Federal Reports: OMB and Agencies Should More Fully Implement the Process to Streamline Reporting Requirements
Published: 2017-07-14T00:00:00

Fast Facts:
When federal agencies find that some of their annual reports to Congress are outdated or duplicative, they can propose to eliminate or modify related reporting requirements.
A 2010 law directs the Office of Management and Budget to coordinate an annual review of agencies' plans and reports.
The reviews have led to new proposals and elimination of some required reports. However, OMB does not coordinate this effort every year.
Among other things, we recommended that OMB adjust its process to comply with the law.

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal government produces thousands of plans and reports each year to meet the informational needs of Congress. GPRAMA established a process to eliminate or modify reports that may be outdated or duplicative.
GAO was asked to examine OMB and agencies' implementation of GPRAMA provisions to identify unnecessary reports and develop proposals to eliminate or modify them as appropriate. GAO's objectives were to (1) review agencies' report modification proposals, (2) assess the extent to which OMB and agencies implemented related GPRAMA requirements, and (3) describe how selected federal agencies determined which plans and reports are outdated or duplicative.
To address these objectives, GAO reviewed agencies report modification proposals, relevant laws, OMB guidance, and agency documents. GAO interviewed staff from Congress, OMB, and six selected agencies. Agencies were selected based on the number of proposals they published. GAO reviewed selected agencies' complete list of reports and internal guidance, and analyzed the contents of their report modification proposals.
section_title: What GAO Found
paragraphs: The GPRA Modernization Act of 2010 (GPRAMA) requires the Office of Management and Budget (OMB) to coordinate an annual review of agencies' plans and reports for Congress and publish proposals to eliminate or modify reports that may be outdated or duplicative. Since the passage of GPRAMA, OMB posted three lists of proposals (in 2012, 2014, and 2016) on Performance.gov. These lists contained a total of 523 new proposals. In 2014, Congress acted on agencies' report modification proposals by eliminating 51 reporting requirements, including 34 that were identified through this process.
As shown in the figure, GAO found that OMB did not implement the report modification process on an annual basis, as required by GPRAMA. OMB staff said that they implemented the report modification process every other year because reporting requirements are relatively static. OMB staff said, in future years, they plan to implement the process annually as required.
GAO also found that OMB is publishing agencies' proposals on Performance.gov, rather than in the President's annual budget as GPRAMA requires. OMB staff said that they published the proposals online rather than in the budget because the website hosts many GPRAMA resources. However, publishing or referencing the proposals in the President's annual budget, in addition to posting them on Performance.gov, may increase their visibility and usefulness to congressional decision makers and others. GAO also found that OMB's email instructions to agencies did not align with GPRAMA and Circular A-11 directives for agencies to review a complete list of reports, which could have resulted in a missed opportunity to identify additional report modification proposals. OMB staff stated that their email instructions are not a substitute for A-11 guidance, but also acknowledged that the instructions could have led to missed opportunities.
Selected agencies told GAO they periodically review or update their report modification proposals. Specifically, selected agencies said they involved relevant subject matter experts when developing proposals, and followed OMB instructions to submit their proposals, and consulted with Congress.
section_title: What GAO Recommends
paragraphs: GAO recommends that OMB submit or reference report modification proposals with the President's annual budget, and ensure that email instructions to agencies align with GPRAMA and Circular A-11 guidance. OMB staff agreed with the recommendations.

section_title: Letter
paragraphs: The federal government is one of the world’s largest and most complex  entities, running thousands of critical programs and delivering services  ranging from national security, to economic development, education,  public safety, and more. To effectively oversee the multitude of complex  and cross-cutting federal programs, Congress relies on executive branch  agency plans and reports. For example, agencies’ plans and reports  contain important information such as agency priority goals, evaluations  of program effectiveness, financial statements, and data to track  economic growth. Over time, Congress has updated reporting  requirements to meet its informational needs.
The federal government produces thousands of plans and reports each  year to meet the informational needs of Congress. While there will always  be a need for information, at times, both Congress and the executive  branch have raised questions about whether some reports may be  duplicative or outdated. By modifying or eliminating unnecessary  reporting requirements, congressional information needs can be better  met and resources can be reallocated to other priorities.
One of Congress’ more recent efforts to streamline federal reporting  requirements occurred with the passage of the GPRA Modernization Act  of 2010 (GPRAMA). Among other things, GPRAMA provisions establish  a process to reexamine the usefulness of certain existing reporting  requirements. Specifically, GPRAMA requires an annual review, based  on Office of Management and Budget (OMB) guidance, of all agencies’  reporting requirements, and requires OMB to provide Congress with  agencies’ proposals to eliminate or modify plans and reports that may no  longer be necessary. The Government Reports Elimination Act of 2014  eliminated or modified 51 reporting requirements, of which, 34 were  identified through the GPRAMA process. Most recently, in April 2017,  OMB issued a government-wide memorandum confirming the  administration’s intent to follow the GPRAMA provision to regularly review  reporting requirements. The memorandum also called for a review to  streamline other agency reporting not required in statute.
