EXPORT 

PROMOTION

Better Information 

Needed about Federal 

Resources

Report to the Chairman, Committee on 

Small Business, House of 

Representatives

July 2013

GAO-13-644

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-644, a report to the 

Chairman, Committee on Small Business, 

House of Representatives

July 2013

EXPORT PROMOTION

Better Information Needed about Federal Resources

Why GAO Did This Study

In 2010, the President launched the 

NEI with the goal of doubling U.S. 

exports over 5 years. More than 2 

decades ago, Congress directed the 

President to establish the TPCC to 

provide a unifying framework for 

federal efforts in this area. Among 

other things, Congress directed the 

TPCC to assess the appropriate levels 

and allocations of resources and 

develop a government-wide strategic 

plan that identifies federal export 

promotion priorities, reviews current 

programs in light of these priorities, 

and proposes to the President a 

federal trade promotion budget that 

supports the plan. Congress also 

required the TPCC to submit annual 

reports to Congress describing the 

required strategic plan.

This report assesses the extent to 

which the TPCC compiles and reports 

information on how federal export 

promotion resources are aligned with 

export promotion priorities. GAO 

reviewed the laws governing the TPCC 

and good practices for interagency 

initiatives, analyzed TPCC budget data 

and documents, and interviewed TPCC 

secretariat and Office of Management 

and Budget staff.

What GAO Recommends

GAO recommends that TPCC (1) 

develop and distribute guidance for 

member agencies on what information 

they should provide the TPCC on the 

resources they spend on export 

promotion activities; and (2) report in 

its National Export Strategies on how 

resources are allocated by agency and 

aligned with the strategy’s priorities.

The TPCC secretariat agreed with our 

recommendations and stated it plans 

to take steps to address them.

What GAO Found

The interagency Trade Promotion Coordinating Committee (TPCC) neither 

reports nor compiles information on how federal export promotion resources align 

with government-wide priorities. As a result, decision makers lack a clear 

understanding of the total resources dedicated across the country and around 

the world by TPCC member agencies to priority areas, such as increasing 

exports by small- and medium-sized businesses. GAO has previously reported 

that effective national strategies should address costs and has found 

shortcomings in the committee’s response to the budget-related portions of its 

mandate. While the TPCC’s National Export Strategy reports issued since 

initiation of the National Export Initiative (NEI) outline government-wide priorities 

and progress in achieving them, they do not discuss how resources are allocated 

in support of these priorities. Despite the current emphasis on export promotion 

as a high-priority goal, recent strategies have provided less information on 

budget resources than have previous strategies, as shown below. The TPCC last 

publicly reported a summary budget table in 2008. TPCC secretariat officials 

acknowledged that the TPCC agencies currently place little emphasis on 

displaying or discussing agencies’ resources in the National Export Strategy.

National Export Strategy Presentation of Budget Information

The TPCC last compiled high-level data on member agencies’ budget authority in 

2011, but this information is not useful for assessing resource allocations. To be 

useful, data should, among other things, be consistent and sufficiently complete 

for the intended purpose. However, the TPCC’s data are inconsistent across 

agencies and not detailed enough to facilitate an understanding or comparison of 

how resources are allocated among priorities. TPCC agencies do not use a 

common definition of export promotion, so it is unclear why some agencies are 

included in the TPCC’s data and others are not, and the TPCC’s data are not 

current. Although agency accounting systems and budget processes differ, which 

presents challenges, clear guidance for agencies on what information they 

should provide the TPCC could improve the quality of the data. Without better 

information on agencies’ export promotion resources, decision makers cannot 

determine whether the federal investment in export promotion is being used 

effectively or make informed decisions about future resource decisions.

View GAO-13-644. For more information, 

contact Kimberly Gianopoulos at (202) 512-

8612 or gianopoulosk@gao.gov.
Page i GAO-13-644 Export Promotion

Letter 1 

Background 2

The TPCC Does Not Report or Collect Information on How 

Resources Align with Priorities 6

Conclusion 17

Recommendations for Executive Action 18

Agency Comments and Our Evaluation 18

Appendix I Scope and Methodology 21

Appendix II Comments from the Trade Promotion Coordinating 

Committee 23

Appendix III GAO Contact and Staff Acknowledgments 25

Related GAO Products 26

Tables

Table 1: Congressional Committees with Jurisdiction over Core 

TPCC Agencies 3

Table 2: TPCC Data on Select Member Agencies’ Export Promotion 

Budget Authority, Fiscal Years 2007 to 2009 10

Figures

Figure 1: 2012 National Export Strategy Discussion of the Export 

Promotion Budget 8

Figure 2: Major Changes in National Export Strategy Presentation 

of Budget Information 9

Contents 
Page ii GAO-13-644 Export Promotion

Abbreviations

Ex-Im Export-Import Bank of the United States

GPRA Government Performance and Results Act of 1993

NEI National Export Initiative

OMB Office of Management and Budget

ONDCP Office of National Drug Control Policy

OPIC Overseas Private Investment Corporation

SBA Small Business Administration

TPCC Trade Promotion Coordinating Committee

USAID United States Agency for International Development

USTDA United States Trade and Development Agency

USTR United States Trade Representative

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Page 1 GAO-13-644 Export Promotion

441 G St. N.W.

Washington, DC 20548

July 17, 2013

The Honorable Sam Graves

Chairman

Committee on Small Business

House of Representatives

Dear Mr. Chairman:

In January 2010, the President launched the National Export Initiative 

(NEI) with the goal of doubling U.S. exports over 5 years. In doing so, the 

President drew renewed attention to a long-standing challenge: effectively 

coordinating the many and varied federal programs aimed at supporting 

growth in U.S. exports. More than 2 decades ago, Congress directed the 

President to establish the interagency Trade Promotion Coordinating 

Committee (TPCC) to provide a unifying framework for federal export 

promotion and export financing programs.1 Under the Export 

Enhancement Act of 1992, Congress directed the TPCC to assess the 

appropriate levels and allocations of resources for export promotion and 

export financing efforts.2 The law further required theTPCC to develop a 

government-wide strategic plan and provide annual reports to Congress 

describing the plan and its implementation.3 These strategic plans are to 

identify priorities, review current export promotion programs in light of 

these priorities, and propose to the President a federal trade promotion 

budget that supports the TPCC’s plan for priority activities and improved 

coordination and eliminates funding for identified areas of overlap and 

duplication.

