy states that the donor may lack invoices or pricing 

information for the contribution. For these cases, the policy specifies the 

37The in-kind contributions policy also includes guidelines for the submission of cash 

contributions that are eligible for federal matching funds.

Brand USA and Commerce 

Have Established 

an In-kind Contributions 

Policy but Brand USA Has

Not Formalized 

Procedures for Making 

Future Revisions or 

Resolving Differences

Brand USA and Commerce 

Have Developed a Policy for 

Valuing In-kind Contributions 

for Federal Matching Funds,

and Brand USA Has Submitted 

Contributions for Approval
Page 28 GAO-13-705 Travel Promotion

methods that Brand USA will use to calculate the contribution’s fair 

market value to the corporation.

To receive federal matching funds, Brand USA accounts for the fair 

market value of contributed goods and services using the procedures 

outlined in the policy. When the corporation receives an in-kind 

contribution, it collects supporting documentation from the donor to 

determine the value in accordance with the policy. For each submission 

for federal matching funds, an independent accountant reviews the 

supporting documentation and verifies the corporation’s valuations to help 

ensure that they align with the in-kind contributions policy. The 

accountant submits a report documenting the procedures performed and 

the related findings of its review. Brand USA staff resolve any findings 

detailed in the independent accountant’s report and include the report in 

the request to Commerce for federal matching funds. After reviewing the 

independent accountant’s report and Brand USA’s valuations and 

documentation to ensure compliance with the policy, Commerce directs 

Treasury to disburse to Brand USA federal matching funds for all eligible 

in-kind contributions. Figure 3 provides an overview of the process for the 

acceptance, review, and approval of Brand USA’s submission of in-kind 

contributions for disbursement of federal matching funds.
Page 29 GAO-13-705 Travel Promotion

Figure 3: Overview of Procedures for Brand USA’s Submission of In-kind 

Contributions for Federal Matching Funds
Page 30 GAO-13-705 Travel Promotion

Overall, for fiscal year 2012, Brand USA submitted to Commerce 13 

requests for approval of federal matching funds, 11 of which included inkind contributions. These submissions reflect total private sector 

donations of $51.9 million in cash and in-kind contributions (see fig. 4).38

Figure 4: Private Sector Donations of Cash and In-kind Contributions to Brand USA, 

Fiscal Year 2012

Commerce approved 53 in-kind contributions valued at $24.7 million from 

45 private sector donors. Figure 5 shows Brand USA’s approved 

submissions of in-kind contributions for fiscal year 2012.

 38Brand USA exceeded its fiscal year 2012 matching requirement of $50 million by 

approximately $1.9 million, which it will apply toward the $100 million in available federal 

matching funds for fiscal year 2013. 
Page 31 GAO-13-705 Travel Promotion

Figure 5: Brand USA’s Approved Submissions of In-kind Contributions, Fiscal Year 

2012

Contributions of digital libraries, including photographs and videos; 

information technology and website development services; market 

research; and Internet, print, and television advertising represented the 

largest shares of the total value of in-contributions approved by 

Commerce (see fig. 6). See appendix II for a list of approved in-kind 

contributions for fiscal year 2012.
Page 32 GAO-13-705 Travel Promotion

Figure 6: Categories of In-kind Contributions to Brand USA, Fiscal Year 2012

Since drafting the in-kind contributions policy in November 2011, Brand 

USA, in collaboration with Commerce and Treasury, has revised the 

policy three times—in April 2012, September 2012, and March 2013—as 

Brand USA submitted new types of in-kind contributions for Commerce’s 

approval. For example, in April 2012, Brand USA and Commerce agreed 

to revise the in-kind contributions policy to incorporate the methodology 

that the media consulting firm had developed in consultation with them

and Treasury to estimate Brand USA’s portion of the fair market value of 

in-kind contributions of cooperative advertising. In September 2012, 

Brand USA revised the policy further to incorporate the methodology that 

the media consulting firm had developed for valuing contributions of trade 

show sponsorships. In March 2013, Brand USA incorporated a new 

valuation methodology that Commerce developed to measure the value 

of television, radio, and print media contributions. Commerce and Brand 

USA, in consultation with Treasury, undertook a comprehensive revision 

of the in-kind contributions policy and procedures and subsequently 

approved a new set of guidelines in March 2013.

