Financial Management: NOAA Needs to Better Document Its Policies and Procedures for Providing Management and Administration Services
Published: 2011-01-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The National Oceanic and Atmospheric Administration (NOAA) is a bureau within the Department of Commerce (Commerce). To help achieve NOAA's program goals, it relies on management and administration (M&A) services, such as legal support and information technology. In response to the fiscal year 2010 Consolidated Appropriations Act Conference Report, GAO (1) examined how NOAA's M&A services are funded, (2) assessed the extent to which NOAA's policies and procedures for M&A services conform to applicable standards, and (3) estimated salaries and expenses for NOAA's budget for fiscal year 2009. Among other things, GAO reviewed documents on M&A services and data on M&A costs from NOAA officials for its headquarters; line offices, which are responsible for executing NOAA's programs; and a subset of financial management centers (FMC) within the line offices, which manage specific programs and projects.
section_title: What GAO Found
paragraphs: M&A services at NOAA are provided at four levels--Commerce, NOAA's headquarters, line offices, and FMCs--and each level funds its services in different ways. First, Commerce uses NOAA payments to the department's Working Capital Fund to support M&A services, such as legal services, that can be more efficiently provided centrally. It also uses payments to its Advances and Reimbursements Account for, among other things, payments to external parties for M&A services provided to the department as a whole. Commerce uses funds appropriated for departmental management to provide leadership services for the whole department, including NOAA. Second, NOAA's headquarters funds most of its M&A services using its corporate administrative services appropriation. NOAA's headquarters also uses a direct billing process to provide some unplanned services, such as issuing new identification cards, as well as pooled and additional services requested by line offices. Third, line offices fund the M&A services they provide by assessing their programs, projects, and activities in various ways. Finally, some FMCs fund M&A services through assessments of their subunits, while others do not track or separately define their M&A costs. NOAA's headquarters, line offices, and FMCs have documented some of their policies and procedures for M&A services, but they have not done so to the full extent required by applicable internal control and federal cost accounting standards. Taken together, these standards require agencies to document in a manual or handbook (1) their policies regarding the types of M&A services they provide; (2) the procedures they use each year to determine the budgets for their M&A services; (3) their policies and procedures for assigning the costs of their M&A services to specific programs, activities, or outputs that benefit from the services, and the results of that assignment; and (4) the justification for why those assignments are appropriate. NOAA's headquarters has documented some of its policies and procedures for its M&A services in written yearly operating and spending plans, but has not done so in a manual or handbook. In addition, the line offices and FMCs have no or limited documentation of their policies and procedures for the M&A services they provide. This lack of documentation limits the availability of information on M&A services for agency officials and congressional decision makers and may hamper financial management and management decision making. Estimated salaries and expenses for NOAA were about $3.8 billion for fiscal year 2009, with approximately $1.38 billion in estimated salaries and $2.46 billion in estimated expenses. NOAA does not separately report salaries and expenses for each line of its budget. Therefore, GAO estimated salaries and expenses based on budget object class data. These estimates are approximate because salaries and expenses could be higher if they were accounted for in object classes that GAO did not include in its estimates.
section_title: What GAO Recommends
paragraphs: GAO recommends that NOAA require its headquarters, line offices, and FMCs to document in a manual or handbook their policies and procedures for the M&A services they provide in line with federal cost accounting and internal control standards. NOAA reviewed a draft of this report and concurred with the recommendation.

section_title: Letter
paragraphs: Federal agencies rely on a variety of management and administration  (M&A) services, such as workforce management and information  technology, to help achieve their mission and program goals. By fully  documenting their policies and procedures related to M&A services, and  accounting for their costs, agencies can, among other things, provide  relevant and reliable information to assist congressional decision makers  in allocating federal resources and evaluating program performance.  However, concerns have been raised about the availability of such  information at the National Oceanic and Atmospheric Administration  (NOAA), a bureau within the Department of Commerce (Commerce).
NOAA has a broad mission to understand and predict changes in the  earth’s environment and conserve and manage coastal and marine  resources to meet the nation’s economic, social, and environmental needs.  To carry out this mission in fiscal year 2010, NOAA received an  appropriation of about $4.7 billion and relied primarily on five line offices  to execute its programs: the National Environmental Satellite, Data, and  Information Service (NESDIS); National Marine Fisheries Service (NMFS);  National Ocean Service (NOS); National Weather Service (NWS); and the  Office of Oceanic and Atmospheric Research (OAR). Each line office is  divided into financial management centers (FMC) to perform the mission- related work of the line office, as well as to assign and track resources.  For example, NMFS has 12 FMCs below the line office level that provide  M&A services: of these 12 FMCs, 6 are regional offices and 6 are regional  science centers.
To help achieve its mission, NOAA relies on a variety of M&A services.  Major types of M&A services include leadership services, planning and  budgeting, legal support, acquisitions and grants administration,  workforce management, information technology (IT) infrastructure and  operations, and facilities support.
The Conference Report accompanying the Consolidated Appropriations  Act for fiscal year 2010 directed GAO to report on how NOAA’s M&A  services are financed and to identify salaries and expenses within NOAA’s  budget. In this context, we (1) examined how M&A services at NOAA are  funded; (2) assessed the extent to which NOAA’s policies and procedures  for accounting for M&A services conform to applicable standards; and  (3) estimated salaries and expenses for NOAA’s budget for fiscal year  2009.
