Federal Printing: Fewer Plants Are in Operation Than in 1990, and Selected Agencies Reported Declining Volumes
Published: 2013-07-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Federal law requires that, with limited exceptions, all federal printing be performed by or through GPO. The JCP authorizes exemptions to specific agencies to operate in-house printing plants. In its 1990 JCP Regulations, the JCP included a list of authorized federal in-house printing plants. Some agency documents, once published, are required to be submitted to the FDLP, a GPO program designed to preserve government documents and make them available to the public.
GAO was asked to examine how federal printing practices had changed since the JCP Regulations were updated in 1990. This report describes (1) agencies' current printing practices--including the number of in-house printing plant and selected agencies' volumes and spending--and (2) how agencies' current printing practices are reflected in federal printing regulations and statutes.
GAO surveyed agencies that might be operating in-house printing plants, interviewed GPO and agency officials, analyzed agency data on printing volumes and spending, and reviewed printing regulations and statutes. GAO also selected six agencies from those surveyed to interview, based on their printing and reproduction obligations. Findings from these interviews cannot be generalized to other federal agencies.
GAO is not making recommendations in this report. GAO provided copies of the draft report to GPO and DOD for review and comment. GPO generally agreed with the findings and provided a letter and technical comments which were incorporated as appropriate. DOD did not provide comments.
section_title: What GAO Found
paragraphs: Agencies GAO surveyed reported operating fewer in-house printing plants than in 1990. Specifically, surveyed agencies reported operating 64 percent fewer plants than the number listed in the Congress's Joint Committee on Printing's (JCP) Government Printing and Binding Regulations, updated in 1990 (1990 JCP Regulations). The Department of Defense (DOD) accounted for the greatest decline in in-house printing plants. The 1990 JCP Regulations listed 142 DOD printing plants; however, the Defense Logistics Agency, which currently manages the majority of DOD's printing infrastructure, reported 17 in-house printing plants in GAO's survey. In addition, most agencies reported operating toner-based high-speed duplication machines, and fewer reported operating ink-based conventional printing presses. Of the 32 agencies operating in-house printing plants, 17 reported that all of their in-house printing was conducted on high-speed duplication machines; another 14 agencies reported operating some duplication equipment in addition to conventional printing presses (the remaining agency did not report its type of equipment). No agency reported having only ink-based conventional printing presses at its in-house plants. In addition, interviews with selected agencies showed declines in printing volumes and total spending, and suggested that agencies spent more on printing sent to the Government Printing Office (GPO) and its contracted private printers than on printing done at in-house printing plants.
Agencies' printing practices have changed, but existing authorities have not been updated. For example, in 1994, Title 44 of the U.S Code was updated to include "duplicating" in the definition of "printing," but the 1990 JCP Regulations do not include this definition. According to JCP staff, the Committee is aware that the 1990 JCP Regulations do not include duplicating in the definition of printing, and the Committee is working to revise the guidance. Also, the majority of government documents are now published digitally, but provisions in Title 44 that require agencies to submit documents to the Federal Depository Library Program (FDLP) do not reference digital publishing. Selected agencies GAO interviewed reported that they do not submit digital documents to FDLP. FDLP staff have taken a number of steps to address this, including educating agencies about FDLP requirements. In addition, the National Academy of Public Administration recently recommended that GPO develop a plan to preserve and collect government documents, and include a process for ingesting digitized copies into GPO's online government publications system, and GPO reported that it would incorporate this recommendation into its national plan for the future of the FDLP.

section_title: Letter
paragraphs: Federal agencies publish thousands of items such as reports, regulatory  decisions, consumer information, and other types of documents that are  of interest to the public. Federal law requires that, with limited exceptions,  all federal printing be performed by or through the Government Printing  Office (GPO). The Congress’s Joint Committee on Printing (JCP) issues  exemptions to some agencies to operate in-house printing plants, and in  1990, the JCP included within its Government Printing and Binding  Regulations (1990 JCP Regulations) a list of authorized federal in-house  printing plants. At the time, this included 231 in-house printing plants  across 36 agencies. Once published, some agency documents, including  some printed at in-house plants, are required to be submitted to the  Federal Depository Library Program (FDLP), a program within GPO  designed to preserve government documents and make them available to  the public. However, since 1990, federal printing operations have  changed, as industry and government data suggest that digital publication  (producing and disseminating documents electronically) has increased  and the traditional production of printed documents has decreased.
In this context, you asked us to examine the current state of federal  printing. In this report, we describe: (1) agencies’ current printing  practices, including the number of in-house printing plants and selected  agencies’ volumes and spending, and (2) how agencies’ current printing  practices are reflected in federal printing regulations and statutes.