You requested that we review information about federal export promotion 

resources available to TPCC agencies. This report assesses the extent to 

which the TPCC currently compiles and reports information on how 

federal export promotion resources are aligned with established priorities.

 

1

Export Enhancement Act of 1992, Pub. L. No. 102-429, § 201, 106 Stat. 2186. codified

as amended at 15 U.S.C. § 4727.

2

Id.

3

15 U.S.C. § 4727.

 
 

Page 2 GAO-13-644 Export Promotion

To address this objective, we analyzed the laws and presidential 

directives that define what is required of the TPCC as an interagency 

coordinating body, including the budget-related requirements in the 

Export Enhancement Act of 1992. We also reviewed GAO’s guidance 

regarding data reliability and examined good practices for coordinating 

interagency initiatives, as described in other GAO reports, including those 

covering the Government Performance and Results Act (GPRA) of 1993 

and the GPRA Modernization Act of 2010. We reviewed budget data 

collected by the TPCC, the TPCC’s annual National Export Strategies 

(focusing in particular on reports issued since the NEI was announced), 

and other TPCC documents describing efforts to compile and report 

budget information. We also interviewed TPCC secretariat and Office of 

Management and Budget (OMB) staff. For more details about our 

objectives, scope, and methodology, see appendix I.

We conducted this performance audit from February 2013 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 that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Responsibility for designing and carrying out federal export promotion 

programs is widely dispersed. Numerous federal agencies have offices 

across the country and overseas and operate a wide variety of programs 

that are intended, at least in part, to assist U.S. companies in entering 

foreign markets or expanding their presence abroad. For example, 

agencies provide companies with information on market opportunities and 

help them connect with potential buyers abroad, provide access to export 

financing, and negotiate with other countries to lower trade barriers.

The dispersion of export promotion activities among numerous agencies 

led us to observe in a 1992 report that “funding for ... agencies involved 

in export promotion is not made on the basis of an explicit governmentwide strategy or set of priorities. Without an overall rationale it is unclear 

whether export promotion resources are being channeled into areas with 

Background 
 

Page 3 GAO-13-644 Export Promotion

the greatest potential return.”

4 In 1992, Congress passed the Export 

Enhancement Act of 1992, which directed the President to establish the 

TPCC.5 The TPCC is chaired by the Secretary of Commerce, and its dayto-day operations are carried out by a secretariat that is housed in 

Commerce’s International Trade Administration. The TPCC has 20 

members, including 7 core members.6 Oversight of these agencies is 

dispersed across many congressional committees. Table 1 identifies the 

authorizing and appropriating subcommittees with jurisdiction over the 

seven core TPCC agencies.

Table 1: Congressional Committees with Jurisdiction over Core TPCC Agencies 

Agency

Subcommittees under Committees on 

Appropriations Authorizing committees with jurisdiction

House Senate House Senate

Commerce

(International Trade 

Administration)

Commerce, Justice, 

Science and Related 

Agencies

Commerce, Justice, 

Science, and Related 

Agencies

Foreign Affairs Banking, Housing, and 

Urban Affairs

Commerce, Science, and 

Transportation

Ex-Im State, Foreign 

Operations, and Related 

Agencies

State, Foreign Operations, 

and Related Agencies

Financial Services Banking, Housing, and 

Urban Affairs

OPIC State, Foreign 

Operations, and Related 

Agencies

State, Foreign Operations, 

and Related Agencies

Foreign Affairs Foreign Relations

SBA Financial Services and 

General Government

Financial Services and 

General Government

Small Business Small Business and 

Entrepreneurship

 

4

GAO Export Promotion: Federal Programs Lack Organizational and Funding 

Cohesiveness, GAO/NSIAD-92-49 (Washington, D.C.: Jan.10, 1992). 

5

Pub. L. No. 102-429, § 201.

6

TPCC members as specified in the Export Enhancement Act of 1992 are the 

Departments of Commerce, State, the Treasury, Agriculture, Energy, and Transportation; 

the Agency for International Development (USAID); the Trade and Development Agency 

(USTDA); the Small Business Administration (SBA); the Overseas Private Investment 

Corporation (OPIC); the Export-Import Bank of the United States (Ex-Im); and the Office of 

the U.S. Trade Representative, as well as other departments or agencies as the President 

determines necessary. In Executive Order 12870, the President added the Departments of 

Defense, Labor, and the Interior; the Environmental Protection Agency; the Council of 

Economic Advisors; the Office of Management and Budget; the National Economic 

Council; and the National Security Council. 58 Fed. Reg. 190 (Sept. 30, 1993). The seven 

core members are the Departments of Commerce, State, and Agriculture; USTDA; SBA; 

OPIC; and Ex-Im. 
 

Page 4 GAO-13-644 Export Promotion

Agency

Subcommittees under Committees on 

Appropriations Authorizing committees with jurisdiction

House Senate House Senate

State State, Foreign 

Operations, and Related 

Agencies

State, Foreign Operations, 

and Related Agencies

Foreign Affairs Foreign Relations

USDA

(Foreign Agricultural 

Service) 

Agriculture, Rural 

Development, Food and 

Drug Administration, and 

Related Agencies

Agriculture, Rural 

Development, Food and 

Drug Administration, and 

Related Agencies

Agriculture Agriculture, Nutrition, and 

Forestry 

USTDA State, Foreign 

Operations, and Related 

Agencies

State, Foreign Operations, 

and Related Agencies

Foreign Affairs Foreign Relations

Source: GAO.