You requested that we review federal agencies’ compliance with  GPRAMA’s provisions to propose eliminating or modifying unnecessary  reports, and to describe the process being used to generate report  modification proposals. This report (1) reviews the information included in  agencies’ report modification proposals, and identifies the number of  proposals published by OMB; (2) assesses the extent to which OMB and  agencies implemented GPRAMA requirements regarding the elimination  or modification of unnecessary plans and reports; and (3) describes how  selected federal agencies determined which plans and reports were  outdated or duplicative.
To review the information included in agencies’ report modification  proposals and identify the number of proposals published by OMB, we  reviewed selected agencies’ full lists of reports for Congress, all agencies’  report modification proposals, and OMB guidance and instructions. We  analyzed agencies’ report modification proposals to determine the  number of proposals submitted from each agency and to categorize the  justifications provided by agencies. We assessed the reliability of  information included in agencies’ report modification proposals by  ensuring the completeness of information on modification proposals  provided by agencies, and by reviewing internal controls used by selected  agencies when validating information provided to OMB. Based on this  assessment we determined this information was sufficiently reliable for  the purposes of our objective.
To assess the extent to which OMB and agencies are implementing  GPRAMA requirements, we reviewed relevant agency documents  including OMB guidance, all agencies’ report modification proposals,  records of congressional consultations, and selected agencies’ complete  lists of reports for Congress (see next paragraph for a list of selected  agencies). To determine whether each agency met the percent threshold  established in the first year of implementation as required by GPRAMA,  we calculated the percentage of all reports that were published in 2012  for each agency that the agency believed to be unnecessary. We  interviewed staff from OMB and selected agencies to learn about their  methodology and process for developing proposals to eliminate or modify  reporting requirements. We spoke with staff from the House Committee  on Oversight and Government Reform and the Senate Homeland  Security and Governmental Affairs Committee to gather their perspectives  on consultations with agencies regarding their proposals to eliminate or  modify reports.
To describe how selected federal agencies determined which reports  were outdated or duplicative, we selected a non-generalizable sample of  six agencies for review based on the number of proposals submitted to  Congress for elimination or modification between 2011 and 2016. We  selected the two agencies that published the greatest number of  proposals—Department of Defense (DOD) and Department of Homeland  Security (DHS)—two that published one proposal—Consumer Product  Safety Commission and the Federal Communications Commission—and  the two closest to the average—National Aeronautics and Space  Administration (NASA) and the Department of the Treasury (Treasury).  Our findings based on these selected agencies are not generalizable. We  interviewed officials at these agencies responsible for developing and  submitting proposals to OMB. We also reviewed relevant agency  documents such as agencies’ lists of all reports they produce for  Congress, their report modification proposals, congressional  correspondence, and internal guidance or instructions provided to the  offices or components that were involved in generating and reviewing  proposals. A more detailed objectives, scope, and methodology is  provided in appendix I.
We conducted our work from June 2016 to July 2017 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.
subsections: section_title: Background
paragraphs: GPRAMA established a set of requirements to annually examine  potentially unnecessary plans and reports based on OMB guidance, and  for agencies to develop proposals to eliminate or modify them as  appropriate. GPRAMA defines unnecessary plans and reports as those  that are outdated or duplicative. For simplicity and consistency, we will  subsequently refer to plans and reports for Congress as “reports,” and will  refer to agencies’ proposals for eliminating or modifying unnecessary  reports as “report modification proposals.”
GPRAMA designates OMB a coordinating role in the process to develop  an annual list of report modification proposals for congressional  consideration. Specifically, GPRAMA requires OMB annually to determine  a minimum percentage of reports to be identified as unnecessary, and to  compile a list of agencies’ report modification proposals and then include  it in the President’s Budget. GPRAMA also provides OMB the option of  concurrently submitting legislation to Congress for eliminating or  modifying proposed reports on this list, as appropriate.
Most executive branch agencies are subject to GPRAMA requirements  for identifying and developing report modification proposals. GPRAMA  requires the Chief Operating Officer (COO) at each agency annually to  complete the following four activities:  1.  Compile a list that identifies all reports the agency produces for  Congress, in accordance with statutory requirements or as directed in  congressional reports.  2.  Analyze the list compiled to identify which reports are outdated or  duplicative of other required plans and reports, and refine the list to  include only the plans and reports identified to be outdated or  duplicative.  3.  Consult with the congressional committees that receive the agency- proposed outdated or duplicative reports to determine whether they  could be eliminated or consolidated with other reports.  4.  Provide a total count of reports compiled and the list of outdated and  duplicative reports identified to the Director of OMB.