To carry out this review, we developed working definitions of key printing  terms — “printing,” “duplication,” and “printing plant”—intended to capture  agencies’ current printing practices. To develop these definitions, we  used existing statutory language, and consulted with GPO and the  Interagency Council on Printing and Publication Services. We  distinguished “duplication” from “copying” by the number of pages printed,  which allowed us to identify and include larger duplication operations that  qualified as agency in-house printing plants and exclude smaller copying  operations, sometimes referred to as “copy centers.” We considered  volumes above 500 copies of a single page and 2,500 copies in the  aggregate of multiple pages to be “duplication,” and we considered  volumes below that to be “copying.” For further information on the  definitions used and challenges they presented, see appendix I.
To develop a list of agencies that might be currently operating in-house  printing plants, we identified 31 agencies with printing plants listed in the  1990 JCP Regulations and an additional 16 agencies identified by  reviewing agency obligations of funds identified in the Office of  Management and Budget’s (OMB) “printing and reproduction” object class  data for fiscal years 2009 through 2011. We included only those  agencies that had obligated funds in at least 2 years from fiscal years  2009 to 2011. This resulted in a total universe of 47 agencies. To  describe agencies’ current printing practices, such as the operation of in- house printing plants, we administered a survey from January 2013  through March 2013. We received a 100 percent response rate on our  survey and analyzed the information obtained.
To obtain information about selected agencies’ current printing  operations, including their volumes and spending, we interviewed officials  from the six agencies from our survey universe whose printing and  reproduction obligations in fiscal years 2009, 2010, and 2011 together  constituted the majority—roughly 80 percent—of total federal obligations  to printing and reproduction. Those agencies were the Departments of  Commerce (Commerce), Defense (DOD), Health and Human Services  (HHS), State (State), and Veterans Affairs (VA), and the U.S. Postal  Service (USPS). We interviewed printing and budget officials from these  agencies, and obtained information on their printing operations, including  data on volumes and spending. Findings from these interviews cannot be  generalized to other federal agencies.
Although we used OMB obligations data to identify agencies to be  included in our review, we could not use the same obligations data to  describe agencies’ in-house printing activities because obligations data  includes other agency printing activities, such as printing sent to GPO and  private printers. As such, we relied on interviews with agency officials to  describe their in-house printing. The spending data agencies provided fell  into two categories: (1) printing and reproduction expenses and (2)  printing and reproduction obligations. For the purposes of this report, we  refer to both as “spending.” “Obligations” and “expenditures” capture  different aspects of the budgeting process—obligations are the legal  commitment to pay for a good or service while expenditures are the  actual disbursement of money. For the purposes of this report we assume  that there is a relatively short time lag between obligation and expenditure  for printing and reproduction activities, and therefore that the difference is  not material. Therefore, we refer to both obligations and expenditures as  a single “spending” category.
To understand and describe federal printing authorities, we reviewed Title  44 of the U.S. Code and the 1990 JCP Regulations, and interviewed  officials from GPO and other agencies.
We conducted this performance audit from August 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 that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives. See appendix I for more  detailed information on our scope and methodology.
subsections: section_title: Background
paragraphs: The JCP and the GPO have prominent roles in federal government  printing. The oldest joint committee in Congress, the JCP was established  in 1846 and is comprised of five Representatives and five Senators. It  oversees the operation of GPO, which by law is the principal printing  organization for federal agencies. The JCP exercises oversight over  government printing, and is authorized to “use any measure it considers  necessary to remedy neglect, delay, duplication or waste in the public  printing and binding, and the distribution of Government publications.” To  assist in carrying out its responsibilities, in 1990 the JCP updated the  Government Printing and Binding Regulations, which require agencies to  report semi-annually to the JCP any in-house printing and any printing  that exceeds 5,000 production units of a single page or 25,000 production  units in the aggregate of multiple pages.
GPO was established in 1861 to print government documents and  disseminate them to the public. Title 44 of the U.S Code, Public Printing  and Documents, provides that all printing for Congress, the executive  branch, and the judiciary (except the Supreme Court) is to be done by or  contracted by GPO, unless otherwise exempted. GPO prints at its in- house plant in Washington, D.C., and one other secure facility for  passports and smart cards only, but it contracts with private printers to  produce the majority of printing for the federal government. At its in-house  plant, GPO prints primarily congressional documents, such as the  Congressional Record. GPO offers different programs and services such  as GPO Express, which allows agencies to print directly to FedEx Office  and other private sector vendors, and the GPO Simplified Purchase  Agreement Program, which provides a list of pre-approved private  printers and stated prices for federal agencies to use when selecting a  printer. GPO receives funding through direct appropriations ($126 million  in fiscal year 2012), collection of an approved fee-for-service from other  federal agencies for print procurement, and the sale of publications to the  public.