We have reviewed the TPCC’s operations on several occasions since its 

creation in 1992.7 We have found that the TPCC and its member 

agencies have improved coordination in several areas, but we also found 

shortcomings in the committee’s response to the budget-related portions 

of its mandate. In 2002, we observed that the Secretary of Commerce, as 

the chair of the TPCC, made recommendations to the President, through 

OMB, on selected export promotion budget matters on multiple 

occasions. However, with no authority to reallocate resources among 

member agencies and occasional agency resistance to its guidance, the 

TPCC provided limited direction over the use of export promotion 

resources in support of its strategies. We also noted that the TPCC had 

not used its National Export Strategies to examine how agencies’ 

resources aligned with their goals, and we recommended that the TPCC 

consistently do so. The TPCC agreed with our findings and 

recommendation. However, in 2006 we determined that the committee 

had not implemented our recommendation; we found that the committee’s 

annual strategies did not review agencies’ allocation of resources in 

relation to identified priorities. In 2009, we observed that the TPCC’s most 

recently published National Export Strategy continued to lack an overall 

review of agency resource allocations relative to government-wide 

priorities.

Export promotion has recently been emphasized as a high priority for the 

federal government. In his 2010 Executive Order announcing the NEI, the 

 

7

For a list of GAO reports on the TPCC and related topics, see the Related GAO Products 

section at the end of this report.
 

Page 5 GAO-13-644 Export Promotion

President emphasized that creating jobs and sustainable economic 

growth in the United States was his top priority, and that increasing 

exports was a critical component of those efforts. He also laid out eight 

priority areas to be addressed through the NEI.8 OMB subsequently 

identified the NEI’s goal of doubling U.S. exports as one of 14 interim 

crosscutting priority goals under the GPRA Modernization Act.9

Additionally, as part of his 2013 and 2014 budget proposals, the 

President proposed consolidating six departments and agencies involved 

in export promotion into one new cabinet-level department.10

In his directives regarding the NEI, the President established a new body, 

the Export Promotion Cabinet, to develop and implement the initiative.11

The Export Promotion Cabinet is coordinated by a White House official, 

has most of the same member agencies as the TPCC, and is to 

coordinate its efforts with the TPCC. Among other things, the President 

tasked the Export Promotion Cabinet to work with the TPCC to determine 

how resources should be allocated. In particular, a February 2012 

Presidential Memorandum instructed the Export Promotion Cabinet, in 

consultation with the TPCC, to evaluate the current allocation of federal 

government resources, make recommendations to the Director of OMB 

for their more effective allocation, and propose a unified federal trade 

budget, consistent with the administration’s priorities, to the Director of 

OMB as part of the annual process for developing the President’s budget.

 

8

The NEI’s priority areas are (1) exports by small- and medium-sized enterprises; (2) 

federal export assistance; (3) trade missions; (4) commercial advocacy; (5) increasing 

export credit; (6) macroeconomic rebalancing; (7) reducing barriers to trade; and (8) 

export promotion of services.

9

This act calls upon OMB to develop long-term, outcome-oriented goals for a limited 

number of cross-cutting policy areas, and to provide information on how they will be 

achieved. Parts of the act do not come into effect until the 2015 budget is issued, but the 

act requires OMB to develop interim goals starting with the 2013 budget. Pub. L. No. 111-

352, 124 Stat. 3866 (2011) (amending the Government Performance and Results Act of 

1993, Pub. L. No. 103-62, 107 Stat. 285 (1993)). For comments on each of the interim 

crosscutting priority goals provided in the President’s budget, see GAO, Managing for 

Results: GAO’s Work Related to the Interim Crosscutting Priority Goals under the GPRA 

Modernization Act,GAO-12-620R (Washington, D.C.: May 31, 2012).

10The President proposed consolidating into a single department the Department of 

Commerce’s core business and trade functions: SBA, USTR, Ex-Im, OPIC, and USTDA. 

The proposal would also incorporate related programs from a number of other 

departments.

11Exec. Order No. 13534, 75 Fed. Reg. 12433 (Mar. 11, 2010).
 

Page 6 GAO-13-644 Export Promotion

The Export Enhancement Act states that the TPCC’s strategies should 

establish a set of priorities for federal export promotion activities and 

propose a unified federal trade promotion budget that supports the plan.12

Additionally, we have previously reported that one of the six 

characteristics of an effective interagency national strategy is that it 

identifies the resources needed to carry out the strategy. Specifically, an 

effective national strategy should address what it will cost, the sources 

and types of resources and investments needed, and where resources 

and investments should be targeted based on balancing risk reductions 

with costs.13

The most recent National Export Strategies, published in 2011 and 2012, 

outline federal priorities for export promotion, but provide little information 

on member agencies’ resources for carrying out these priorities. Both 

strategies outline progress made toward the eight NEI priorities and 

identify specific areas federal agencies will focus on in the coming year. 

In fact, the 2011 strategy includes the NEI recommendation to “increase 

the budget for trade promotion infrastructure” as one of five critical 

recommendations on which TPCC agencies would focus. However, these 

strategies do not provide summary information on the total resources 

available for export promotion and do not discuss how resources are 

currently allocated across priorities. Without this information, decision 

makers lack a clear understanding of the total federal resources being 

dedicated to export promotion activities, and it is not possible to assess 

the appropriate levels or allocations of export promotion resources.

 

1215 U.S.C. § 4727(c).

13GAO, Combating Terrorism: Evaluation of Selected Characteristics in National 

Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004).