These requirements are also included in OMB’s Circular A-11 guidance to  agencies, along with additional directions for agencies to follow when  implementing the law. For example, OMB clarifies that agencies’ full list of  plans and reports should be available to OMB and Congress upon  request. Furthermore, OMB’s A-11 guidance provides a timeline,  describes the information that agencies should include in their report  modification proposals, and delineates a process for submitting proposals  to OMB. Figure 1 outlines the process OMB uses to implement GPRAMA  requirements.
As the coordinating agency, OMB developed a template for agencies’  report modification proposals. Each proposal is to include the report title,  statutory requirement, proposed action for modification, and a justification  that explains why the agency identified the report as unnecessary.  Agencies can propose one of six recommended modifications: eliminate,  consolidate, reduce frequency, streamline, modify the due date, or modify  the report language. Figure 2 provides three examples of agencies’  proposals. OMB maintains a current list of proposals on  Performance.gov.
In addition to the GPRAMA process for developing report modification  proposals, agencies can use a number of other mechanisms or  authorities to identify duplicative or outdated reports and eliminate or  modify them, as appropriate. For example, agencies in our review  described efforts to work directly with congressional committees to  develop legislation to eliminate or modify reports. Agencies have also  provided report modification proposals in their annual budget submission  to OMB or directly to their authorizing committees, as part of a periodic  reauthorization process. In some instances, congressional committees  have initiated their own efforts to streamline reporting requirements. For  example, Congress passed the Reports Consolidation Act of 2000 which  authorized executive agencies, with the concurrence of OMB, to  consolidate or adjust the frequency and due dates of certain statutorily  required reports that focused on financial management and government  performance. At other times, executive branch leaders have chosen to  undertake internal efficiency reviews that have included efforts to identify  and eliminate duplicative or outdated reporting.
section_title: OMB and Agencies Developed Hundreds of Proposals for Report Elimination or Modification
subsections: section_title: Agencies Proposed to Eliminate or Modify Hundreds of Reporting Requirements
paragraphs: Since the passage of GPRAMA, OMB has publicly posted 788 report  modification proposals, which includes 523 new proposals and 265  proposals that were published a second time in 2016. These were  published in three lists (2012, 2014, and 2016) on Performance.gov. As  shown in figure 3, the total number of report modification proposals varied  by year.
Agencies varied in the number of new report modification proposals they  published over time as shown in figure 4. Thirty-two federal agencies  developed a total of 523 new proposals. Nineteen of the 32 agencies  published 10 proposals or fewer. Not surprisingly, the number of  proposals published by each agency was generally associated with the  total number of reporting requirements identified by agencies in 2012.  Specifically, we found that agencies that produced a greater number of  reports for Congress also generally developed the most report  modification proposals. Nevertheless, we found that the actual  percentage of reports identified as unnecessary varied by agency. See  appendix II for the percentages of each agency’s reports identified as  unnecessary in 2012. The number of proposals submitted may also vary  according to agencies’ needs. Agencies that determined that they have  fewer outdated or duplicative reports may have submitted fewer  proposals. For example, OMB staff told us that the Nuclear Regulatory  Commission did not submit proposals because they did not identify any  unnecessary reporting requirements.
For each report modification proposal, agencies provided one  recommended action: to eliminate, consolidate, reduce the frequency,  streamline, modify the report language, or modify its due date. As shown  in figure 5, 72 percent of agencies’ new proposals recommended  eliminating a report. The remaining 28 percent of new report proposals  recommended consolidating, reducing the frequency, or otherwise  modifying a report.
section_title: Agencies’ Proposals Included Justifications to Eliminate or Modify Reports
paragraphs: As instructed by OMB, agencies provided a justification explaining why a  report should be eliminated or modified. The length of these justifications  varied from one word to several sentences. While GPRAMA defines  unnecessary reports as outdated or duplicative, we found agencies  provided additional justifications for eliminating or modifying a report. We  identified a range of justifications and organized them into one or more of  the following themes: 1) Not useful or obsolete, 2) Duplicative, 3) No  funding, 4) Limited congressional interest, 5) Costs outweigh benefits, 6)  No clear justification provided, and 7) Other.