The policy, which does not provide a comprehensive list of in-kind 

contributions that are eligible for matching funds, states that it may be 

Brand USA Has Revised the 

In-kind Contributions Policy 

Several Times but Has Not 

Formalized Procedures for 

Making Revisions or Resolving 

Differences
Page 33 GAO-13-705 Travel Promotion

revised by Commerce when appropriate. However, neither the policy nor 

Brand USA’s memorandum of understanding with Commerce and 

Treasury include protocols specifying the time frames and conditions for 

reaching agreement about such revisions or resolving differences of 

opinion about the policy. According to Commerce, the in-kind 

contributions policy will likely continue to be revised as the agency 

continues to work with Brand USA to determine what types of 

contributions the corporation may submit and how those contributions 

should be valued to receive matching federal funds. Brand USA staff and 

Commerce officials stated that the policy is subject to revision because 

the corporation will likely receive new and unanticipated types of in-kind 

contributions, such as novel types of social media, owing to the nature of 

its promotional campaign activities.

In the absence of formal procedures for revising the in-kind contributions 

policy, Commerce and Brand USA have periodically negotiated revisions 

of sections of the policy after Commerce reviewed submissions of in-kind 

contributions that Brand USA believed were consistent with the policy. 

However, following negotiations with Commerce regarding whether 

certain types of contributions qualify for federal matching funds, Brand 

USA returned approximately $1.1 million in previously approved matching 

funds for “earned media” and uncompensated board expenses.

• Earned media contributions. The November 2011 policy allowed for 

in-kind contributions of earned media—that is, publicity gained 

through promotional efforts other than advertising, such as editorials 

and news articles about Brand USA—not specifically donated to the 

corporation. However, following discussions with Commerce about 

whether earned media qualified as in-kind contributions, in July 2012 

Brand USA returned approximately $859,000 in federal matching 

funds that it had received for this type of contribution.

• Uncompensated board contributions. The November 2011 policy 

allowed members of the Board of Directors to contribute 

uncompensated expenses for travel for, and time spent in performing, 

Brand USA management and administrative functions outside normal 

board responsibilities. However, in October 2012, Brand USA 

returned approximately $215,000 in federal matching funds for board 

members’ contributions of uncompensated travel and staff time.

According to Brand USA staff, these contributions of earned media and 

board member donations were eligible for federal matching funds under 

the policy, and Commerce initially agreed to match these contributions. 
Page 34 GAO-13-705 Travel Promotion

However, according to a July 2012 memorandum to Commerce, Brand 

USA noted that the corporation and Commerce had engaged in ongoing 

discussions regarding potential changes to the earned media section of 

the in-kind contributions policy. Brand USA further noted that, in an effort 

to act conservatively with respect to federal matching funds, the return of 

matching funds would be prudent until the corporation and Commerce 

reached an understanding about the policy. Moreover, in an October 

2012 memorandum to Commerce, Brand USA stated that it was 

suspending the policy for requesting federal matching funds for 

uncompensated board contributions and proposed the return of federal 

matching funds the corporation had received for these contributions. 

However, Brand USA stated that it reserved the right to revisit the policy 

with Commerce in the future. The revised in-kind contributions policy, 

which Commerce approved in March 2013, allows for in-kind 

contributions of media, including news articles and editorials, if the donor 

attests that it provided the donated media as a contribution to Brand USA. 

The revised policy also allows board members’ donations of 

uncompensated travel and time expenses. Brand USA stated that it 

reserved the right to resubmit the board member donations for federal 

matching funds after it reaches agreement with Commerce on these 

sections of the policy.