The TPCC Does Not 

Report or Collect 

Information on How 

Resources Align with 

Priorities

National Export Strategies 

Outline Priorities, but Do 

Not Identify Associated 

Resources
 

Page 7 GAO-13-644 Export Promotion

The 2011 and 2012 strategies contain very limited discussions on 

agencies’ export promotion resources, consisting only of a few bullets that 

broadly discuss agencies’ budget requests. For example, figure 1 

reproduces in its entirety the section in the 2012 report titled “The 

Administration’s FY2013 Trade Promotion Budget.” The section includes 

three bullets relating to agencies’ requested export promotion budgets for 

2013, but provides no context on the total federal export promotion 

budget or on the budgets of the individual agencies it discusses. The first 

bullet, for example, notes that the President’s budget proposed $30.3 

million in additional funding for the U.S. and Foreign Commercial 

Service’s overseas export promotion activities. However, it does not 

indicate what the Commercial Service’s baseline budget is, whether the 

increase supports specific priorities laid out in the strategy, or whether 

resources could be shifted from existing Commerce activities, or from 

other agencies, to meet these needs. The remaining bullet points do not 

tie specific funding requests to individual agencies. The second bullet 

states that the fiscal year 2013 President’s budget seeks “support” for 

SBA’s Office of International Trade without stating what amount of 

funding, if any, SBA is requesting. The final bullet point simply states that 

five other core TPCC agencies seek a total increase of $19 million over 

2012 funding levels.
 

Page 8 GAO-13-644 Export Promotion

Figure 1: 2012 National Export Strategy Discussion of the Export Promotion Budget

Despite the current emphasis on export promotion as a high-priority goal, 

the level of detail on agencies’ budgets presented in the TPCC’s National 

Export Strategies has decreased. During much of the 1990s, the TPCC 

provided trade promotion budget information by agency and by activity, 

noting as it did so that presenting meaningful information across agencies 

was difficult because of the variety of programs involved. The strategies 

provided in-depth tables on how agency resources were allocated, for 

example, the 1997 report included 44 pages of material on this topic. 

After 2000, the TPCC stopped reporting budget information in such depth. 

The National Export Strategies from 2002 through 2008 provided only a 

summary budget table that presented information on each agency’s total 

budget authority for export promotion activities. As already noted, the 

most recent reports have eliminated these summary budget tables. Figure 

2 compares the budget information presented by the TPCC in 1996, 

2004, and 2012.
 

Page 9 GAO-13-644 Export Promotion

Figure 2: Major Changes in National Export Strategy Presentation of Budget Information

TPCC secretariat officials acknowledged that the amount of budget 

information presented in the National Export Strategies has declined and 

that the TPCC members currently place little emphasis on displaying or 

discussing agencies’ resources. They noted that changes in the political 

and budget environment over time have affected the TPCC’s processes. 

First, TPCC secretariat officials said that in the early 2000s, the TPCC 

shifted its focus away from resources in favor of efforts to improve the 

management of existing programs. For example, in 2003, a TPCC 

secretariat memo to member agencies stated that, given the budget 

environment, agencies should assume their budgets would be flat. The 

TPCC recommended that agencies look for opportunities to leverage 

resources through coordination or by sharing costs. Because the TPCC 

anticipated that members’ appropriations would not be increasing, 

secretariat officials stated that the TPCC largely stopped talking about or 

examining resources. Officials further noted that, while the NEI has 

generated enthusiasm for export promotion, the TPCC’s current focus 

remains on better managing and coordinating existing resources.14

Second, TPCC secretariat officials also stated that because final 

appropriations have not been passed until later in the fiscal year, it has 

been more difficult to collect up-to-date budget data. Finally, though 

GPRA sought to improve agency management and reporting processes, 

TPCC secretariat officials indicated that, as member agencies 

increasingly worked to comply with the law in 1999, it hindered their ability 

 

14TPCC secretariat officials stated that they try to influence agencies to use discretionary 

funding in support of TPCC priorities, but it is difficult to make recommendations about the 

allocation of resources, in part because the TPCC is chaired by the Secretary of 

Commerce, one of its many member agencies, who has no specific authority over other 

agencies.
 

Page 10 GAO-13-644 Export Promotion

to do crosscutting analyses. Officials found that agencies focused on their 

own specific core priorities and on developing agency-specific 

performance plans, which complicated the TPCC’s ability to obtain and 

track export promotion budgets.

The TPCC periodically collects summary data on agencies’ total budget 

authority for export promotion activities with OMB’s assistance. According 

to OMB staff, OMB asks agencies’ budget offices to self-identify their 

activities that relate to export promotion and compile a summary budget 

number. OMB resource management offices typically review the numbers 

provided by the agencies to ensure they are reasonable. Table 2 below 

reproduces the last table publicly released by the TPCC in its 2008 

National Export Strategy, including its footnotes. 

Table 2: TPCC Data on Select Member Agencies’ Export Promotion Budget Authority, Fiscal Years 2007 to 2009

Dollars in millions

Agency

FY 2007 FY 2008 FY 2009

Actual Enacted Request

Department of Agriculture 674 644 563

Department of Commerce 356 339 350

Department of Statea 176 184 198

Department of Treasury 3 3 3 

Export-Import Bank 38 1 3 

Overseas Private Investment Corporationb (192) (165) (170)

Small Business Administration 5.2 6 6.4

Trade and Development Agency 50 51 51

U.S. Trade Representative 44 44 46

Total 1,346 1,272 1,220 

Source: TPCC.

Notes:

This table reproduces the data presented in the TPCC’s 2008 National Export Strategy in its entirety.

Note to original TPCC table: “Amounts may be restated in the future to reflect new data or definitions. 

Figures may include administrative expenses, transfers, or other adjustments.” 

a

Note to original TPCC table: “Dollars are cumulative of all business and economic activities in the 

State Department.” 

b

Note to original TPCC table: “Totals do not include OPIC.” 

The Budget Data the TPCC 

Collects Are Not Useful for 

Assessing Resource 

Allocations 

The TPCC Collects Some HighLevel Budget Data 
 

Page 11 GAO-13-644 Export Promotion

According to OMB staff, OMB only compiles this information when 

requested by the TPCC, and the committee last requested this data in the 

spring of 2011. Because the TPCC opted not to make these data public in 

that year’s National Export Strategy, OMB staff did not fully review them. 