To examine how M&A services at NOAA are funded, we reviewed NOAA’s  documentation related to M&A services, including its policy and guidance  documents. We also analyzed cost data on M&A services NOAA provided.  We took steps to determine the reliability of that data, including reviewing  documentation and interviewing knowledgeable agency officials, and we  found that the data were sufficiently reliable for our purposes. To  determine the extent to which NOAA’s policies and procedures for  accounting for M&A services conform to applicable standards, we  compared NOAA’s policies and procedures with applicable federal  standards for managerial cost accounting and internal control. To address  our first two objectives, we also interviewed officials from Commerce,  NOAA’s headquarters, each line office, and a subset of officials at FMCs  within each line office. To estimate salaries and expenses for NOAA’s  budget for fiscal year 2009, we requested obligations data from NOAA’s  Budget Office, organized by federal budget object classification. We took  steps to determine the reliability of these data, including reviewing  documentation and interviewing knowledgeable agency officials, and we  found that the data in the aggregate were sufficiently reliable for our  purposes. It was beyond the scope of our engagement to determine the  reliability of the more detailed salaries and expense data presented in  appendix II, and we did not do so. See appendix I for a more detailed  description of our objectives, scope, and methodology.
We conducted this performance audit from March 2010 to January 2011 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: The sections below describe (1) NOAA’s organizational structure,   (2) applicable standards for M&A services, and (3) the federal budget  object classification system.
subsections: section_title: NOAA’s Organizational Structure
paragraphs: NOAA is one of the largest bureaus within Commerce. As mentioned  earlier, five line offices—NESDIS, NMFS, NOS, NWS, and OAR—are  primarily responsible for executing the agency’s mission. Specifically:    NESDIS provides access to global environmental data from satellites and    NMFS manages, conserves, and protects living marine resources within  the U.S. Exclusive Economic Zone;   NOS provides science-based solutions to address issues concerning    NWS provides weather, water, and climate forecasts and warnings; and    OAR works with NOAA’s other line offices to provide a variety of research  services in support of the agency’s mission.
Each line office includes a headquarters office and several FMCs below  the line office level. Line office headquarters units house NOAA’s assistant  administrators and perform a variety of policymaking, budgeting,  coordination, and oversight activities. FMCs below the line office level  manage specific programs and projects within the purview of each line  office and manage their own FMC activities. For example, 13 FMCs at OAR  provide M&A services below the line office level, including the Office of  Ocean Exploration and Research, which uses advanced undersea  technologies to research and explore the oceans.
Each of the five line offices receives funding from NOAA’s overall  appropriation in two main budget accounts: Operations, Research and  Facilities (ORF) and Procurement, Acquisition, and Construction (PAC).  According to NOAA officials, in general, the ORF account funds salaries,  benefits, utilities, and other programmatic services (such as legal services  and IT). The PAC account does not fund program services, rather it funds  capital assets and investments of $75 million or greater, such as the  purchase of a new satellite. The ORF and PAC budget accounts each fund  numerous programs, projects, or activities (PPA). For example, in fiscal  year 2010, the ORF account funded 285 PPAs. Each FMC receives funding  from one or more PPAs, and the FMC decides how it will fund its program  and M&A services. For example, in fiscal year 2010, OAR’s National Sea  Grant College Program received funding from three PPAs: (1) National Sea  Grant College Program Base, (2) Aquatic Invasive Species Program, and  (3) Marine Aquaculture Program. Figure 1 illustrates the four  organizational levels discussed in this report—Commerce, NOAA’s  headquarters, line offices, and FMCs—where M&A services are provided.
The same broad types of M&A services, such as leadership and IT, are  each provided at all four organizational levels, but the nature of these  services varies depending on the needs of that level. Table 1 provides  examples of how two types of M&A services—leadership and IT  services—are generally provided at each organizational level.
section_title: Applicable Standards for M&A Service
paragraphs: Federal cost accounting standards provide guidance to federal agencies on  assigning the costs they incur to the programs they support, the activities  within these programs, and the outputs of these activities. In practice,  “assigning costs” for M&A services means that federal financial managers  are to identify and document the costs of the M&A services that are  provided to specific programs, activities, and outputs. For example, they  should document what portion of the total costs for IT services is  attributable to specific programs, activities, and outputs that benefit from  the service. According to the standards, cost accounting helps improve  financial management and managerial decision making by providing useful  information to people inside and outside an agency on its budget and  performance.
The objectives of the federal cost accounting standards include:    providing relevant and reliable information to program managers  regarding the full costs of programs, their activities, and their outputs;    providing relevant and reliable information to assist congressional and  other decision makers in allocating federal resources, authorizing and  modifying programs, and evaluating program performance; and   ensuring consistency between costs reported in financial reports and costs  reported to program managers.
The standards do not impose a specific methodology on federal agencies  to satisfy these objectives but allow them the flexibility to design their  own cost accounting systems. However, the standards call for all cost  accounting activities, processes, and procedures to be documented by a  manual, handbook, or guidebook. The documentation should (1) outline  the specific programs, activities, and outputs for which costs will be  determined; (2) provide instructions for procedures and practices to be  followed in assigning costs, including M&A costs, to those program,  activities, and outputs; and (3) contain examples of forms and other  documents to be used.
In addition, standards for internal control in the federal government call  for federal agencies to document their policies and procedures, which help  managers exercise control over agency activities, including activities  undertaken to manage and administer programs. Policies and procedures  include the methods federal agencies use to assign their M&A costs. The  internal control standards also state that the documentation should be  complete and periodically updated to reflect any changes to the policies  and procedures.
To adhere to both internal control and federal cost accounting standards,  as they relate to M&A services, federal agencies need to document their  policies and procedures. Specifically, to meet internal control standards,  agencies need to document:  their policies regarding the types of M&A services they provide, and the procedures they use each year to determine the budget for their M&A  services.