GPO’s activities also include providing public access to official  government documents though the FDLP and GPO’s Federal Digital  System (FDsys) website. The Superintendent of Documents, who heads  GPO’s Information Dissemination division, is responsible for collecting  government products and disseminating them to the public through a  network of approximately 1200 depository libraries and online catalogues.  GPO evaluates documents to identify those that contain information on  U.S. government activities or are important reference publications, and  should therefore be disseminated to a depository library. Title 44 requires  that federal agencies make their publications available to the  Superintendent of Documents for cataloging and distribution though the  FDLP. With the onset of digital publishing, the FDLP has been  transformed into a primarily electronic program, obtaining and distributing  federal documents digitally. GPO’s FDsys website, which offers an online  catalogue of official government digital documents, also aids in the  collection and preservation of government publications and provides  access to the public.
subsections: section_title: Printing Definitions
paragraphs: Federal government printing definitions are outlined in statute and  regulation. Title 44 at Section 501 Note defines printing as the processes  of composition, platemaking, presswork, duplicating, silkscreen  processes, and binding. The 1990 JCP Regulations include the definitions  of key printing terms applicable at that time. Prior to 1994, Title 44 did not  include duplicating in the definition of printing, but in 1994, the Title 44  definition was updated to include duplicating (i.e., printing done on high- speed duplication machines) as a printing process. However, the 1990  JCP Regulations were not updated to include duplicating.
In our review, we identified two main categories of agency printing used  today— ink-based, and toner-based or ink-jet-based:  Ink-Based Printing (also referred to as conventional printing) is a  water and ink-based process that uses machines called printing  presses to produce material such as publications and other  documents. Presses use plates to transfer images onto a final paper  document. Conventional presses are relatively costly to set up,  making the first impression of a document expensive, but costs  decline as the volume of copies increases, which makes it cost- effective for high volume print jobs. Ink-based printing uses offset or  digital printing presses. Offset printing presses typically have many  open areas where the machinery can be manually adjusted, and can  take up a large amount of space (see fig. 1).
A digital printing press also uses plates to transfer images and ink, but  the process is computerized and the press is mostly closed because it  does not need the same level of manual adjustments (see fig. 2).
Toner-Based Printing (also referred to as duplication) is a process on  machines that use either heat to transfer an image on paper or toner  or ink-jet to transfer an image to paper. Toner-based printing is  typically done on one type of equipment, a high-speed duplication  machine, also referred to as a high-speed copier. This refers to a high  capacity toner-based machine, typically capable of 100 or more black  and white images per minute with some finishing capabilities (e.g.,  staples, collating, limited binding, etc.) (see fig. 3). These machines  typically have a higher printing speed and capacity than typical “walk- up” office copiers.
section_title: Current Printing Practices Show Changes since 1990
paragraphs: Since the JCP Regulations were updated in 1990, agencies’ printing  operations have changed in scale and type. Printing industry and  government data suggest that the total volume of printed material has  been declining for at least the past 10 years. A major factor in this  decline is the use of electronic media options, such as digital publishing.  As such, federal agencies publish more documents directly to the Internet  where the public can access them, bypassing the need for the agency to  print hard copies. At the same time that digital publishing was increasing,  digital printer/copier technology was developing. In circumstances where  agencies still needed hard copies to be printed, digital printers and  copiers allowed federal agencies to produce documents themselves that  formerly would have required professional printing expertise from outside  vendors such as GPO or private printers.
subsections: section_title: Fewer In-house Printing Plants Are in Operation Than in 1990
paragraphs: Based on definitions we developed in conjunction with GPO and the  Interagency Council on Printing and Publication Services, among the  agencies in our survey universe, we measured 64 percent fewer in-house  printing plants than the number included in the 1990 JCP Regulations.  The 1990 JCP Regulations listed 231 authorized in-house printing  plants; agencies we surveyed reported operating 84 in-house plants.  Although there was an overall decline in the number of printing plants,  there was not a decline across all agencies—9 of the surveyed agencies  reported a decrease in the number of plants, 14 agencies reported no  change in the number of in-house plants, and 8 agencies reported an  increase in the number of in-house plants.
DOD accounted for the greatest decline in in-house printing plants. For  example, the 1990 JCP Regulations listed 142 in-house printing plants for  the armed services and the Defense Logistics Agency (DLA), which  currently manages the majority of DOD’s printing infrastructure. DLA  officials reported managing 17 in-house plants in our survey (see fig. 4).