Therefore, OMB staff requested that we not publish the data collected in 

2011. We nevertheless examined the more recent information the TPCC 

provided us, which included actual budget data for the same member 

agencies as shown in table 2 from fiscal years 1994 through 2010 and 

agencies’ requested budget for fiscal years 2011 and 2012. The TPCC 

used the same process to collect data in 2011 that it used for the 2008 

National Export Strategy. Therefore, our discussion below, which 

identifies several significant issues impacting the reliability and usefulness 

of the data, focuses on the 2011 update but also generally applies to the 

data presented in table 2. According to TPCC secretariat officials, the 

committee has initiated efforts to further update this information, but 

officials have not indicated whether they plan to make it public as part of a 

future National Export Strategy.

The data the TPCC collects are not useful for assessing the allocation of 

export promotion resources. To be useful for assessing how agencies’ 

resources are allocated, data should, among other things, be consistent 

and sufficiently comprehensive for the intended purpose.15 Moreover, 

collaborating agencies would need to use compatible methods to track 

funding.16 Additionally, we have reported on the importance of agencies 

providing appropriate levels of detail in budgeting documents. For

example, prior to the creation of the Department of Homeland Security, 

we noted that crosscutting funding data provided in an OMB annual report 

on combating terrorism had limited utility for decision makers, in part 

because it did not include data on obligations or on duplication in 

 

15According to GAO’s guidance on assessing the reliability of computer-processed data, 

consistency refers to the need to obtain and use data that are clear and well defined 

enough to yield similar results and similar analyses. See GAO, Applied Research and 

Methods: Assessing the Reliability of Computer-Processed Data, GAO-09-680G

(Washington, D.C.: Feb. 2009). 

16GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012).

The TPCC’s Data Are Not 

Consistent or Comprehensive 

Enough to Understand How 

Resources Are Allocated 
 

Page 12 GAO-13-644 Export Promotion

programs for combating terrorism.17 We identified several issues with the 

TPCC’s most recent data, from 2011, and determined that the data are 

neither consistent across agencies nor comprehensive enough to indicate 

how resources are allocated across priorities or the overall cost of 

carrying out the National Export Strategy.

• Agencies use different definitions: According to TPCC secretariat 

and OMB staff, each agency independently defines export promotion 

and self-identifies the activities to include in its export promotion 

budget. The TPCC’s data include few explanatory notes about how 

each agency’s budget was computed, making it difficult to compare 

numbers across agencies or understand what activities are included 

for each agency. In fact, TPCC secretariat officials were not always 

certain what each agency’s number represented. Because agencies 

use different definitions, there is no assurance that TPCC’s data treat 

similar activities consistently. For example, SBA, OPIC, and Ex-Im all 

provide some form of export financing, but the TPCC’s data for these 

agencies represent three different aspects of their budgets. SBA’s 

data show the administrative expenses for its Office of International 

Trade, which is responsible for its export loan programs. OPIC’s data 

capture the agency’s total impact on the federal budget but do not 

provide any indication of the costs of operating its financing programs. 

Ex-Im’s data show the appropriations for its Office of Inspector 

General, but do not include any information on the costs of operating 

its financing programs or the agency’s total impact on the federal 

budget.18

• The reasons for including or excluding agencies are not always 

clear: An example of the lack of clarity in how the TPCC treats 

member agencies is that its summary budget table does not include 

USAID, noting that it does not do so because the agency’s activities 

 

17GAO, Combating Terrorism: Funding Data Reported to Congress Should Be Improved, 

GAO-03-170 (Washington, D.C.: Nov. 26, 2002). See also GAO, Veterans’ Health Care 

Budget: Better Labeling of Services and More Detailed Information Could Improve the 

Congressional Budget Justification, GAO-12-908 (Washington, D.C.: Sept. 18, 2012), in 

which we pointed out that more detailed information could improve the Department of 

Veterans Affairs Congressional Budget Justification.

18This only applies to Ex-Im submissions provided after fiscal year 2008. Since fiscal year 

2008, Ex-Im has been self-sustaining for appropriations purposes, financing its operations 

from receipts collected from its borrowers. Therefore, Ex-Im’s budget submissions prior to 

2008 used a different formulation than those submitted after 2008.
 

Page 13 GAO-13-644 Export Promotion

support trade promotion indirectly. However, the TPCC’s data include 

OPIC, which also focuses on international development and only 

indirectly supports exports. Moreover, the TPCC’s table continues to 

include other agencies, such as the Department of the Treasury, 

which do not directly fund trade promotion activities. Nonetheless, as 

we noted in 2006,19 portions of several National Export Strategies 

continued to highlight export promotion programs involving USAID.20

According to TPCC secretariat officials, member agencies decide 

whether or not they have export promotion programs and whether to 

provide resource data.

• The data are not detailed enough to align with priorities: The 

TPCC’s summary budget table presents data at a very high level, with 

one number for each agency, and provides no information on specific 

activities or programs. Without greater detail, it is not possible to 

understand whether or how agency resources are aligned with the 

priorities laid out in the National Export Strategy and National Export 

Initiative. Some TPCC member agencies conduct activities in more 

than one priority area. For example, among other activities, 

Commerce supports U.S. business in conducting trade missions and 

also works to reduce barriers to trade, both of which are priority areas 

in the National Export Initiative. Among its many activities, USDA 

supports the goals of increasing exports by small and medium-sized 

enterprises and increasing export credit available to U.S. businesses. 

Because it only presents information at a high level, the TPCC’s table 

does not allow users to understand how federal resources are being 

allocated across these, or other, priority areas.

• The data are not current: The TPCC’s data are not comprehensive 

because they do not include current information about agencies’ 

resources. The TPCC last updated its information in April 2011 and 

that summary budget table reflected agency budget requests for fiscal 

year 2012. The President released his fiscal year 2013 budget 

request in February 2012. Nonetheless, the latest data collected by 

 

19GAO, Export Promotion: Trade Promotion Coordinating Committee’s Role Remains 

Limited, GAO-06-660T (Washington, D.C.: Apr. 26, 2006).