Furthermore, to meet both internal control and federal cost accounting  standards, agencies also need to document:  the policies and procedures they use for assigning the costs of their M&A  services to specific programs, activities, or outputs that benefit from the  services and the results of the cost assignments, and the justification for why those assignments are appropriate.
section_title: The Federal Budget Object Classification System
paragraphs: The federal budget object classification (object class) system is one of  several ways to array financial data, such as salaries and expenses, in  budgetary presentations. Federal agencies are required to report object  class information in their budgets and track the goods, services, or items  agencies purchase. There are five major object classes; by number, they  are as follows: (10) personal compensation and benefits; (20) contractual  services and supplies; (30) acquisition of assets; (40) grants and fixed  charges; and (90) other. These major classes are divided into smaller  classes. For example, object classes 11, 12, and 13 all fall under major  object class 10 and include (11) personnel compensation, (12) personnel  benefits, and (13) benefits for former personnel.
section_title: M&A Services for NOAA Are Funded in a Variety of Ways
paragraphs: Commerce, NOAA’s headquarters, line offices, and FMCs use a variety of  mechanisms to fund M&A services. These mechanisms include NOAA  payments, appropriations identified for specific functions, direct billings,  assessments, and receipts from reimbursable agreements.
subsections: section_title: Commerce Charges NOAA to Support Some M&A Services and Uses Its Own Funds to Provide Other Services to NOAA
paragraphs: According to our analysis of Commerce documents and interviews with  departmental officials, Commerce charges NOAA for certain M&A services  it provides, which NOAA pays for through reimbursements to the  department’s Working Capital Fund and its Advances and  Reimbursements account. The Working Capital Fund finances services  that the Secretary of Commerce determines can be performed more  advantageously or efficiently as central services, rather than separately by  each of Commerce’s bureaus. In addition, according to Commerce  officials, Commerce uses the Advances and Reimbursements account for  two things: (1) pass-through payments to external organizations for  services provided to the department as a whole, and (2) payments for  short-term projects that benefit Commerce’s bureaus. The services funded  through both the Working Capital Fund and the Advances and  Reimbursements account include services such as mail management,  library services, and legal counsel. The services funded through the  Advances and Reimbursements account include services provided by the  National Finance Center to support processing NOAA’s payroll and  services provided by Commerce’s Office of Budget to prepare and finalize  the department’s Performance and Accountability Reports as required by  the Government Performance and Results Act. The following 12 offices  within Commerce provide M&A services through these mechanisms:  (1) Acquisition Management, (2) Administrative Services, (3) Budget,  (4) the Chief Information Officer, (5) Chief of Staff, (6) Civil Rights,  (7) Financial Management, (8) the General Counsel, (9) Human Resources  Management, (10) Management and Organization, (11) Public Affairs, and  (12) Security.
NOAA, like other bureaus in Commerce receiving services paid for  through these mechanisms, pays the Working Capital Fund and the  Advances and Reimbursements account from its own funding for services  received. Commerce’s documents show that its billings to NOAA for the  Working Capital Fund were about $34 million in fiscal year 2007, about  $34.5 million in fiscal year 2008, and about $36 million in fiscal year 2009.  Commerce’s billings to NOAA for the Advances and Reimbursements  account ranged from about $5.6 million in fiscal year 2007 to about $8.9  million in fiscal year 2009. In fiscal year 2009, according to NOAA  documents, NOAA paid for 39 projects through the Working Capital Fund,  ranging in cost from $6,800 to help pay for the upkeep of facilities shared  by several Commerce bureaus, to about $5.2 million to pay for NOAA’s  share of costs for the Commerce Business System, which is the  department’s financial management system. In that same year, Commerce  documents show, Commerce billed NOAA for 31 projects through the  Advances and Reimbursements account, ranging in cost from about $5,200  to pay for Commerce’s grant management support for funding provided  through the American Recovery and Reinvestment Act of 2009 to about  $1.8 million for rent to the U.S. General Services Administration.
In contrast, Commerce does not charge NOAA for the M&A services it  provides through the Salaries and Expenses subaccount of its  Departmental Management account, according to Commerce officials.  This account funds the activities of the Secretary of Commerce, Deputy  Secretary, and support staff. These personnel are responsible for  developing and implementing the department’s policies; coordinating  bureaus’ program activities to accomplish the department’s mission; and  developing and implementing internal policies, procedures, and  administrative guidelines. Departmental Management funds appropriated  for these services for all of Commerce were about $47 million in fiscal year  2007, about $44 million in fiscal year 2008, and about $53 million in fiscal  year 2009. Commerce officials could not identify the cost of services  provided specifically to NOAA because, according to these officials, the  department does not separately allocate the costs for the M&A services  provided by this appropriation to each bureau.
section_title: NOAA’s Headquarters Funds the M&A Services It Provides to the Agency through Funds Appropriated for M&A Services and through Direct Billings
paragraphs: According to NOAA officials, NOAA’s appropriation for corporate  administrative services funds the following four types of M&A services  that NOAA’s headquarters provides to the agency:    services provided by NOAA’s Undersecretary and related staff offices,  including executive management policy formulation and direction;   NOAA-wide corporate services and agency management, including  activities such as financial, procurement, and human resource services; information services provided by the Office of the Chief Information  Officer; and  facilities management services, such as repairs, restoration, construction,  and environmental compliance and safety for NOAA-owned buildings.
Because these services are funded through NOAA’s corporate  administrative services appropriation, they are provided at no charge to  those receiving services. According to NOAA documentation, obligations  associated with these services from fiscal years 2007 to 2009 ranged from  $164 million (fiscal year 2009) to $167.5 million (fiscal year 2007), or about  85 percent of the total cost for M&A services provided by NOAA’s  headquarters.
NOAA’s headquarters funds the remaining 15 percent of M&A services  through direct billings—that is, NOAA’s headquarters internally bills those  receiving services, who then pay for these services with their allocated  funds. NOAA officials told us that they use the direct billing process to pay  for three types of services:    Unplanned services. If there are M&A services that NOAA’s headquarters  must provide but did not anticipate during the annual budget process, it  can use the direct billing process to pay for the services. For example,  according to NOAA officials, in fiscal years 2008 and 2009 NOAA was  required to issue new identification cards to employees and contractors in  compliance with a federal security directive. NOAA had not planned for  this expense, and NOAA used the direct billing process to pay for that  service. Each office was billed for the cost of providing the cards to their  employees and contractors.