Other agencies that reported declines showed less dramatic reductions,  such as the Department of Energy, which had 18 plants on the 1990 list,  and reported 5 plants in our 2013 survey. A decline in the number of in- house plants could be due to some agencies reducing their printing and  focusing more on digital publications. One factor that could have  influenced the increased emphasis on digital publications is a November  9, 2011, executive order promoting efficient spending. This executive  order included a provision encouraging agencies “to limit the publication  and printing of hard copy documents and to presume that information  should be provided in an electronic form, whenever practicable, permitted  by law, and consistent with applicable records retention requirements.”
section_title: Agencies Reported Operating Primarily Duplication Equipment at In-house Printing Plants
paragraphs: The vast majority of agencies that currently operate in-house printing  plants reported operating duplication equipment. That is, most agencies  reported operating high-speed duplication machines, and fewer reported  operating conventional printing presses. Of the 32 agencies operating in- house printing plants, 17 reported that all of their in-house printing was  duplication, and another 14 agencies reported operating some duplication  equipment in addition to ink-based conventional printing presses. The  remaining agency did not report its type of equipment (see fig. 5). No  agency reported having only ink-based conventional printing presses at  its in-house plants.
In addition to agencies operating fewer printing plants and conducting  more duplication, interviews with selected agencies showed declines in  printing volumes in recent years. We interviewed six agencies that,  according to OMB budget data, accounted for about 80 percent of total  federal printing and reproduction obligations. Of those six agencies, five  reported declines in total printing volumes between fiscal year 2009 and  fiscal year 2011, ranging from 6 percent to 59 percent. One agency  reported an 11 percent increase in printing volumes and told us it was  due in part to opening an additional in-house plant in 2009. All six  agencies estimated a decrease in total spending on printing and  reproduction between fiscal year 2009 and fiscal year 2011. Decreases  ranged from as little as 0.1 percent to over 90 percent. All six agencies  also reported greater spending on printing sent to GPO and private  printers than on in-house printing or duplication. For example, in fiscal  year 2011, USPS reported spending $5.8 million on in-house printing and  spending $108.3 million on printing sent to private printers. Similarly,  HHS reported spending $0.4 million on in-house printing, and $50.2  million on printing sent to GPO or private printers in fiscal year 2011.
Agencies told us that they use a number of factors such as sensitivity,  cost, volume, turnaround time, and in-house capabilities to determine if  they will print in-house or externally through GPO or private printers. For  example, DLA officials told us DLA produces some documents, such as  those printed for the President, at in-house facilities to accommodate the  short turnaround time and possible sensitive nature of the documents. VA  officials said they send large volume print orders or documents requiring  special finishing to private printers. For example, VA officials told us they  used GPO and its approved private printers to print 2.9 million copies of  its 2011 federal benefits booklet for veterans, survivors, and dependents  because private printers could better handle this quantity than VA could  in-house.
section_title: Current Printing Practices Are Not Fully Reflected in Existing Printing Authorities
subsections: section_title: 1990 JCP Regulations
paragraphs: Even with these changes in agencies’ printing, the definition of “printing”  has not been updated in the 1990 JCP Regulations, which outline  printing-related definitions and list authorized agency in-house printing  plants. In 1994, Title 44 was updated to include “duplicating” in the  definition of “printing,” so that it read “… ‘printing’ includes the processes  of composition, platemaking, presswork, duplicating, silk screen  processes, binding, microform, and the end items of such processes.”  However, the 1990 JCP Regulations have not been updated to include  duplicating in the definition of printing, and duplicating is not separately  defined in either authority. For example, Title 44 does not separately  define duplicating, and the 1990 JCP Regulations include a definition for  “duplicating/copying,” such that it is not distinguished from “copying.”
Some agencies had difficulty using the definitions we created or  identifying the number of their in-house facilities that performed  duplication and qualified as printing plants. As mentioned above, to  facilitate consistent data gathering from federal agencies on their printing  activities, we worked with GPO and the Interagency Council on Printing  and Publication Services to establish working definitions that included the  Title 44 definition of printing and an updated definition of duplicating. In  our survey, three agencies told us their definition of printing differed from  ours. Two of those reported using the 1990 JCP Regulations printing  definition, which does not include “duplicating”. Similarly, VA officials  believed their agency operated one in-house printing plant, but in our  discussion officials noted that the facility does not typically produce work  that exceeds the volume limits of “duplication” and as such would not  qualify as a printing plant. Postal Service officials reported that its 67  district offices do not track printing volumes, and thus could not determine  if those offices’ printing operations would qualify as printing plants. We  excluded these VA and Postal Service plants in our tally.