The lack of formal procedures for addressing and resolving differences 

regarding the in-kind contributions policy may hinder efforts to ensure 

clear agreement about the policy. According to standards for internal 

control in the federal government, control activities, such as policies and 

procedures, are an integral part of an entity’s accountability for 

stewardship of government resources.39 Establishing procedures helps 

ensure that the findings of reviews are promptly resolved, and resolution 

is completed only after management has taken action that corrects the 

review’s identified deficiencies or disagreements. Our recent work on 

independent organizations that, like Brand USA, receive both federal and 

nonfederal resources has noted that formalizing and documenting a 

process for resolving any disagreements between partners, such as 

Brand USA and Commerce, can enable productive interactions and 

facilitate collaboration.40

 39GAO/AIMD-00-21.3.1.

40GAO, Congressionally Chartered Organizations: Key Principles for Leveraging 

Nonfederal Resources, GAO-13-549 (Washington, D.C.: June 7, 2013).
Page 35 GAO-13-705 Travel Promotion

Since it was established in 2010, Brand USA has undertaken numerous 

activities to promote travel to the United States globally and in targeted 

markets overseas. Further, Brand USA has established long-term goals 

to increase travel to, and spending in, the United States, and has taken 

steps to measure some results of its global and targeted promotional 

campaigns. However, it does not yet have a plan for collecting and using 

performance data and information to assess whether these campaigns 

are having a positive impact on achieving its longer-term goals. Given the 

significance of international tourism to the United States’ economy and 

the role Brand USA is expected to play in increasing the United States’

share of the international tourism market, it is vital that the corporation 

optimize its use of resources to promote travel to the United States.

Brand USA’s development of policies detailing procedures that govern 

personnel, procurement, and valuation of in-kind contributions—a key 

source of its funding—are important steps to ensure that it complies with 

TPA’s requirements and creates an effective organization. Citing the need 

to develop methodologies to value certain kinds of in-kind contributions, 

Brand USA did not competitively procure the services of the media 

consulting firm that helped it develop the methodologies it uses to value 

in-kind contributions. Although experts we spoke with found these 

methodologies reasonable, they noted that other approaches may provide 

more accurate valuations. Brand USA staff indicated that they intend to 

solicit bids for a media consulting contract when the current contract 

expires in December 2013, although according to its terms, the contract 

could be extended past that time. Further, Brand USA lacks procedures 

for resolving differences with Commerce regarding the types of in-kind 

contributions allowed under Brand USA’s policy. Consequently, Brand 

USA returned nearly $1.1 million in federal matching funds for 

contributions of certain types of media and uncompensated board travel 

and staff time expenses after Commerce questioned whether these types 

of contributions qualified for federal matching funds. The March 2013 

revisions to the in-kind contribution policy, which Commerce, Treasury, 

and Brand USA agreed to, continue to allow for such contributions and 

Brand USA reserves the right to submit these types of contributions in the 

future. Establishing and documenting formalized procedures for agreeing 

to any revisions to the policy and resolving any disagreements about 

allowable contributions is important to ensure that federal matching funds 

are disbursed in a timely and efficient manner. Moreover, resolving these 

issues in a timely fashion is prudent since, to receive the maximum 

amount of federal matching funds in 2013, Brand USA must raise twice 

the amount of private-sector contributions that it raised in fiscal year 

2012.

Conclusions
Page 36 GAO-13-705 Travel Promotion

To strengthen Brand USA’s ability to carry out its mission of promoting 

international travel to the United States, we recommend that the Chief 

Executive Officer of Brand USA take the following three actions:

1. To provide more objective information on the progress of Brand USA’s 

travel promotion efforts and allow it to assess their effectiveness, 

especially as it relates to achieving its primary objectives of increasing 

travel to, and travel-related spending in, the United States, develop a 

plan that specifies timeframes, methodologies, and data sources for 

measuring performance and conducting periodic program evaluations.

2. To ensure consideration of multiple firms for the development of

methodologies for determining the fair market value of in-kind 

contributions, use a competitive process, in accordance with Brand 

USA’s procurement policy, to select firms to help it develop and 

implement valuation methodologies.