Pooled services. In some cases, NOAA officials determine that it is more  appropriate to procure M&A goods or services at NOAA’s headquarters  level. According to NOAA officials, this procurement approach is used  when it will decrease overall costs and increase efficiency. For example,  NOAA’s headquarters has used its direct billing process to procure IT   infrastructure and e-mail services for all NOAA users, rather than have  individual line offices, FMCs, or programs procure such services  individually.
Additional services requested by line offices. When line offices request  services not provided by NOAA’s corporate administrative services  appropriation, NOAA officials told us that they can request and pay for  them through the direct billing process. These services have included, for  example, additional legal services requested by NMFS to carry out its  regulatory responsibilities or additional acquisitions support requested by  NESDIS to help complete specialized satellite acquisitions.
Total direct billing charges varied across offices because NOAA bills each  office the same amount for some services but different amounts for other  services. NOAA’s headquarters bills each office the same amount to pay  for some services, such as developing NOAA’s new strategic plan and  funding the office that staffs NOAA’s Science Advisory Board. For fiscal  years 2007 through 2009, NMFS had the highest direct billing charges of all  offices. According to NMFS officials, this was in part because NMFS uses  the most legal support to carry out its regulatory responsibilities.  Conversely, OAR, with the lowest budget among line offices, had the  lowest direct billing charges.
Table 2 provides information on NOAA’s reported direct billings by office  for fiscal years 2007 through 2009.
According to NOAA documents and officials, in fiscal year 2009, the direct  billing process was used to fund 29 projects, ranging in cost from $151,700  to fund a travel management system for NOAA employees in the  Washington, D.C. and Silver Spring offices, to about $12 million for  NOAA’s Office of General Counsel to provide specified legal services to  line offices. NOAA documents indicated that total obligations for direct  bills for fiscal years 2007 through 2009 ranged from $27.2 million to $30.3  million. While some billings were added or increased in those years, others  stayed the same and still others decreased or were no longer funded in  2009. For example, according to NOAA documentation, billings to support  NOAA’s creation of its new strategic plan and to support computerized  legal research contracts did not occur in fiscal year 2007, but were added  in 2009. Furthermore, billings for Office of General Counsel support and  for NOAA’s e-mail services steadily increased from fiscal year 2007  through fiscal year 2009. For example, NOAA officials told us that billings  for the Office of General Counsel increased during those years owing to  increased regulatory responsibilities, largely due to NMFS’s additional  responsibilities related to reauthorization of the Magnuson-Stevens Act.  Other billing amounts stayed the same in those years, such as those for  NOAA’s Grants Online service or for NOAA’s Science Advisory Board.  Several billings from fiscal year 2007 were no longer funded in fiscal years  2008 and 2009, including billings for a celebration recognizing 200 years of  service by NOAA and its predecessor agencies and NOAA’s initiative on  business process reengineering.
According to officials in NOAA’s headquarters, using both the corporate  administrative services appropriation and the direct billing process to fund  M&A services provides a good blend of funding mechanisms. Specifically,  they noted that the corporate administrative services appropriation  provides for base funding that they can count on from year to year, while  direct billings provide the flexibility that allows M&A services to expand  and contract as needed from year to year.
section_title: Line Offices Fund the M&A Services They Provide to Their Programs and FMCs through Assessments
paragraphs: Line offices fund the M&A services they provide to their programs and  FMCs by assessing their PPAs. Because the line offices have limited  documentation of their assessment methods, the information on  assessments we present below is based on discussions with line office  officials. Based on these discussions, we determined that the assessment  methods each line office used in fiscal year 2009 varied.
NESDIS. According to NESDIS officials, the line office assessed each of its  PPAs a flat 13.8 percent of the PPA’s federal labor costs and a  supplemental amount. NESDIS officials told us that they used a  supplemental assessment because much of the line office’s funding is for  activities, such as purchasing satellites, where the federal labor costs are  relatively low, and NESDIS does not want to unfairly burden other more  labor-heavy PPAs. For example, NESDIS documents show that for the  Polar Convergence National Polar-orbiting Operational Environmental  Satellite System PPA, a PPA with relatively low federal labor costs,  NESDIS assessed 13.8 percent of its federal labor costs (about $1.4  million) but added a supplemental assessment of about $4.1 million. In  contrast, NESDIS assessed its Satellite Command and Control PPA, a PPA  with relatively higher federal labor costs, 13.8 percent of its federal labor  costs, for an assessment of about $2.2 million, but only added a  supplemental assessment of $50,000. Overall, in fiscal year 2009, about 49  percent of NESDIS’s total assessment came from the 13.8 percent charge,  while about 51 percent came from the supplemental assessment. NESDIS  officials reported that their line office’s M&A obligations were about $19.4  million in fiscal year 2007, about $19 million in fiscal year 2008, and about  $22 million in fiscal year 2009.
NMFS. According to NMFS officials, the line office assessed several of its  PPAs different percentages of their budgets, ranging from 0 to 10.2 percent  for fiscal year 2009. For example, NMFS assessed its Habitat  Conservation PPA a total of about $1.8 million, or about 9.8 percent of that  PPA’s reported obligations of about $18.6 million. According to NMFS  documentation, the line office’s M&A obligations were about $23 million in  fiscal year 2007, about $23 million in fiscal year 2008, and about $25.9  million in fiscal year 2009.
NOS. According to an NOS official, the line office assessed each of its  eligible PPAs a flat percentage of about 8.9 percent of their budgets for  fiscal year 2009. For example, NOS documentation indicated that the line  office assessed its Ocean Health Initiative PPA $356,843 or about 8.9  percent of that PPA’s $4 million budget. Congress placed limits on the  amount of M&A costs that certain NOS PPAs could incur in certain fiscal  years, including fiscal year 2009, and NOS officials told us they made  assessments in accordance with those limits. According to NOS  documentation, the line office’s M&A obligations ranged from about $26.7  million in fiscal year 2007 to about $28 million in fiscal year 2009.