Some agencies also had difficulty providing volumes and spending data  under these definitions. For instance, printing officials from Commerce’s  bureaus told us that they each tracked printing differently—some tracked  pages while others tracked the number of jobs. Regarding spending,  some printing officials told us they combined in-house printing and  printing through GPO and its contractors in their spending estimates while  others were able to report these amounts separately. For example, DLA  officials said that they do not typically track volumes by our duplication  volume limits, and as such would not track spending at facilities (i.e.,  printing plants) that may exceed those volumes. However, at our request,  DLA officials reviewed production at the agency’s in-house facilities and  identified plants that met our definitions, and then estimated spending at  these plants. Other agencies we interviewed, such as the Postal Service  and the State Department, provided total spending for all jobs printed at  their in-house printing plants. As such, this data could include jobs printed  at volumes below those in the provided duplication definition.
Agencies may also have had difficulty providing volumes and spending  data because of decentralized printing practices. For instance, five  agencies reported that their printing operations were dispersed across the  agency, which meant that officials responsible for printing operations did  not have readily available information on agency-wide printing operations.  One was the Department of Commerce, which houses 12 bureaus and  agencies that operate independently and differently. Commerce officials  told us that because printing is dispersed, there was not a single official  who could report on printing across the agency. Health and Human  Services’ four divisions with printing operations also reported operating  with their own distinct printing officials and practices. In these cases, each  division provided its own volume and spending information, which could  lead to inconsistencies in data across bureaus or sub-agencies.
In addition, the 1990 JCP Regulations provide that federal agencies  report on their print operations to the JCP, but the requirements do not  address duplication. The 1990 JCP Regulations state that agencies shall  report printing operations semi-annually to the JCP, on information such  as the total cost of printing and an inventory of plant equipment at in- house printing plants. Officials from four of the six agencies we  interviewed reported that they did not recently send reports on their  printing operations to the JCP, and JCP staff told us they received only a  few reports in the last 5 years. Discussions with officials from one agency  suggested a reason for this may be that some agency officials believed  they are only required to report on printing plants with offset or  conventional printing equipment, not those with duplication equipment.  Since the reporting requirements date back to 1990, before Title 44 was  updated to include duplicating in the definition of printing, neither the 1990  JCP Regulations nor the JCP report forms specify that agencies are  required to submit reports for printing plants that agencies may consider  duplication plants. Officials from one agency told us they did not report to  JCP because they did not have any in-house facilities, and officials from  another agency noted that they were exempt from the reporting  requirements. Additionally, officials from a bureau at one agency told us  they send JCP reports to an in-house printing officer, suggesting some  confusion regarding reporting requirements.
JCP staff told us they recognize the 1990 JCP Regulations do not include  duplication in the definition of printing, and are working to revise this  guidance. Specifically, JCP staff are in the process of developing printing  definitions that more closely reflect current printing practices, particularly  for “duplication” activities. JCP staff also told us that they are working to  streamline reporting requirements for agency printing officials.
The majority of government documents are published digitally  (electronically produced and then disseminated over the Internet);  however, the provisions in the law that require agencies to submit  documents to the Federal Depository Library Program (FDLP) do not  reference digital publishing. GPO estimates that more than 90 percent of  all government information is published digitally. Title 44 outlines the  types of documents that are required to be submitted to the FDLP, upon  request, but does not reference digital documents explicitly. Currently,  Title 44 defines a “government publication” as “… informational matter  which is published as an individual document at Government expense, or  as required by law.” Title 44 does not specify if “published” includes  digitally published documents. Officials from selected agencies told us  they do not submit digital documents to FDLP, and two reported that  they do not have any policies or procedures for submitting documents to  the FDLP regardless of whether the documents were printed at their in- house printing plants or published electronically. For documents printed  through GPO, agencies are not required to make a determination about  whether a document should be submitted to FDLP, as GPO typically  identifies documents that could be of interest to the FDLP and then, if  FDLP request them, sends them directly to the FDLP. Some agencies’  officials told us they rely on GPO for this service, and do not submit digital  documents to the FDLP.
FDLP staff have taken a number of steps to address this challenge, and  to obtain digital documents from agencies. FDLP staff told us they focus  on educating agencies about document submission requirements, and  searching for and locating possible “fugitive documents”—documents that  agencies published and FDLP staff believe should have been submitted  to the FDLP. In a January 2013 report, the National Academy of Public  Administration (NAPA) recommended that GPO work with depository  libraries and other library groups to develop a comprehensive plan for  preserving the print collection of government documents, including a  process for ingesting digitized copies into FDsys, GPO’s online system  that provides free access to government publications. In response to  NAPA’s recommendation, GPO noted that GPO and the depository library  community have long recognized the need to catalog and preserve the  tangible collections that GPO has distributed to federal depository  libraries since 1861, and that implementing this recommendation will be  incorporated into GPO’s national plan for the future of the FDLP.  Because NAPA’s review was ongoing and GPO was outside the scope of  our review, we do not make recommendations regarding FDLP  submissions to GPO in this report (see app. I for more information on our  scope and methodology).
section_title: Agency Comments
paragraphs: We provided copies of our draft report to GPO and DOD for their review  and comment. GPO generally agreed with our findings and provided a  letter and technical comments, which we incorporated as appropriate.    DOD did not provide comments.