20For example, the 2012 National Export Strategy includes a discussion of a 4-year, $120 

million USAID program, the African Competitiveness and Trade Expansion Initiative, 

which provides funding for African Regional Trade Hubs. The strategy notes that these 

hubs promote increased trade between sub-Saharan African countries and the United 

States. The cost of this program, however, is not captured in the TPCC’s budget data.
 

Page 14 GAO-13-644 Export Promotion

the TPCC do not reflect fiscal year 2013 requests, nor do they show 

actual data for 2011, or estimates for 2012. Moreover, because the 

TPCC opted not to include the data in its National Export Strategy, 

OMB staff never fully vetted the data collected in 2011. Therefore, the 

most recent fully vetted data on federal export promotion resources 

are from 2008.

• Budget authority data does not fully reflect costs of all agencies’ 

programs: Finally, the TPCC’s use of total budget authority data

provides an incomplete picture of the costs of some agencies’ 

programs. For example, OPIC is self-funded through receipts 

collected on its financing activities and has a net negative budget 

authority, meaning it returns money to the U.S. government. However, 

it does receive annual instructions from Congress on the amount of 

money it can spend on administrative and program expenses for its 

financing programs. While the TPCC’s use of total budget authority

data may accurately represent one aspect of an agency’s impact on 

the overall federal budget allocated for export promotion, it is not 

sufficiently detailed to fully understand the agency’s contributions 

toward export promotion. For example, the TPCC’s number does not 

indicate the costs associated with operating OPIC’s financing 

programs or how much financing its budget supports.

Without consistent and comprehensive information on export promotion 

resources, the TPCC cannot accurately assess the levels and allocation 

of resources among agencies. Thus, decision makers in Congress and 

the administration do not have full information about the U.S. 

government’s investment in export promotion and cannot determine 

whether resources are being allocated to the highest priority areas. 

Further, without information on export promotion resources, neither the 

TPCC nor the Export Promotion Cabinet can make informed 

recommendations about their appropriate allocation across agencies. 

Additionally, the Export Enhancement Act requires the TPCC to identify 

overlap and duplication among export promotion programs. However, as 

we have reported, it is difficult to gauge the magnitude of the federal 

commitment to a particular area of activity or assess the extent to which 
 

Page 15 GAO-13-644 Export Promotion

federal programs are duplicative without a clear understanding of the 

costs of implementing those programs and the activities they support.21

According to TPCC secretariat officials, the TPCC does not provide any 

guidance to agency officials on what budget information should be 

reported or how agencies should determine which activities should be 

included as export promotion. In the past, the TPCC provided guidance 

on the information member agencies should submit on their export 

promotion budgets. We reported that the data presented by the TPCC 

fostered a better understanding of historic and potential expenditures.22

The lack of clear TPCC guidance makes it difficult for agencies to 

provide, and for the committee to collect, comparable budget information. 

Without clear guidance, TPCC agencies use different definitions for 

export promotion in compiling budget information. Many agencies’ 

programs have multiple objectives, some of which are directly related to 

export promotion and some of which are not. For example, USDA’s 

export promotion programs also fulfill domestic agricultural objectives. 

According to OMB staff, this makes it challenging to clearly determine 

what activities should be considered export promotion. OMB staff stated 

that TPCC secretariat and OMB staff have had some preliminary 

discussions about developing standardized definitions of what activities 

should be considered export promotion and how data should be reported.

However, these discussions are in the early stages, and the TPCC would 

need to decide what information it wants to include in the National Export 

Strategies before moving forward.

Similarly, the TPCC does not supply guidance that could help clarify what 

level of detail agencies should provide to them. As the TPCC noted in its 

2000 National Export Strategy, its ability to collect and present detailed 

budget information is limited by agencies’ abilities to generate 

comparable data within their varied accounting structures. In developing 

guidance, the TPCC could work with member agencies to determine a 

reasonable level of detail and identify the limitations of the data. For 

 

21GAO, 2013 Annual Report: Actions Needed to Reduce Fragmentation, Overlap, and 

Duplication and Achieve Other Financial Benefits, GAO-13-279SP (Washington, D.C.: 

Apr. 9, 2013). 

22GAO, National Export Strategy, GAO/NSIAD-96-132R (Washington, D.C.: Mar. 26, 

1996).

Lack of Clear Guidance 

Impedes the Collection of 

Useful Data
 

Page 16 GAO-13-644 Export Promotion

example, in 2000, the TPCC provided details on agencies’ expenditures 

in major federal export promotion areas, such as combating foreign 

export subsidies. However, they included a caveat that detailed budget 

numbers below the overall agency total can be difficult to validate and

should only be used as an indication of the resources available for each 

area. 

There are lessons to be learned from other bodies coordinating 

crosscutting government programs and facing similar challenges.23 For 

example, like the TPCC, the Office of National Drug Control Policy 

(ONDCP) has a statutory requirement to develop a national strategy and 

propose a consolidated budget to implement that strategy.24 ONDCP’s 

process for developing the National Drug Control Strategy and its 

associated budget is not a perfect comparison for the TPCC because 

ONDCP has different authorities for reviewing and suggesting changes to 

member agencies’ budgets. However, its process for collecting and 

compiling data can highlight the usefulness of providing clear and detailed 

guidance.25 ONDCP provides detailed guidance to relevant agencies on 

how to assemble budget information.26 Its guidance includes a sample 

budget table that identifies the level of detail agencies should provide, 

including a list of the functions, such as corrections or interdiction, 

agencies should report on.27 ONDCP’s guidance also defines those 

 

23In addition to ONDCP, discussed above, the Intellectual Property Enforcement 

Coordinator also has a statutory mandate to coordinate the development of a Joint 

Strategic Plan which shall include resource estimates. 15 U.S.C. §§ 8111, 8113. In 2010 

we reported that the Coordinator had not done so because data collection and analysis 

were still in progress. See GAO, Intellectual Property: Agencies Progress in Implementing 

Recent Legislation, but Enhancements Could Improve Future Plans, GAO-11-39

(Washington, D.C.: Oct. 13, 2010). We have also recommended that the Director of 

National Intelligence include a discussion of resources in a strategic framework for its 

Joint Duty Program, a personnel rotational program across the intelligence community. 