NWS. According to an NWS official, the line office assessed selected PPAs  different percentages of their budgets, ranging from about 4.2 percent to 5  percent for fiscal year 2009. For example, according to NWS  documentation, NWS assessed the Local Warnings and Forecasts Base  PPA 4.9 percent of that PPA’s roughly $600 million budget, for a total  assessment of about $29.5 million. In addition, NWS assessed the Central  Forecast Guidance PPA about 4.2 percent of that PPA’s allocation of about  $67 million, for a total assessment of about $2.8 million. NWS officials  reported that the line office’s M&A obligations were $34 million in fiscal  year 2007, $34.6 million in fiscal year 2008, and $38.8 million in fiscal year  2009.
OAR. According to an OAR official, the line office assessed its PPAs rates  varying from about 16.5 percent to about 18.4 percent of the PPA’s federal  labor costs. For example, in fiscal year 2009 OAR assessed its National  Severe Storms Laboratory PPA varying percentages over the year  including 16.5 percent, 17.6 percent, and 18.4 percent, of the federal labor  costs of its National Severe Storms Laboratory for a total assessment of  $777,109. OAR officials reported that the line office’s M&A obligations  ranged from about $10.2 million in fiscal year 2007 to about $11 million in  fiscal year 2009.
Table 3 summarizes each line office’s M&A obligations for fiscal years  2007 through 2009, based on data provided by line office officials. As the  table shows, these obligations ranged from a low of about $10.2 million at  OAR in fiscal year 2007 to about $38.8 million at NWS in fiscal year 2009.  According to NOAA officials, line offices each define and track their M&A  services in different ways. As a result, the information in the table below is  not comparable across line offices.
section_title: Some FMCs Fund M&A Services through Assessments and Other FMCs Do Not Track or Separately Define Their M&A Costs
paragraphs: FMCs at two of NOAA’s line offices use assessments to fund the M&A  services they provide, and some or all the FMCs at the other three line  offices do not track their costs for M&A services. Specifically, according to  line office officials, FMCs below the line office level at NMFS and most  FMCs in OAR below the line office level assess subunits within their  organizations to pay for M&A services using methods that are generally  similar to the methods their line offices use. For example, OAR’s Earth  Science Research Laboratory’s Global Monitoring Division assesses each  of its PPAs on the basis of its federal labor costs, which is the same  approach the OAR line office uses. In contrast, according to officials in  three line offices—NOS, NWS, and NESDIS—funding for M&A services at  some or all of their FMCs is not defined or separately accounted for.  Because these FMCs do not separately account for their M&A services,  they could not provide us with information on their costs.
section_title: Commerce, NOAA’s Headquarters, Line Offices, and FMCs Use Funds Received through Reimbursable Agreements to Provide M&A Services to Other Agencies
paragraphs: When organizations within NOAA enter into reimbursable agreements  with other agencies to perform work for those agencies, it is NOAA’s  policy to charge the agencies for the M&A costs NOAA incurs in executing  the agreements unless the law authorizing the agreement provides  otherwise. These payments are distributed to NOAA’s headquarters, line  offices, or FMCs, depending on which entities perform work related to the  agreements. The NOAA Budget Office reported that M&A reimbursements  associated with these agreements were about $15.9 million in fiscal year  2007, about $19 million in fiscal year 2008, and about $16.7 million in fiscal  year 2009.
section_title: NOAA’s Documentation of Its Policies and Procedures for M&A Services Does Not Always Conform to Applicable Federal Standards
paragraphs: NOAA’s headquarters, line offices, and FMCs have documented some  aspects of their policies and procedures for M&A services, but not to the  full extent called for by applicable federal cost accounting and internal  control standards. For example, NOAA’s headquarters has documented  some of its policies and procedures for M&A services, but it has not done  so in a handbook or manual as called for by applicable federal standards.  In addition, the five line offices and the FMCs have no or limited  documentation of their policies and procedures for the M&A services they  provide.
subsections: section_title: NOAA’s Headquarters’ Documentation of Its Policies and Procedures for M&A Services Conforms to Some of the Applicable Federal Standards
paragraphs: NOAA’s headquarters documents some of its policies and procedures  related to the M&A services funded by its corporate administrative  services appropriation, but not in a handbook or manual as called for by  applicable federal standards. Specifically, NOAA’s headquarters  documents its policies on the types of services it plans to provide through  the appropriation as part of the President’s budget request to Congress. In  addition, it documents the procedures it uses to determine the budget for  its M&A services as part of the yearly budget formulation process.  According to NOAA officials, these steps include developing yearly written  operating and spending plans for each program funded by NOAA’s  corporate administrative services appropriation. In addition, NOAA’s  headquarters documents its procedures for assigning its M&A costs to its  mission support programs. However, this documentation has not been  compiled into a handbook or manual as called for by applicable federal  standards, which makes it more difficult for an independent third party,  such as an auditor, to readily evaluate the appropriateness of the policies  and procedures and may also hamper oversight.
In addition, for its corporate administrative services appropriation,  NOAA’s headquarters does not assign its M&A costs to the mission  programs they ultimately serve, as would be consistent with federal cost  accounting standards. Specifically, NOAA’s strategic plan has four broad  mission goals (ecosystems; climate; weather and water; and commerce  and transportation) and one mission-support goal. NOAA has numerous  programs under each goal designed to achieve that goal. Programs under  the mission-support goal provide M&A services, such as information  technology and facilities services, to support NOAA’s mission goals and  programs. While officials told us that NOAA assigns costs related to the  corporate administrative services appropriation to programs under its  mission-support goal, it does not assign these costs to NOAA’s other four  goals, which limits information on how much the work related to these  goals costs. This situation represents a change since 2004. Before 2004,  NOAA billed each of its line offices to pay for its corporate administrative  services, but the Senate Committee report accompanying NOAA’s  appropriation in fiscal year 2004 directed the agency to end this cost  assignment.