We are sending copies of this report to the appropriate congressional  committees. The report will also be available at no charge on the GAO  Website at https://www.gao.gov  If you or your staff have any questions about this report, please contact  me at 202-512-2834 or stjamesl@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix V.
section_title: Appendix I: Objectives, Scope and Methodology
paragraphs: To address our objectives, we developed working definitions of key  printing terms—“printing”, “duplication”, and “printing plant”—to use when  surveying and interviewing agencies on their current printing practices. To  do this we used existing statutory language for “printing” and “printing  plant” from Title 44 of U.S. Code, Public Printing and Documents, and the  Joint Committee on Printing’s 1990 Printing and Binding Regulations  (1990 JCP Regulations). To define “duplication” we worked with GPO and  the Interagency Council on Printing and Publication Services to update  the definition of duplication in the 1990 JCP Regulations.
We considered volumes above 500 copies of a single page and 2,500  copies in the aggregate of multiple pages “duplication,” and volumes  below that “copying”. This allowed us to identify agencies’ printing  operations that qualified as printing plants rather than lower volume  copying operations, sometimes referred to as “copy centers”. In  interviews with selected agencies, printing officials expressed confusion  over this definition of “duplication”, in part due to the volume limits  distinguishing duplication from copying. The volume limits we used were  similar but not the same as limits outlined in the 1990 JCP Regulations on  the number of pages agencies are permitted to produce in-house without  prior authority of the JCP (5,000 copies of a single page or 25,000 in the  aggregate of multiple pages). We clarified our definitions when possible,  but it is possible that agency officials’ confusion could have affected the  number of printing plants reported in our survey. See table below for a list  of how each printing term was defined in the 1990 JCP Regulations, Title  44, and by GAO with assistance from GPO and the Interagency Council  on Printing and Publication Services.
To identify agencies that could be operating in-house printing plants, we  developed a universe consisting of agencies authorized in the 1990 JCP  Regulations and agencies that had obligated funds to the “printing and  reproduction” object class in at least 2 years between fiscal years 2009  and 2011. Agencies report printing and related obligations in this object  class. Data in the various volumes of the President’s budget request,  including object class data, undergo rigorous review by the OMB, and  accordingly, are generally considered sufficiently reliable for most of  GAO’s purposes. This includes using this data to select agencies to  survey.
For the purposes of our review we made a number of adjustments to the  1990 JCP Regulations list of 36 agencies. First, we combined the armed  forces and their plants, which were listed separately in the 1990 JCP  Regulations, under the Defense Logistics Agency (DLA) since DLA took  over all printing plants for the armed forces. Second, we excluded the  Administrative Office of U.S. Courts, due to its being outside the  executive branch; GPO, as it was outside the scope of our review, and  the National Academy of Public Administration since it had ongoing  related work on GPO; and the Panama Canal Commission, as it was de- commissioned in 1999. Finally we separated the Social Security  Administration from Health and Human Services. In 1990 the Social  Security Administration was a sub-agency with an in-house printing plant  within Health and Human Services, but it became an independent agency  in 1994. With these exceptions, 31 of the agencies from the 1990 list  remained in our universe.
Through budget obligations data we identified 16 additional agencies with  at least 2 years of printing and reproduction obligations for fiscal years  2009 through 2011. This resulted in a total universe of 47 agencies with  possible in-house printing plants.
To describe how federal printing regulations and statutes reflect current  printing practices, we reviewed legal documents such as Title 44 of the  U.S. Code and the 1990 JCP Regulations, administered a survey to the  universe of agencies described above, and interviewed officials from the  printing industry, GPO, and other federal agencies.
To describe agencies’ printing volumes and spending, we interviewed the  six agencies from our survey universe whose printing and reproduction  obligations in fiscal years 2009, 2010, and 2011 together constituted the  majority—roughly 80 percent—of total federal obligations to printing and  reproduction. Those agencies were the Department of Commerce, the  Department of Defense, Health and Human Services, Department of  State, U.S. Postal Service, and Veterans Affairs. We interviewed printing  and budget officials from these agencies, and obtained information on  their printing operations, including data on printing volumes and spending.  Findings from our interviews with selected agencies cannot be used to  generalize results to the entire population.