3. To improve the in-kind contributions policy and procedures, in 

coordination with the Secretary of Commerce and Secretary of the 

Treasury, formalize procedures for revising the policy.

We provided a draft of this report to Brand USA for comment. We 

received written comments from Brand USA which are reprinted in 

appendix III. Brand USA concurred with our findings and 

recommendations and commented on its efforts to implement our 

recommendations. For example, Brand USA noted the importance of 

measuring the impact of its promotional campaign on increased travel 

and spending, and stated that it is undertaking efforts to develop plans for 

measuring performance. In addition, Brand USA noted that it plans to 

solicit competitive bids to select a media consulting firm to develop 

methodologies for determining the fair market value of in-kind 

contributions when the current contract expires.

Commerce received a draft of the report but did not provide formal 

comments. Both Commerce and Brand USA provided technical 

comments, which we have incorporated in the report, as appropriate.

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 37 GAO-13-705 Travel Promotion

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 appropriate 

congressional committees, the CEO of Brand USA, and other interested 

parties. In addition, the report will be available at no charge on the GAO 

website at http://www.gao.gov.

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

me at (202) 512-3665 or dinapolit@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

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

report are listed in appendix IV.

Sincerely yours,

Timothy J. DiNapoli, Director

International Affairs and Trade
Appendix I: Objectives, Scope and 

Methodology

Page 38 GAO-13-705 Travel Promotion

We (1) described Brand USA’s programs and activities; (2) evaluated 

Brand USA’s efforts to measure program performance; and (3) examined 

the extent to which Brand USA established policies and procedures for 

personnel, procurement, and in-kind contributions consistent with Travel 

Promotion Act (TPA) requirements.

To describe Brand USA’s programs and activities, we reviewed relevant 

documents related to Brand USA’s strategic planning and marketing 

activities, including the corporation’s annual reports for fiscal years 2011 

and 2012, its marketing and strategic plans for fiscal year 2013, as well 

as its fiscal year 2013 financial statement prepared by its independent 

auditor. We also reviewed Brand USA’s promotional materials, including 

advertisements provided by Brand USA to examine its marketing 

activities and the specific U.S. travel destinations that Brand USA 

promoted. In addition, we interviewed Brand USA staff about the 

programmatic activities that Brand USA has planned and undertaken, 

including information about its global marketing and advertising activities, 

as well as the role its Board of Directors, advisory groups, and partners 

play in these efforts. In addition, we discussed with Brand USA staff the 

criteria and strategies used for the selection of targeted overseas markets 

and for marketing specific U.S. destinations. We discussed with these 

staff the roles and responsibilities of Brand USA’s contracted international 

offices and representatives in planning and implementing its promotional 

campaign in targeted overseas markets and reviewed documentation of 

the scope of work these offices perform.

To assess Brand USA’s approach to measuring program performance, 

we reviewed documentation of Brand USA’s performance data and 

reports of the evaluations its contracted firm conducted, and we 

interviewed Brand USA staff and representatives of the firm contracted to 

evaluate Brand USA’s promotional campaign in targeted overseas 

markets. We analyzed Brand USA’s performance objectives and the 

performance measures it reported in its fiscal year 2013 marketing plan. 

We interviewed representatives of the contracted firm that conducted 

survey evaluations of Brand USA’s promotional campaigns in Canada, 

Japan, and the United Kingdom to determine how the performance of 

these campaigns has been evaluated. In addition, we examined the firm’s 

survey instrument, documentation outlining the evaluation methodology, 

and reports of the firm’s evaluation results. We assessed the reliability of 

these data and evaluations. For example, we asked Brand USA and the 

contracted firm how the data were collected, the quality checks 

performed, and the other internal controls in place. We found the data 

sufficiently reliable for the purposes of reporting the results of Brand 

Appendix I: Objectives, Scope and 

Methodology
Appendix I: Objectives, Scope and 

Methodology

Page 39 GAO-13-705 Travel Promotion

USA’s metrics to monitor its Internet and social media activity over time, 

as well as the results of the contracted firm’s evaluations. We evaluated 

Brand USA’s efforts to measure the performance of its promotional 

campaign using GAO criteria on good practices for designing evaluations 

and developing performance plans and measures, as well as criteria from 

the American Evaluation Association on good practices for planning 

evaluations.1

To examine the extent to which Brand USA established policies and 

procedures for personnel, procurement, and in-kind contributions 

consistent with applicable TPA requirements, we reviewed and evaluated 

documentation outlining Brand USA’s personnel, procurement, and inkind contributions policies and procedures against relevant laws and 