Based on a generalizable stratified random sample of 133 report  justifications, 65 percent of the justifications were characterized as  “Duplicative” or “Not useful or obsolete.” (See table 1.) The “Not useful or  obsolete” theme included agency justifications for reports that had  information that was insufficient to report, were outdated, or were for  programs that have been completed. For example, the Department of  State proposed that Congress eliminate a report on Kosovo  peacekeeping because “it addresses circumstances that have been  overtaken by events or otherwise no longer pertain.” We characterized  justifications as “Duplicative” if the agency reported the information in a  report was available online or in another report. The sixth theme, “No  clear justification,” includes agency justifications that were unclear or  recommended an action be taken—such as briefing Congress—rather  than offering an explanation for Congress to eliminate a report.
section_title: OMB and Agencies Have Not Fully Implemented GPRAMA Requirements Report Modification Proposals Were Not Developed Annually or Always Included in the President’s Budget
paragraphs: Between 2011 and 2016, OMB did not initiate the report modification  process on an annual basis as required. OMB staff told us that they  implemented the process every other year due to timing constraints and  because reporting requirements are relatively static and do not change as  frequently as other information used in the annual budget process. OMB  staff said they expect little change in report modification proposals from  one year to the next. Moreover, according to OMB, it takes time for  Congress to deliberate and act on agencies’ proposals. In 2012, OMB  published a proposal requesting that the report modification process  occur biennially, but no legislation was enacted amending the required  frequency of the process.
OMB staff told us they plan to discuss all statutory responsibilities with  congressional leaders from the 115th Congress, including whether the  report modification process should occur every other year instead of  annually. OMB staff also told us they plan to begin the next iteration of  report modification proposals in fall of 2017, corresponding with the fiscal  year 2019 budget process. However, they said that any new report  modification proposals will not be finalized and published until the release  of the President’s fiscal year 2019 budget.
GPRAMA requires OMB to include agencies’ report modification  proposals in the President’s budget; however, OMB instead published  agencies’ proposals on Performance.gov. OMB staff told us that they  decided to publish the proposals online rather than in the budget because  the website hosts many related GPRAMA resources and OMB staff  determined it would be the most appropriate location for this content.  Congressional staff we spoke with were not aware that OMB published  agencies’ report modification proposals online. OMB staff acknowledged  that the location of the proposals on FAQ page of the Performance.gov  website may be difficult for users to find, and will consider options to  improve accessibility of this information.
The President’s fiscal year 2013 budget referenced the publication of  proposals on Performance.gov. In subsequent years, the budget did not  reference proposals. Furthermore, the proposals were not always  published concurrently with the President’s budget. (See figure 6.) In  2012 and 2014, the report modification proposals were published months  after the release of the President’s budget. In 2016, OMB published  report modification proposals concurrent with the President’s budget on  Performance.gov.
OMB staff told us they understand the requirement to publish proposals  with the President’s budget but were concerned that the budget is already  a voluminous document and that report modifications would not get the  attention needed. Nonetheless, they pointed to the April 2017 OMB  memorandum that specifically states, “in accordance with the GPRA  Modernization Act of 2010, agencies should also include with their [fiscal  year] 2019 Budget submission a list of statutorily required reports they  believe should be eliminated or modified by Congress.” OMB staff told  us that while they prefer posting the report modification proposals on  Performance.gov, they will, at a minimum, begin referencing proposals in  future President’s budgets. However, they have not finalized plans to do  so. Referencing or publishing new proposals in the President’s annual  budget may increase their visibility and usefulness to congressional  decision makers and other stakeholders involved in developing and using  reports for Congress. In addition, including the list in the President’s  budget would not limit OMB’s ability to post the list on Performance.gov  as well.
section_title: In 2012, OMB Instructed Agencies to Develop Report Modifications Proposals for at Least 10 Percent of Their Total Reports, but Some Agencies Did Not Meet This Threshold for a Variety of Reasons
paragraphs: As required by GPRAMA, during the first year of enactment in 2012, OMB  instructed agencies to identify a minimum of 10 percent of all of their  reports for Congress as potentially unnecessary. According to data  provided to OMB by agencies, of  the 35 federal agencies that  participated in the process to streamline reporting requirements in 2012,  18 agencies did not meet the threshold, while 16 met or exceeded it. We  were unable to determine whether the Department of Defense met the  threshold because, according to DOD, the number of total reports we  obtained from OMB for 2012 was inaccurate. Instead DOD provided us  with a report from 2010 that cited a range of reports, from 600 to 800,  rather than one specific number for 2012. Agencies varied in the extent to  which they met the threshold. Six agencies at least doubled the threshold,  with 20 percent or more of their reporting requirements proposed for  modification. However, OMB’s published list identified no unnecessary  reports for 7 agencies.
OMB staff told us it was difficult for them to enforce the 10 percent  threshold for agencies that found value in their reports. OMB staff  explained that stakeholders within the Executive Office of the President  (EOP) found value in some reports that agencies proposed for  elimination, which made it more difficult for certain agencies to meet the  10 percent threshold. For example, an environmental policy council within  EOP removed several agency reports from the list of report modification  proposals because they determined the reports were still necessary.  However, other agencies were able to exceed the target. For example, in  2012 NASA reported that they had 42 reports for Congress and submitted  11 proposals, or 26 percent of their total. See appendix II for a list of all  agencies compliance with the 10 percent threshold in 2012.