To describe agencies’ in-house printing spending, we relied on data  provided by selected agencies since federal printing and reproduction  obligations may not reliably describe agencies’ in-house printing  spending. This is partially due to challenges with obligations data we have  previously reported, such as that obligations categories are not mutually  exclusive (e.g., it is possible for some printing and duplication obligations  to be categorized under a different object class, and vice versa). We also  found that the printing and reproduction object class includes printing  done through GPO or external private printers as well as that done at  agencies’ in-house printing plants. As such, we relied on interviews with  agencies to describe their in-house printing operations and collected  spending information from agencies for analysis. We also asked agencies  to provide spending information on the printing that they sent out to GPO  and private printers. Some agencies provided printing expenses and  others provided obligations, but for the purposes of this report, we refer to  both as “spending.” Obligations and expenditures capture different  aspects of the budgeting process – obligations are the legal commitment  to pay for a good or service while expenditures are the actual  disbursement of money. For the purposes of this report we assume that  there is a relatively short time lag between obligation and expenditure for  printing and reproduction activities, and therefore that the difference is not  material. As such, we refer to both obligations and expenditures as a  single “spending” category.
subsections: section_title: Government Printing Survey
paragraphs: To describe agencies’ current printing practices, such as operation of in- house printing plants, we administered the survey described above to the  47 agencies in our universe from January through March 2013. Results  from that survey are presented in this report, and the questions asked in  our survey instrument can be found in appendix III. We received a 100  percent response rate on the survey and analyzed the information  obtained.
subsections: section_title: Administration of Survey and Quality Assurance
paragraphs: We developed a questionnaire using Microsoft Excel to obtain information  about federal agencies in-house printing operations. We identified  potential survey recipients from a list of agency print contacts provided by  GPO and the Interagency Council on Printing and Publication Services.  We tested the questionnaire with print officials from five agencies  included on our list of potential respondents. We selected these agencies  to represent different printing and reproduction obligations and to provide  a mix of agencies we identified through obligations data and those listed  in the 1990 JCP Regulations. We conducted these survey pretests to  determine if the questions were understandable and measured what we  intended, and to ensure that the survey was not overly burdensome. On  the basis of feedback from the pretests we modified the questionnaire as  appropriate. In late January 2013, we sent an email alerting agency  contacts to the upcoming survey; the survey was delivered to recipients  via email message a few days later. Using the questionnaire, we  requested contact information for print officials; feedback on the  definitions used in the survey, each agency’s cited authority to operate in- house printing plants, and information on in-house printing plants such as  location and equipment used. We did not independently verify if the  information in the surveys was accurate. For agencies in the JCP 1990  Regulations, we provided a list of plants that were authorized in 1990 and  asked them to verify if a listed plant was operational or not operational.  We also asked that the agencies identify any additional plants that were  not included in the 1990 list. For agencies that were not included in the  1990 list but were added to our survey population using obligations data,  we asked that they provide plant information. To help increase our  response rate, we sent two follow-up emails and called agency officials  from January through March 2013.
section_title: Nonsampling Error
paragraphs: The practical difficulties of conducting any survey may introduce some  types of errors, commonly referred to as nonsampling errors. For  example, differences in how a particular question is interpreted or the  sources of information available to respondents can introduce unwanted  variability into the survey results. As we discussed previously, some of  our survey respondents reported having difficulty with the definitions of  printing, duplication, and printing plant that we included in our survey. We  included steps in the design of the questionnaire, such as testing the  instrument, and followed-up with agencies to clarify responses during the  data collection for the purpose of minimizing such nonsampling errors.
We took the following steps to increase the response rate: pretesting the  questionnaires with agency officials with print operation knowledge,  conducting multiple follow-up calls and emails to encourage responses to  the survey, and contacting respondents to clarify unclear responses.
We conducted this performance audit from August 2012 through 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.
section_title: Appendix II: 47 Surveyed Agencies’ In-house Printing Plants
paragraphs: GAO surveyed 47 agencies to determine if they operated in-house  printing plants. To identify agencies that could be operating in-house  printing plants, we developed a universe consisting of agencies  authorized in the 1990 Government Printing and Binding Regulations and  agencies that had obligated funds to the “printing and reproduction” object  class in at least 2 years between fiscal years 2009 and 2011. The tables  below contain the agencies in this universe and the number of plants  authorized in the 1990 Printing and Binding Regulations and/or plants  reported in 2013 in the GAO Government Printing Survey.
section_title: Appendix III: Questions from GAO’s Survey of Federal Printing Activities and Plants
paragraphs: We administered a survey focused on government printing operations to  print officials at 47 agencies we determined could be operating in-house  printing plants. We provided questions to identified agency print officials  using Microsoft Excel to obtain information about federal agencies’ in- house printing operations. This appendix contains the questions from the  survey questionnaire.