NOAA’s documentation of its policies and procedures for the direct billing  process adheres to most but not all of the applicable federal cost  accounting and internal control standards. Specifically, according to  NOAA’s headquarters officials, they do not document in a manual or  handbook their policies regarding the types of M&A services that may be  provided through the direct billing process. This lack of documentation  makes it difficult to ensure that NOAA managers and line office officials  have a clear understanding of what types of M&A services can be provided  through the direct billing process compared to the corporate services  appropriation, especially when staffing changes occur. Officials at NOAA’s  headquarters acknowledged this lack of documentation, and told us that  they plan to draft guidance on the direct billing process that will include  information on the types of M&A services they can provide.
In contrast, NOAA’s headquarters has documented the procedures it uses  each year to determine the budget for M&A services funded by this  process and its policies and procedures for assigning the costs to the  offices that will benefit from the services. This documentation has  included an annual memo to line and staff office officials outlining the  steps for the direct billing procedure for the upcoming fiscal year. The  memo has noted that line and staff offices requesting directly billed  services must submit their proposed requests to NOAA’s Budget Office  prior to a final review by the Chief Financial Officers’ Council. In addition,  the memo requires a template to be completed that includes information  on what service is being proposed and how much the service will cost. The  template also documents the assignment of the cost of M&A services to  the specific offices that will benefit from the services funded through the  direct billing process, and the justification for why those assignments are  appropriate. Specifically, NOAA’s headquarters requires that direct billing  proposals include documentation of cost assignments to the specific line  and staff offices that will benefit from the services. For example, in 2009,  NOAA’s Office of the Chief Information Officer submitted a proposal  outlining a service to integrate the agency’s e-mail software with its  Blackberry devices, to ensure that these devices could be fully used. The  proposal listed a description and expected cost of the service, and  explained how the cost for the service would be assigned to each line and  staff office. According to NOAA officials, NOAA’s Chief Financial Officers’  Council reviews these proposals and determines, based on a majority vote,  whether line offices should pay for the proposed services. However,  because each directly billed service is submitted to a vote by those who  will pay it, this transparency and the available documentation of the  process provides evidence that costs have been fairly assigned, according  to line office officials.
section_title: Line Office Documentation of Policies and Procedures for M&A Services Generally Does Not Conform to Applicable Federal Standards
paragraphs: The five line offices have no or very limited documentation of their  policies regarding the types of M&A services they provide to the FMCs,  which is not consistent with applicable federal cost accounting and  internal control standards. Specifically, NESDIS, NOS, NWS, and OAR  have not documented their policies regarding the types of the M&A  services they provide in a manual or handbook. Only one office—NMFS— has limited documentation on the types of M&A services it provides. The  documentation consists of a set of internal guidelines the line office issued  in 1999; however, the guidelines include only general information and have  not been updated. We believe the lack of documentation of the line offices’  policies regarding the types of M&A services they provide decreases FMC  officials’ understanding of what their assessments may fund. For example,  officials from the majority of OAR’s FMCs that provide M&A services told  us they do not receive information from the line office on the M&A  services the line office provides, and that they are not sure what services  they receive for the assessments they pay. In addition, an NWS FMC  official told us that the FMC had to pay $150,000 for a technology licensing  fee, which the official thought was already covered by the assessment that  the FMC paid to the line office.
The line offices also do not document the procedures they use to  determine the budget for the M&A services they provide. Nonetheless,  officials from each line office told us that they use specific procedures to  determine their budgets. Officials from NOS told us they develop their  budgets using current and projected funding needs, while NMFS officials  stated they use historical practices. In contrast, according to NESDIS and  NWS officials, they perform a yearly needs assessment to develop their  budget estimates. OAR officials told us that to determine their M&A  budget, they develop specific operating plans. In addition, according to  line office officials, OAR’s Chief Financial Officer chairs a committee that  reviews the budget. However, none of the five line offices could provide us  with documentation that clearly showed the procedures they followed to  ensure consistent implementation from year to year and continuity of the  process if staffing changes occurred.
Furthermore, the line offices have no or limited documentation of their  policies and procedures for assigning M&A costs and justifications for  those assignments. Specifically, NESDIS, NOS, NWS, or OAR do not  document the assignment of their M&A costs to the specific programs,  activities, or outputs that benefit from M&A services, and they do not  justify why the assignments are appropriate. NMFS has limited  documentation—in the form of an e-mail—that instructs FMCs to draw  their assessments from six specific PPAs. However, we believe that this  documentation is not detailed enough to provide a full understanding of  NMFS’s assessment process or its justification. The line offices’ lack of  documentation of their policies and procedures limits their ability to  explain their assignments to those paying the assessments as well as those  overseeing the process, including NOAA’s headquarters’ officials and  congressional decision makers. Furthermore, a lack of documentation  limits line office officials’ ability to demonstrate that they have chosen the  most appropriate method for assigning M&A costs. For example, NOS  assesses all of its PPAs equally to fund its Office of Special Projects.  However, according to NOS officials, program managers have expressed  concern that the activities of the Office of Special Projects do not equally  benefit all of the PPAs being assessed. NOS officials acknowledge that  there may be more equitable methods for funding some of the costs within  the Office of Special Projects to more accurately align assessments with  benefits. NOS officials told us that they are considering changes to the way  NOS funds projects in the Office of Special Projects.