guidelines, including the Travel Promotion Act of 2009, and GAO’s 

Standards for Internal Control in the Federal Government.

We also interviewed Brand USA staff to determine the 

extent to which Brand USA has developed plans for collecting and 

reporting performance measures for its promotional campaign activities, 

and to obtain information about how performance data are collected and 

used to manage these activities.

2 We assessed 

Brand USA’s procurement data by interviewing knowledgeable Brand 

USA staff and reviewing relevant documentation and found them to be 

sufficiently reliable for our purposes. We reviewed our prior report on the 

corporation’s programmatic activities.3

 1

GAO, Designing Evaluations, 2012 Revision, 

We examined Brand USA’s 

external legal determination of federal guidelines applicable to the 

corporation. We analyzed data and supporting documentation for each of 

Brand USA’s submissions of in-kind contributions for federal matching 

funds for fiscal year 2012. We found the data to be sufficiently reliable for 

the purposes of reporting Brand USA’s values and the categories of inkind contributions approved for federal matching funds. Consequently, we 

determined that Brand USA’s data accurately reflected the values it 

GAO-12-208G (Washington, D.C., Jan. 31,

2012); GAO, Effectively Implementing the Government Performance and Results Act, 

GAO/GGD-96-118 (Washington, D.C.: June 1, 1996); GAO, Performance Measurement 

and Evaluation: Definitions and Relationships, GAO-11-646SP (Washington, D.C.: May 2,

2011); and American Evaluation Association, An Evaluation Roadmap for More Effective 

Government, (Washington, D.C.: September 2010). 

2

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

GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 1, 1999).

3

GAO, Corporation for Travel Promotion: Establishment and Planned Programmatic 

Activities, GAO-12-485R (Washington, D.C.: Mar. 21, 2012). 
Appendix I: Objectives, Scope and 

Methodology

Page 40 GAO-13-705 Travel Promotion

placed on the in-kind contributions. However, it was beyond the scope of 

this engagement to assess the accuracy of Brand USA’s procedures for 

valuing in-kind contributions, and how its procedures compare to 

available alternatives. We examined the policy and procedures Brand 

USA uses to value its private sector in-kind contributions. We evaluated 

the in-kind contributions policy and procedures using GAO’s Standards 

for Internal Control in the Federal Government, including standards for 

ensuring policies and procedures are in place to promptly resolve the 

findings of audits and other reviews; as well as Financial Accounting 

Standards Board (FASB) standards for fair value measurements.4

We conducted this performance audit from November 2012 to July 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 the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

We 

interviewed officials at Commerce’s International Trade Administration 

who are responsible for reviewing Brand USA’s requests for federal 

matching funds, and representatives of Brand USA’s independent auditor 

and an independent accounting firm that verifies the corporation’s in-kind 

contribution valuations and reviewed documentation of their reviews of 

the policy and procedures and the valuation of in-kind contributions, to 

obtain their opinions about the policy and procedures. We additionally 

interviewed representatives of the firm contracted by Brand USA to 

develop methodologies for valuing in-kind contributions. We also 

reviewed documentation to determine the development and application of 

these valuation methodologies. We interviewed three academic experts in 

the field of media and marketing at the University of California, Davis; 

University of California, Los Angeles; and Loyola Marymount University to 

obtain their opinions of these methodologies. We selected these 

academic experts based on their expert qualifications in the field of 

marketing and media valuations as demonstrated by the number of 

research publications and membership on marketing research boards, as 

well as recommendations of other academic experts.