Following the first year of enactment, GPRAMA requires the Director of  OMB to determine the minimum percentage of reports to be identified as  potentially unnecessary. OMB did not provide agencies with a minimum  threshold in subsequent years. OMB staff views the threshold percentage  as unnecessary and accepts the percentage achieved by each agency.  As such, OMB staff told us the effective threshold is zero.
section_title: OMB’s Email Instructions Did Not Fully Reflect GPRAMA and A-11 Guidance
paragraphs: OMB’s A-11 guidance includes all relevant requirements for agencies, but  its email instructions and other correspondence with agencies in 2015 did  not fully reflect this guidance. For example, OMB’s email instructions  conflicted with certain A-11 directives and GPRAMA, as shown in table 2.  Specifically, OMB’s email guidance to agencies did not instruct agencies  to compile a list of all of their reports for Congress. Instead, OMB  instructed agencies to update their prior list of report modification  proposals and add any new proposals if desired.
OMB staff told us their email instructions are in addition to, and not a  substitute for, Circular A-11 guidance, and they expect agencies to follow  the official A-11 guidance. However, as a result of OMB instructing  agencies to update their previously submitted report modification  proposals rather than analyzing their complete list of reports, agencies  may not have reviewed a comprehensive list of their reports, as required  by GPRAMA, when they developed proposals in fiscal year 2015.
Moreover, since the publication of the 2012 report modification proposals,  OMB has not instructed agencies to provide a total count of their reports  for Congress. Since 2012, at least one agency did not analyze their total  list of reports when developing new proposals because they followed  OMB’s email instructions to update their prior list of proposals.  Specifically, Treasury officials reported they updated their prior list of  report modification proposals by removing proposals that had been acted  upon or were no longer relevant, but could not confirm that all agency  reports were considered during this process. Consequently, agencies  may have missed an opportunity to identify all potentially unnecessary  reports and develop new proposals. OMB staff acknowledged that their  email instructions could have contributed to missed opportunities.
section_title: Selected Agencies Reported They Followed OMB Instructions to Develop Report Modification Proposals
paragraphs: In October 2015, OMB emailed agencies instructing them to update  previously published report modification proposals or to develop new  proposals, if desired, for publication concurrent with the President’s fiscal  year 2017 budget. OMB provided agencies a template with their  previously submitted proposals and asked them to make updates as  appropriate, such as by removing proposals if the corresponding reporting  requirements had been eliminated. The instructions also requested that  agencies consult with relevant congressional committees prior to  submitting proposals for OMB review in November 2015. All of the  selected agencies reported they followed OMB’s instructions when  identifying unnecessary reports and submitting their proposals. Some  agencies we spoke with also followed OMB A-11 directives to maintain a  total list of reports for Congress and to analyze this list when developing  new proposals.
subsections: section_title: Selected Agencies Reported They Maintain a Total List of Reports for Congress
paragraphs: Four of the six selected agencies provided us with a list of all of the  reports they produce for Congress. DOD and DHS officials also told us  they maintain a central list of all reports. In addition, agencies described  the methods they use to ensure their lists are regularly updated and to  track certain aspects of reporting requirements, such as the authorizing  statutes, congressional recipients, and due dates. For example, officials  at DOD told us that, beginning in 2000, the agency has maintained a  comprehensive list of all reports, and, since 2011, the agency has worked  with its component offices to track reports with set due dates to determine  whether they have been submitted to Congress. In another example,  DHS officials told us that their Office of the Executive Secretary maintains  a complete list of the agencies’ reporting requirements and updates and  disseminates the list within the agency on a biweekly basis.
section_title: Selected Agencies Reported They Analyzed Their Total List to Identify Their Initial List of Unnecessary Reports
paragraphs: Officials we spoke with from all of the selected agencies reported that, in  2012, they analyzed all of the reports they produce for Congress to  identify unnecessary reports and develop report modification proposals.  Specifically, these agencies delegated responsibility for developing  proposals to individuals with subject matter expertise and others with  knowledge about the agency’s reporting requirements. The agencies  forwarded OMB’s instructions to their components and offices and  directed them to analyze the total list to identify reports that may be  unnecessary. For example, officials at NASA’s Office of Legislative and  Intergovernmental Affairs (OLIA) told us that they provided OMB’s  instructions to NASA offices and mission directorates, including a list of all  relevant reports, and asked them to analyze the list to identify which  reports may be outdated or duplicative. The NASA OLIA maintains the  agency’s master list of reports, but relies on subject matter experts to  determine which reports may no longer be necessary. For certain reports  with overlapping jurisdiction, NASA assigned a single office as  responsible for the report, and instructed all relevant offices to coordinate  internally as they developed modification proposals.