Finally, none of the line offices have compiled a handbook or manual  detailing their policies and procedures for their M&A services as called for  by applicable federal standards. Without documentation in a manual or  handbook that has been reviewed and approved by NOAA’s headquarters  and line office management, it is difficult for an independent third party to  readily evaluate the major assumptions and methods used to develop  annual cost estimates for M&A services and the justifications for why  those assignments are appropriate. Officials in the NOAA Budget Office  acknowledged that line offices have no or limited documentation of their  policies and procedures for their M&A services. NOAA’s headquarters and  line office officials also told us that NOAA plans to begin working with the  line offices to develop documentation of their M&A services by spring  2011.
section_title: FMCs’ Documentation of Their Policies and Procedures for M&A Services Generally Do Not Adhere to Applicable Federal Standards
paragraphs: According to line office officials at NESDIS, NOS and NWS, FMCs within  their line offices do not document (1) their policies regarding the types of  M&A services they provide; (2) the procedures they use each year to  determine the budget for their M&A services; (3) their policies and  procedures for assigning the costs of their M&A services to specific  programs, activities, or outputs that benefit from the services and the  results of that cost assignment; and (4) the justification for why those  assignments are appropriate. According to line office officials, these FMCs  consider all costs to be program costs and therefore do not formally  identify their M&A services and costs. As a result, there is a general lack of  clarity on how FMC officials are to assign costs related to M&A services.  In addition, because these FMCs do not separately identify program and  M&A costs, decision makers have an incomplete understanding of the  FMCs’ budgets, which may limit their ability to provide oversight.
According to line office officials in NMFS and OAR, FMCs within their line  offices have M&A services and they assign costs by assessing their  subunits to pay for them. However, according to several FMC officials we  spoke to, they have limited or no documentation of their policies and  procedures in this area. Specifically:    NMFS. Line office officials told us that FMCs within NMFS use the same  documentation the line office uses to describe the types of M&A services  they provide. However, we found that this documentation does not  specifically discuss the differences between the services provided by the  line office and those provided by the FMCs. Furthermore, it does not  outline the procedures the FMCs take to determine the budgets for their  M&A services each year, and it does not include enough detail to provide a  full understanding of the FMCs’ cost assignments or the justification for  those assignments. Consequently, we believe that it may be difficult for the  FMCs to ensure that the process used to determine their budget and costs  for M&A services is applied consistently from year to year.
OAR. Most officials in the OAR FMCs that provide M&A services told us  they have M&A services, but they do not have documentation outlining  (1) their policies regarding the types of M&A services they provide; (2) the  procedures they use each year to determine the budget for their M&A  services; (3) their policies and procedures for assigning the costs of their  M&A services to specific programs, activities, or outputs that benefit from  the services, and the results of that cost assignment; and (4) the  justification for why those assignments are appropriate. Some OAR FMC  officials we spoke with acknowledged that this lack of documentation  presents challenges to managing the FMC, especially when there are  personnel changes. An official in one FMC told us he has started to  prepare documentation of his office’s processes to manage the FMC’s  budget, including procedures related to M&A services and costs.
In addition to the lack of documentation regarding their policies and  procedures for their M&A services, none of NMFS’s and OAR’s FMCs that  we spoke to has compiled a policies and procedures handbook or manual  for their M&A services as called for by applicable federal standards.  Overall, we believe that the lack of consistent documentation at NMFS’s  and OAR’s FMCs decreases transparency about the types of M&A services  they provide, how the costs of those services are determined and assigned,  and the reasonableness of those assignments. Line office officials in the  NOAA Budget Office acknowledged that FMCs lack documentation on  their policies and procedures for M&A services and said that they plan to  develop such documentation in the future.
section_title: Estimated Salaries and Expenses For NOAA Were About $3.8 Billion for Fiscal Year 2009
paragraphs: Using object class data provided by NOAA officials, we estimated that  NOAA’s salaries and expenses were about $3.8 billion for fiscal year 2009.   These estimates are approximate because salaries and expenses could be  higher if they were accounted for in object classes that we did not include  in our estimate. See appendix I for a detailed description of the  methodology we used to create our estimates of salaries and expenses and  the limitations associated with these data. The amount of obligations  related to estimated salaries and expenses varied across NOAA’s budget  activities, as shown in table 4. Because some funds were not included in  the data provided by NOAA for some budget activities, the information in  table 4 is not comparable across budget activities.
section_title: Conclusions
paragraphs: Well-defined and fully documented policies and procedures for M&A  services are critical to NOAA’s ability to exercise effective control over its  activities and fully account for its program costs. Such documentation can  also assist NOAA in providing reliable information to congressional  decision makers who oversee the agency’s activities and expenditures.  NOAA’s headquarters documents some of its policies and procedures for  the M&A services it provides. However, at the line offices and FMCs,  documentation is either very limited or absent on (1) their policies  regarding the types of M&A services they provide; (2) the procedures they  use each year to determine the costs of their M&A services; (3) their  policies and procedures for assigning the costs of their M&A services to  specific programs, activities, or outputs that benefit from the services and  the results of that cost assignment; and (4) justification for why those  assignments are appropriate. Without complete documentation of its  policies and procedures for its M&A services, compiled in a manual or  handbook, NOAA is not meeting internal control and federal cost  accounting standards. Also, it is difficult (1) for NOAA’s staff to have a  clear understanding of the agency’s policies and procedures for M&A  services, especially for new staff, (2) for agency managers to consistently  and equitably account for M&A services during each budget cycle, and  (3) for an independent third party to readily evaluate the appropriateness  of NOAA’s M&A policies and procedures.
section_title: Recommendation for Executive Action
paragraphs: To improve the management and oversight of the National Oceanic and  Atmospheric Administration’s management and administration services  and related costs, we recommend that the Secretary of Commerce direct  the Administrator of NOAA to require that NOAA’s headquarters, line  offices, and FMCs document in a manual or handbook their policies and  procedures for the M&A services they provide in line with internal control  and federal cost accounting standards. Such documentation should  include, at a minimum, (1) their policies regarding the types of M&A  services they provide; (2) the procedures they use each year to determine  the costs of their M&A services; (3) their policies and procedures for  assigning the costs of their M&A services to specific programs, activities,  or outputs that benefit from the services and the results of that cost  assignment; and (4) the justification for why those assignments are  appropriate.