We provided the following definitions for agencies to use when  answering our questions:  Printing includes the processes of composition, platemaking, presswork,  duplicating, silkscreen processes, binding, microform, and the end items  of such processes. Duplicating includes high-speed duplicating. (Title 44  Sec. 503 Note)
Duplication (a) by automatic copy-processing or copier-duplicating  machines, producing copies by electrostatic, thermal, or other copying   processes, and using exclusively toner or ink-jet type inks instead of ink;  and (b) in volumes that exceed either 500 copies of a single page or  2,500 production units in the aggregate of multiple pages, per job.
We asked officials from all surveyed agencies the following  questions regarding the definitions of key print terms:  1.  Does your agency have official definitions of "printing", "duplication,"  or "printing plant" that differ from any of the three definitions above?  2.  If yes, please provide your agency's definitions below:  3.  What authority are the definition(s) from? (Please include statute or  other citation(s).)
We asked agency officials the following questions, with specific  instruction, to determine how many in-house printing plants each  agency operates:  4.  What is the total number of in-house printing plants (including  duplication plants) operated by your agency, across all departments  and bureaus within the agency?
When completing your answer, please include the following types of  facilities:
Any plant that produces printing (including duplicating), owned or
Duplication plants and high speed duplication plants that use toner  or ink-jet machines and typically produce more than 500 copies of  a single page or 2500 production units in the aggregate, per job.
When completing your answer, please exclude the following types of  facilities:
Any small plants or “copy centers” that do NOT produce more  than 500 single/2500 in aggregate production units, per job.  5.  Which of the following is the source of your statutory authority to  operate in-house printing plants (including duplication plants)?
1990 Government Printing and Binding Regulations
Some other statutory authority
Don’t know  a. If you selected "Some other statutory authority" in Q5, please  specify that authority in the space provided here.
We asked only print officials from agencies authorized to operate in- house plants listed in the JCP 1990 Government Printing and  Binding Regulations the following questions to determine the  operating status and additional information on those listed in-house  plants:  6.  The table provided contains information on printing plants operated by  your agency, as indicated in the 1990 Government Printing and  Binding Regulations. Please indicate the current status of each plant  (Q6a), and complete the requested information for all operational  plants (Q6b - Q6f).  a. What is the current status of this plant?   o  Operational  o  Not Operational  b. Does this plant produce the following types of products? (Yes,  No, Don’t Know)  o  Toner or Ink Jet on Paper:   o Ink on Paper:   o  Other products (i.e. other substrates):   If you answered "yes" to other products, please provide two  examples of other products below:  c. Does this plant contain any of the following types of equipment?  (Yes, No, Don’t Know) If yes, how many?  o  Offset printing press (ink):   o  Digital printing press (ink):   o  High speed duplication machine (ink-jet or toner):   d. Approximately how much of this plant's printing volume is offset  printing? (All, More than half, About half, Less than half, None)  e. Approximately how much of this plant's printing volume is digital  printing? (All, More than half, About half, Less than half, None)  f. Approximately how much of this plant's printing volume is  duplication? (All, More than half, About half, Less than half, None)
We asked all survey participants the following questions about any  in-house printing plants not listed in the JCP 1990 Printing and  Binding Regulations:  7.  If your agency operates any in-house printing plants (including  duplication plants) that were NOT included in the previous question  (Q6), please list the name and location of the plant and complete the  requested information using the table below.
If you do not have any in-house printing plants (including duplication  plants) to enter on this tab, please check this box and proceed to the  next tab:  a. Name of Plant:  b. Location of Plant (City and State):  c. Does this plant produce the following types of products? (Yes,  No, Don’t Know)  o  Toner or Ink Jet on Paper:   o Ink on Paper:   o  Other products (i.e. other substrates):   If you answered "yes" to other products, please provide two  examples of other products below:  d. Does this plant contain any of the following types of equipment?  (Yes, No, Don’t Know)  o  Offset printing press (ink):   o  Digital printing press (ink):   o  High speed duplication machine (ink-jet or toner):   e. Approximately how much of this plant's printing volume is offset  printing? (All, More than half, About half, Less than half, None)  f. Approximately how much of this plant's printing volume is digital  printing? (All, More than half, About half, Less than half, None)  g. Approximately how much of this plant's printing volume is  duplication? (All, More than half, About half, Less than half, None)
section_title: Appendix IV: Comments from the Government Printing Office
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Sharon Silas (Assistant Director),  Melissa Bodeau, Leia Dickerson, Sarah Farkas, Kathleen Gilhooly, Leigh  Ann Haydon, Carol Henn, Hannah Laufe, John Mingus, Jr., Betsey Ward- Jenks, Elizabeth Wood, and William T. Woods made significant  contributions to this report.