section_title: Selected Agencies Described Using a Range of Approaches to Consult with Congress
paragraphs: Selected agencies described a range of approaches they used to consult  with Congress, including in-person meetings, briefings with congressional  staff, phone conversations, and email correspondence. For example,  DOD officials told us that the agency routinely involved Congress in  developing their proposals. Specifically, officials from DOD’s General  Counsel and their Office of Legislative Affairs told us they reviewed  agency report modification proposals on an annual basis and then  accompanied relevant component staff during briefings with  congressional committees to discuss their proposals. DOD officials told  us that subject matter experts coordinated with congressional liaisons and  other DOD staff with knowledge of the relevant reporting requirements to  vigorously pursue their proposals with Congress. In another case, NASA  consulted with Congress via email. The agency transmitted an email to its  authorizing committees—the Senate Committee on Commerce, Science,  and Transportation, and the House Committee on Science, Space, and  Technology—to inform them of the GPRAMA requirement to develop  report modification proposals, and provided a spreadsheet with their  proposals. NASA also provided a timeline for answering any questions  the committees may have had. Other agency officials told us they  informally consulted with relevant congressional committees. In  addition, in 2012, we reported that consultations provide Congress with  opportunities to influence the development of executive branch  performance information, and we identified a set of general approaches  for helping to ensure consultations are successful. (See appendix III.)
section_title: OMB and Selected Agencies Identified Actions That Could Help Improve the Report Modification Process
paragraphs: Officials at selected agencies provided a number of suggestions that they  stated could help improve the report modification process in future years.  Specifically:
Develop legislation to address proposals. Three of the six selected  agencies told us they worked alongside Congress to develop  legislation to modify reporting requirements at their agency. For  example, officials from DHS told us that Congress passed legislation  to modify the frequency of an annually recurring U.S. Coast Guard  report to one contingent on the occurrence of an event, such as an oil  discharge from a vessel that is likely to result in damages.
Synchronize timeline with Congress. OMB staff and NASA officials  suggested that agencies synchronize report modification proposals to  coincide with congressional decision making and the legislative  calendar. For example, officials from NASA suggested timing the  GPRAMA report modification to coincide with congressional plans to  develop and consider legislation addressing reporting requirements.  In 2012, OMB submitted a report modification proposal to request  Congress update GPRAMA reporting requirements to allow OMB to  publish proposals later in the year to provide agencies additional time  to consult with Congress.
Improve communication. Officials from four of the six agencies we  spoke with described a need to open lines of communication between  OMB, agencies, and Congress. For example, Consumer Product  Safety Commission officials told us it would be helpful if OMB were to  provide agencies with updates regarding the status of their proposals.  Going forward, OMB staff told us they plan to foster an environment of  open communication by involving agencies in communities of practice  and integrating the process more closely with agencies’ budget  submission routines.
section_title: Conclusions
paragraphs: GPRAMA provides OMB and agencies a mechanism to identify  unnecessary reporting requirements and propose they be eliminated or  modified, as appropriate. In 2014, Congress acted on agencies’ report  modification proposals by eliminating more than 30 reporting  requirements that agencies’ determined were unnecessary.
Despite the progress made in updating and modernizing reporting  requirements across the government, more can be done to fully  implement GPRAMA requirements and improve the report modification  process. Specifically, we found that OMB did not implement the report  modification process on an annual basis as required by GPRAMA. OMB  staff told us that they initiate the report modification process every other  year because reporting requirements are relatively static and do not  change as frequently as other information used in the annual budget  process. However, by implementing the report modification process on an  annual basis, OMB would be positioned to include new report  modification proposals in the President’s annual budgets, and agencies  would be given additional opportunities to propose eliminating or  modifying reports that may be unnecessary. OMB has also published  agencies’ proposals on Performance.gov, rather than in the President’s  annual budget as GPRAMA requires. OMB staff told us that they decided  to publish the proposals online rather than in the budget because the  website hosts many related GPRAMA resources, and OMB staff  determined it would be the most appropriate location for this content.  However, publishing or referencing the proposals in the President’s  annual budget may increase their visibility and usefulness to  congressional decision makers and other stakeholders involved in  developing and using reports for Congress.