See GAO, Intelligence Community Personnel: Strategic Approach and Training 

Requirements Needed to Guide Joint Duty Program, GAO-12-679 (Washington, D.C.: 

June 20, 2012). 

2421 U.S.C. §§ 1703(b)(2) and 1703(c)(2)(A).

25See 21 U.S.C. § 1703(c) for more detail on ONDCP’s authorities with respect to the 

National Drug Control Program budget. 

26ONDCP Circular: Budget Formulation (Jan. 18, 2013).

27ONDCP’s use of the term “budget function” does not refer to the major functions of the 

federal budget. Rather, ONDCP uses “budget function” to describe a particular area of 

federal involvement.
 

Page 17 GAO-13-644 Export Promotion

functions and identifies which activities should be included in each 

function. In 2011, we reported that, while drug control agency officials 

raised some concerns about ONDCP’s budget process, officials at 4 of 6 

agencies stated that it was somewhat or very effective at providing a 

record of national drug control expenditures, among other things.28

Clear guidance can help overcome challenges and make the data 

collected by interagency groups more useful for understanding how 

resources are currently allocated across agencies and activities, as 

illustrated by the ONDCP example. The TPCC’s lack of guidance 

impedes the collection of accurate, comprehensive, and consistent 

information necessary to understand how resources are allocated among 

priorities. Without clear guidance, TPCC agencies are using 

nonstandardized definitions to identify activities that relate to export 

promotion and are not clear about what level of detail is required.

In announcing the National Export Initiative, the President not only 

reemphasized the importance of exports to the U.S. economy, but 

specifically highlighted the need to understand and coordinate federal 

resources for export promotion. However, the TPCC does not provide 

decision makers—including Congress and the Export Promotion 

Cabinet—with information that provides a clear understanding of how 

resources are currently allocated across the country and around the world 

among its member agencies or across federal export promotion priorities. 

In fact, the amount of information the TPCC has reported on agencies’ 

resources has declined. The TPCC has responded to the National Export 

Initiative by reporting on efforts to address established priorities and 

working to improve interagency coordination, but the committee currently 

places almost no emphasis on understanding the federal resources 

dedicated to implementing the National Export Strategy, as is called for in 

good practices. In the absence of clear guidance, the data the TPCC 

collects are not comparable across agencies and not comprehensive 

enough to allow the TPCC to determine how resources are currently 

allocated in support of priority activities. Furthermore, without better 

resource data, neither the TPCC nor the Export Promotion Cabinet can 

make informed recommendations about how federal resources should be 

 

28GAO, Office of National Drug Control Policy: Agencies View the Budget Process as 

Useful for Identifying Priorities, but Challenges Exist, GAO-11-261R (Washington, D.C.: 

May 2, 2011).

Conclusion 
 

Page 18 GAO-13-644 Export Promotion

allocated. As policymakers review the success of the NEI and consider 

the President’s request for authority to consolidate trade agencies in a 

single department, it is important to understand how federal resources are 

being spent. Without consistent and comprehensive information on export 

promotion resources—presented transparently through the TPCC’s 

annual strategies—decision makers in Congress and the administration 

cannot determine whether the return on the federal investment in export 

promotion is adequate or make informed decisions about future resource 

allocations.

To improve the consistency, comprehensiveness, and transparency of 

information provided to Congress and policymakers on the federal 

investment in export promotion programs, the Secretary of Commerce, as 

chair of the TPCC, should

1. develop and distribute guidance for member agencies on what 

information they should provide the TPCC on the resources they 

spend on export promotion activities, and

2. report in its National Export Strategies on how resources are allocated 

by agency and aligned with priorities.

We provided drafts of this report to the Secretary of Commerce, as chair 

of the TPCC, and to OMB. In written comments reprinted in appendix II, 

the Director of the TPCC Secretariat generally concurred with our 

recommendations on behalf of the Secretary and stated that they intend 

to work with TPCC member agencies and the Export Promotion Cabinet 

to implement them. In particular, they plan to create a new TPCC Budget 

Working Group to establish a robust TPCC role in assessing the 

appropriate levels and allocation of resources among agencies, as called 

for in its mandate. TPCC Secretariat officials provided technical 

comments and suggested corrections and clarifications that we 

incorporated, when appropriate. Nevertheless, the Director noted the 

TPCC’s limited authority over budget reporting and resource allocations, 

including its inability to compel member agencies to provide budget and 

resource information. He gave examples of some challenges they face, 

including shifts in the political and budgetary landscape and how different 

Administrations and Congresses have emphasized different priorities over 

time. However, he said the TPCC Secretariat will work within its existing

authorities with TPCC agencies to address our recommendations. 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 19 GAO-13-644 Export Promotion

We support the establishment of a TPCC Budget Working Group and 

note that implementing the requirements of the Export Enhancement Act 

of 1992 is the responsibility of the committee, as comprised of the 

member agencies, under the leadership of the Chair and with the support 

of the secretariat. TPCC member discussions that improve the 

consistency, comprehensiveness, and transparency of information 

provided to Congress and policymakers can help overcome such 

challenges, facilitate well-informed resource decisions, and better support 

the National Export Initiative and the Export Promotion Cabinet. 

We also requested comments on a draft of this report from OMB. On 

June 21, OMB’s Office of General Counsel provided us with comments 

via e-mail. OMB noted that, while export promotion budgetary data have 

not been presented in a public document since the 2008 National Export 

Strategy, OMB annually compiles and reviews current and proposed 

resources across TPCC agencies that are devoted to export promotion 

and trade activities, as part of the development of the President’s budget. 

OMB further stated that it uses these data to ensure prudent governmentwide allocation of export promotion-related resources and strong support 

for the President’s export promotion agenda, but that because these data 

are internal, pre-decisional, and deliberative, OMB does not share the 

cross-agency table outside of OMB, nor does it publish this information as 

part of the President’s budget or related materials. However, OMB 

commented that it consults with a number of officials, including the 

Assistant to the President and Deputy National Security Advisor for 

International Economics, as head of the Export Promotion Cabinet, when 

recommending export-promotion related resources in the President’s 

budget. 