 4

FASB, Financial Accounting Series: Statement of Financial Accounting Standards No. 

157, Fair Value Measurements, (Norwalk, CT: September 2006).
Appendix II: Brand USA In-kind Contributions 

Approved for Federal Matching Funds, Fiscal 

Year 2012

Page 41 GAO-13-705 Travel Promotion

Donor In-kind contribution Value

Amtrak Information technology services $6,800

Amtrak Hospitality services $6,181

Amtrak Travel services $664

Amtrak Travel services $5,532

B*For Trade show sponsorship $41,437

Baxter Travel Media Print advertising $15,465

Black Diamond Films Event planning and services $215,106

British Airways Travel services $1,396,509

Canusa Internet and print advertising $218,000

Capital Region Market research $71,042

Cavallo Point Lodge Travel services $2,368

CISg Information technology services $152,701

Dertour Print advertising $22,248

Destination Marketing International Market research $22,500

ESI Media Print advertising $794,616

Expedia Internet advertising $1,500,000

Farragut Center Office furnishings and equipment $285,018

FTI/Sonnenklar.tv Television and Internet advertising $650,277

Georgia Department of Economic Development Market research $119,600

Go West Trade show sponsorship and travel 

services

$10,039

Harrods and Coastal South Carolina Print advertising $25,600

High Lantern Group LLC Consulting services $280,000

Horizon Travel Magazine Print and television advertising $19,990

Katten, Muchin, Rosenman, LLP Legal services $94,703

Katten, Muchin, Rosenman, LLP Legal services $36,692

Knecht Reisen AG Internet and print advertising $50,318

Major League Baseball-the World Baseball Classic Tournament sponsorship $1,000,000

Marriott International Market research $2,503,401

Meier’s Weltreisen Print advertising $102,485

Meltwater Group Consulting services $18,000

Michigan Lodging and Tourism Association Travel services $1,171

Miles Media Digital library (photographs and video) $4,187,938

National Parks Promotion Council Video production $774,520

National Parks Promotion Council Internet advertising $10,000

National Tour Association and National Parks 

Promotion Council

Trade show sponsorship $61,700

Patton Boggs, LLP Legal services $28,283

Appendix II: Brand USA In-kind 

Contributions Approved for Federal 

Matching Funds, Fiscal Year 2012
Appendix II: Brand USA In-kind Contributions 

Approved for Federal Matching Funds, Fiscal 

Year 2012

Page 42 GAO-13-705 Travel Promotion

Donor In-kind contribution Value

Screen Actors Guild—American Federation of 

Television and Radio Artists and 

Talent Partners

Talent services for advertisements $660,363

Source Communications Print advertising $7,630

Texas Research Market research $68,000

Tourism Economics Market research $3,500

Travel Market Insights Market research $195,000

Travelocity Canada Internet advertising $270,000

Trip Advisor Internet advertising $30,000

U.S. Travel Association Office space and equipment $11,435

U.S. Travel Association Website development $4,407,580

Visit California Market research $405,476

Visit California Market research $415,500

Visit California Digital library (photographs and video) $3,267,264

Visit California Print advertising $9,000

Visit California Travel services $1,868

Visit Orlando Market research $166,250

Visit Savannah Promotional photographs $500

Visit St. Petersburg/Clearwater Internet advertising $3,713

Total $24,653,983

Source: GAO analysis of Commerce and Brand USA data.
Appendix III: Comments from Brand USA

Page 43 GAO-13-705 Travel Promotion

Appendix III: Comments from Brand USA
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 44 GAO-13-705 Travel Promotion

Timothy J. DiNapoli, (202) 512-3665 or dinapolit@gao.gov

In addition to the contact named above, Juan Gobel, Assistant Director;

Martin De Alteriis, Assistant Director; Jack Warner, Assistant Director; 

Ashley Alley; Fred Evans; Teresa Heger; Bradley Hunt, and Reid Lowe 

made key contributions to this report. Additional assistance was provided 

by Ernie Jackson and Etana Finkler.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(320950)
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