OMB provided email instructions to agencies in 2015 instructing them to  update their list of proposed reports for modification or elimination, which  agencies generally followed. However, OMB’s instruction did not fully  reflect GPRAMA and Circular A-11 requirements. For example, the email  instructed agencies to update their previous list of report modification  proposals, rather than analyzing their complete list of reports, as required  by GPRAMA. Although OMB staff told us the email instructions were not  a substitute for Circular A-11 guidance, agencies may have missed  opportunities to identify new proposals by following OMB’s email  instructions.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Director of OMB take the following two actions:  1.  Submit or reference agencies’ report modification proposals in the  President’s annual budget as required by GPRAMA.  2.  Ensure email instructions and other correspondence to agencies align  with GPRAMA and A-11 requirements regarding the identification and  elimination of unnecessary plans and reports. Specifically, OMB’s  email instructions to agencies should request that agencies annually  compile a list of all plans and reports they produce for Congress,  analyze the list to identify those that are outdated or duplicative,  consult and document relevant interactions with congressional  committees, and provide a total count of plans and reports and their  list of outdated and duplicative reports to OMB.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report for review and comment to OMB, the  Departments of Defense, Homeland Security, Treasury, the National  Aeronautics and Space Administration, the Consumer Product Safety  Commission, and the Federal Communications Commission.
In comments provided by email, OMB staff stated that OMB concurs with  the recommendations in this report. OMB staff also provided oral  comments in which they asked us to clarify that OMB intends to  implement the report modification process on an annual basis as  required, unless the law is changed. We revised the report accordingly to  provide this clarification.
CPSC, DHS, DOD, FCC, NASA, and Treasury informed us that they had  no comments.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the Director  of OMB and the heads of the agencies we reviewed as well as  appropriate congressional committees and other interested parties. In  addition, this report is 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) 512-6806 or mihmj@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: You asked us to review federal agencies’ compliance with GPRA  Modernization Act of 2010’s (GPRAMA) provisions to propose eliminating  or modifying unnecessary reports, and to describe the process being  used to generate report modification proposals. This report (1) reviews  the information included in agencies’ report modification proposals, and  identifies the number of proposals published by the Office of Management  and Budget (OMB), (2) assesses the extent to which OMB and agencies  are implementing GPRAMA requirements regarding the elimination or  modification of unnecessary plans and reports, and (3) describes how  selected federal agencies determined which plans and reports are  outdated or duplicative.
To review the information included in agencies’ report modification  proposals and identify the number of proposals published by OMB, we  reviewed selected agencies’ full lists of reports for Congress; all agencies’  report modification proposals (from 2012, 2014, and 2016); and OMB  guidance and instructions. We interviewed OMB staff to ensure that we  obtained the complete lists that OMB published on Performance.gov. To  assess the reliability of information contained in agencies’ published  report modification proposals, we reviewed the completeness of report  modification information provided by agencies and asked selected  agencies to describe their internal controls and related quality assurance  practices for validating information provided to OMB. We determined the  information on report modification proposals by agency was sufficiently  reliable for our purposes. To determine whether there was an association  between the number of reports the agencies produced for Congress in  2012 and the number they marked as unnecessary, we performed a  simple correlation, and found a relatively high degree of association (R =  .76 for all observations). However, we also noted that the percentage of  all reports marked as unnecessary varied considerably by agency, from 0  percent to almost 40 percent. See appendix II for the percentages by  agency. For all agencies apart from DOD, we determined the data were  sufficiently reliable for the purpose of calculating the percentage of  reports proposed for modification as a percentage of reports the agencies  identified as being for Congress. However, DOD informed us that the  number of reports in OMB’s database identified as being for Congress  was incorrect. We could not determine the source of the error because of  the amount of time that had elapsed and because of staff turnover at both  OMB and DOD. Moreover, DOD could not provide us with the correct  number due to the time that has elapsed since 2012, and instead  informed us that that they likely had produced between 600 and 800  reports for Congress at around that time. For that reason, we do not  report the percentage of DOD reports proposed for modification as a  percentage of all their reports for Congress, and do not include DOD in  the correlation between these two data elements that we report in  appendix II.  It was beyond the scope of this engagement to determine if  the agencies had consistently and completely identified all of their reports  for Congress.
We analyzed agencies’ report modification proposals to determine the  number of proposals submitted from each agency and to categorize the  recommended actions and justifications provided by agencies. To  categorize agencies’ recommended actions, we sorted agencies’  proposals based on the action they proposed to Congress. Actions  included elimination, consolidation, reduction in frequency, streamline, or  modification of report language or due date. For reports agencies  proposed to eliminate, we developed seven themes (as shown in table 3)  and categorized a random sample of 133 justifications into one or more of  those themes. To develop these themes, analysts independently  reviewed a portion of the randomly selected justifications and identified  potential themes. After developing potential themes, the analysts  reconciled their lists of draft themes and reached agreement on a final set  of themes to use for categorization. We focused on reports proposed for  elimination because they constituted 72 percent of all agencies’  proposals. The remaining 28 percent of proposals that were not included  in our sample consisted of proposals for consolidating, reducing the  frequency, or otherwise modifying a report.