We acknowledge that OMB conducts a review as part of the annual 

agency budget formulation process. However, this activity is distinct from 

the TPCC’s budget-related requirements in the Export Enhancement Act. 

As OMB notes, its activities are internal and deliberative and not shared 

outside OMB, including with the TPCC Secretariat or its member 

agencies. Thus, OMB’s process is not transparent to Congress or to other 

relevant parties and does not benefit from activities that could improve the 

consistency or comprehensiveness of this information.

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

this report earlier, we plan no further distribution until 28 days from the 

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

Commerce (in her capacity as Chairman of the TPCC), as well as the 
 

Page 20 GAO-13-644 Export Promotion

Director of OMB, interested congressional committees, 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- 8612 or gianopoulosk@gao.gov. Contact points for our 

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

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

report are listed in appendix IV.

Sincerely yours,

Kimberly Gianopoulos,

Acting Director, International Affairs and Trade
Appendix I: Scope and Methodology

Page 21 GAO-13-644 Export Promotion

This report assesses the extent to which the Trade Promotion 

Coordinating Committee (TPCC) currently compiles and reports 

information on how budgetary resources are aligned with established 

export promotion priorities.

To address this objective, we analyzed the laws and presidential 

directives that define what is required of the TPCC as an interagency 

coordinating body. These included the Export Enhancement Act of 1992, 

which directed the President to establish the TPCC; the 1993 Executive 

Order which established the TPCC in accordance with the 1992 act; the 

2010 Executive Order announcing the National Export Initiative (NEI); and 

a subsequent (2012) Presidential Memorandum providing further 

instruction on Export Promotion Cabinet and TPCC collaboration to 

maximize the effectiveness of Federal trade programs. We also reviewed 

GAO’s guidance regarding data reliability and examined alternate models 

and good practices for coordinating and managing multi-agency initiatives 

as described in other GAO reports, including those covering the 

Government Performance and Results Act (GPRA) of 1993 and the 

GPRA Modernization Act of 2010. We reviewed the annual “National 

Export Strategy” reports to Congress that the TPCC has produced since 

its inception, focusing in particular on those prepared since the NEI was 

announced in 2010, as well as TPCC memoranda documenting efforts to 

compile and report budget information and develop a federal trade 

promotion budget. We also interviewed staff of the TPCC Secretariat, 

which is housed in the Department of Commerce, and staff of the Office 

of Management and Budget (OMB).

To assess the reliability and usefulness of budget data collected by the 

TPCC, we took a number of steps, including (1) reviewing the data for 

internal consistency; (2) comparing TPCC’s data table with select agency 

budget documents, including Congressional Budget Justifications, 

appropriations bills, and agency financial or annual reports; (3) reviewing 

past GAO work on the TPCC’s budget; and (4) interviewing 

knowledgeable TPCC secretariat and OMB staff. Based on this 

assessment, we identified numerous issues with the TPCC’s data, as 

discussed in detail in this report. We present the TPCC’s data in the 

report only to illustrate our assessment of the data.

We conducted this performance audit from February 2013 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 that 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 22 GAO-13-644 Export Promotion

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Trade 

Promotion Coordinating Committee

Page 23 GAO-13-644 Export Promotion

Appendix II: Comments from the Trade 

Promotion Coordinating Committee 
Appendix II: Comments from the Trade 

Promotion Coordinating Committee

Page 24 GAO-13-644 Export Promotion
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 25 GAO-13-644 Export Promotion

Kimberly Gianopoulos, (202) 512-8612, gianopoulosk@gao.gov

In addition to the contact named above, Adam Cowles, Assistant Director; 

Michael McAtee, Analyst-in-Charge; Kara Marshall; and Karen Deans 

made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 
Related GAO Products

Page 26 GAO-13-644 Export Promotion

Export Promotion: Small Business Administration Needs to Improve 

Collaboration to Implement Its Expanded Role. GAO-13-217. 

Washington, D.C.: January 30, 2013.

National Export Initiative: U.S. and Foreign Commercial Service Should 

Improve Performance and Resource Allocation Management. 

GAO-11-909, Washington, D.C.: September 29, 2011.

International Trade: Effective Export Programs Can Help In Achieving 

U.S. Economic Goals. GAO-09-480T. Washington, D.C.: March 17, 2009.

Export Promotion: Trade Promotion Coordinating Committee’s Role 

Remains Limited. GAO-06-660T. Washington, D.C.: April 26, 2006.

Export Promotion: Mixed Progress in Achieving a Governmentwide 

Strategy. GAO-02-850. Washington, D.C.: September 4, 2002.

Export Promotion: Federal Agencies’ Activities and Resources in Fiscal 

Year 1999. GAO/NSIAD-00-118. Washington, D.C.: April 10, 2000.

Export Promotion: Issues for Assessing the Governmentwide Strategy. 

GAO/T-NSIAD-98-105. Washington, D.C.: February 26, 1998.

National Export Strategy. GAO/NSIAD-96-132R. Washington, D.C.: 

March 26, 1996.

Export Promotion: Governmentwide Plan Contributes to Improvements. 

GAO/T-GGD-94-35. Washington, D.C.: October 26, 1993.

Export Promotion: Initial Assessment of Governmentwide Strategic Plan. 

GAO/T-GGD-93-48. Washington, D.C.: September 29, 1993.

Export Promotion Strategic Plan: Will It Be a Vehicle for Change? 

GAO/T-GGD-93-43. Washington, D.C.: July 26, 1993.

Export Promotion: Governmentwide Strategy Needed for Federal 

Programs. GAO/T-GGD-93-7. Washington, D.C.: March 15, 1993.

Export Promotion: Federal Programs Lack Organizational and Funding 

Cohesiveness. GAO/NSIAD-92-49. Washington, D.C.: January 10, 1992.

Related GAO Products

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