In order to categorize justifications used in proposals to eliminate reports,  we selected a generalizable stratified random sample of 133 report  proposals from the population of 379 identified from OMB from 2011  through 2016. We selected the 33 proposals associated with reports that  had been eliminated through the 2014 Government Reports Elimination  Act with certainty and randomly selected 100 proposals from the  remaining 346 proposals. Two coders independently coded each of the  133 justifications and reconciled any initial differences in the coding  results to reach agreement on the categories for each justification. As  some report modification proposals contained more than one justification,  we coded each justification and our totals are based on the justifications  rather than the number of reports identified. All percentage estimates  generated for this report have a margin of error of plus or minus 8  percentage points or fewer at the 95 percent confidence level (as shown  in table 3). We did not independently assess the agencies’ justifications.  In some instances, agencies provided very short and even one word  justification; however, we were able to categorize short or one word  justifications, such as “unfunded,” because they consisted of a term or  synonym for a term from one of our justification themes.
To assess the extent to which OMB and agencies are implementing  GPRAMA requirements, we reviewed all relevant GPRAMA requirements  and relevant agency documents including OMB guidance, selected  agencies’ total lists of reports for Congress, records of congressional  consultations, all agencies’ report modification proposals, and related  legislation passed by Congress to eliminate or modify reports. We also  interviewed OMB staff to determine how they operationalized these  requirements. We evaluated whether OMB’s email guidance and related  correspondence was consistent with Circular A-11 guidance and  GPRAMA requirements. We interviewed staff from OMB and responsible  officials at selected agencies to learn about their methodology and  processes for developing proposals to eliminate or modify reporting  requirements. Generally, the officials responsible for coordinating report  modification submissions were senior staff from the agencies’ chief  operating office, budget office, general counsel, the office of legislative  affairs, or a combination of these. We also spoke with staff from the  House Committee on Oversight and Government Reform and Senate  Homeland Security and Governmental Affairs Committee to gather their  perspectives on consultations with agencies. We selected these  committees because they oversee GPRAMA implementation  government-wide.
To describe how selected federal agencies determine which reports are  outdated or duplicative, we selected a non-generalizable sample of six  agencies for review based on the number of proposals that were  submitted to Congress for elimination or modification between fiscal years  2011 and 2016. We selected the two agencies that submitted the greatest  number of proposals (Department of Defense and Department of  Homeland Security), two that published one proposal (Consumer Product  Safety Commission and the Federal Communications Commission), and  the two closest to the average (National Aeronautics and Space  Administration and the Department of the Treasury). Our findings based  on these selected agencies are not generalizable. We interviewed  officials at these agencies responsible for developing and submitting  proposals to OMB. We also reviewed relevant agency documents such as  agencies’ lists of all reports they produce for Congress, their report  modification proposals, congressional correspondence, and internal  guidance or instructions provided to the offices or components that were  involved in generating and reviewing proposals.
We conducted our work from June 2016 to July 2017 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: Percentage of Agency Reports Identified as Unnecessary in 2012
section_title: Appendix III: General Approaches to Help Ensure Congressional Consultations Are Successful
paragraphs: In 2012, we reported that consultations provide Congress with  opportunities to influence the development of executive branch  performance information, and we identified the following approaches for  helping to ensure consultations are successful:
Create shared expectations. Both committee staff and agency  officials stressed that agencies should tailor consultations and  information based on the experience and needs of those involved.  Committee staff also encouraged agencies to provide them with  relevant documents, including drafts, before the meetings. This  enables committee staff to prepare questions and suggestions in  advance.
Promote a mutual understanding of priorities. Successful  consultations should create a basic understanding of the competing  demands that confront most agencies and congressional staff, the  limited resources available to them, and how those demands and  resources require careful and continuing balancing. Required  consultations present an opportunity to develop a mutual  understanding, especially given Congress’s constitutional role in  setting national priorities and allocating the resources to achieve  them.
Engage the right people at the right time. Agencies should remain  open to an iterative process, and engage Congress at the appropriate  times. Agency officials cautioned against waiting too long to consult  with Congress to allow time for adequate deliberation and dialogue.  Congressional staff and agency officials agreed that consultations  should begin at the staff level—that is, without Members of Congress  and agency top leadership—and involve agency officials with varying  responsibilities. Both congressional committee staff and agency  officials stressed the importance of having agency officials who can  answer specific program-related questions attend, as well as those  with authority to revise the agency’s plans.
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: J. Christopher Mihm, (202) 512-6806 or mihmj@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Lisa Pearson, Assistant Director,  and Peter Beck, Analyst-in-Charge, supervised the development of this  report. Emily Hutz, Brian Wanlass, Martin DeAlteriis, and Andrew J.  Stephens made significant contributions to all aspects of this report.  Robert Robinson provided additional assistance.