section_title: Agency Comments
paragraphs: We provided a copy of our draft report to the Department of Commerce  for review and comment. The department provided us NOAA’s comments  on the draft report, in which NOAA said it generally agreed with the draft  report and concurred with our recommendation. In response to the  recommendation, NOAA said it had already convened an Administrative  Cost Working Group to identify the approach the bureau should take to  standardize and document its M&A services. In its comments, NOAA also  noted that the draft report did not explain how the ORF and PAC budget  accounts are used by NOAA to fund its M&A services. In response to this  comment, we incorporated information on these accounts into the report.  NOAA also provided technical comments that we incorporated into the  report as appropriate. NOAA’s comments are presented in appendix III.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of Commerce, and other interested parties. In  addition, the report will be available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or mittala@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. Key contributors to this report are listed in  appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report (1) examined how management and administration (M&A)  services at the Department of Commerce’s (Commerce) National Oceanic  and Atmospheric Administration (NOAA) are funded, (2) assessed the  extent to which NOAA’s policies and procedures for accounting for M&A  services conform to applicable standards, and (3) estimated salaries and  expenses for NOAA’s budget for fiscal year 2009.
To examine how M&A services at NOAA are funded, we reviewed policy  and guidance documents that explained NOAA’s mechanisms for funding  M&A services, such as excerpts from the NOAA Budget Handbook and  Commerce’s Working Capital Fund Advances & Reimbursements  Handbook. We also reviewed written documentation on, among other  things, NOAA’s funding of M&A services at the line office and FMC level;  NOAA’s budget data and management information systems; and NOAA’s  Planning, Programming, Budgeting, and Execution System. We  interviewed officials and gathered and reviewed cost data on M&A  services from NOAA at each of four levels—Commerce, NOAA’s  headquarters, line offices, and a subset of FMCs. Specifically, for services  provided by Commerce, we gathered and reviewed data on Commerce’s  billings to NOAA for its Working Capital Fund and Advances and  Reimbursements accounts for fiscal years 2007 through 2009. For services  provided by NOAA’s headquarters, we obtained data from NOAA’s Budget  Office on its (1) obligations from its appropriation for corporate  administrative services and (2) direct billings for M&A services to line and  staff offices. For services provided by line offices, we collected obligations  data from each line office. For M&A reimbursements associated with  reimbursable agreements with other agencies, we collected  reimbursement data for all NOAA organizations from the NOAA Budget  Office. To determine the reliability of all of these data, we reviewed  documentation, including yearly audit reports on Commerce’s and NOAA’s  financial statements, and reports outlining findings and corrective actions  from internal reviews of NOAA’s information technology systems. In  addition, we interviewed knowledgeable officials, including NOAA’s  Budget Director and the Director of Finance, about data quality, inputs,  and extraction. Based on our document review and information obtained  from our interviews, we determined that the data are sufficiently reliable  for the purposes of this report. We attempted to gather obligations data  from all of the FMCs within each line office on the M&A services they  provide. However, because we could not verify the reliability of the data  across all organizations at the FMC level, we did not present these data in  this report.
To assess the extent to which NOAA’s policies and procedures for  accounting for M&A services conform to applicable federal standards, we  reviewed applicable federal cost accounting and internal control  standards, including Standards for Internal Controls in the Federal  Government, and the Statement of Federal Financial Accounting  Standards No. 4. We reviewed Commerce and NOAA internal documents  related to policies and procedures on M&A services and cost assignments,  including Commerce’s Working Capital Fund Advances &  Reimbursements Handbook, NOAA’s headquarters direct billing  templates, and briefing slides and other guidance from line offices on the  types of M&A services provided and their assessment processes. We  obtained information on NOAA’s adherence to the applicable federal  standards through interviews with knowledgeable officials at Commerce,  NOAA’s headquarters, line offices, and selected FMCs. At Commerce, we  interviewed officials at the Office of Financial Management. At NOAA’s  headquarters, we spoke with officials in the Budget Office and Finance  Office. We also interviewed budget or finance officials from each of the  five line offices—National Environmental Satellite and Data Information  Service (NESDIS), National Marine Fisheries Service (NMFS), National  Ocean Service (NOS), National Weather Service (NWS), and Office of  Oceanic and Atmospheric Research (OAR). In addition, we interviewed  two or more FMCs from each line office. Specifically, we spoke with  NESDIS’s Office of Systems Development and National Climatic Data  Center; NMFS’s Northeast Fisheries Science Center and Alaska Regional  Office; NOS’s Center for Operational Oceanographic Products and  Services, Office of Coast Survey, and Office of Ocean and Coastal  Resource Management; and NWS’s Office of Hydrologic Development and  Eastern Regional Office. In addition, we spoke with officials in each of  OAR’s FMCs that provide M&A services.
To estimate salaries and expenses for NOAA’s budget for fiscal year 2009,  we requested obligations data from NOAA’s Budget Office, organized by  federal budget object classification (object class). We used object class  data to estimate NOAA’s salaries and expenses because NOAA does not  separately report salaries and expenses. However, 6 of the 11 budgets  submitted under Commerce do separately report salaries and expenses.  Using the 10 object classes common to the separately reported salaries  and expenses in these six budgets, we were able to estimate NOAA’s  spending related to salaries and expenses. The 10 object classes common  across Commerce bureaus that separately account for salaries and  expenses are object classes (11) personnel compensation; (12) personnel  benefits; (13) benefits for former personnel; (21) travel and transportation  of persons; (22) transportation of things; (23) rent, communications and  utilities; (24) printing and reproduction; (25) other contractual services;  (26) supplies and materials; and (31) equipment. We included object  classes 11, 12, and 13 in the estimation of salaries, and object classes 21,  22, 23, 24, 25, 26, and 31 in the estimation of expenses. The NOAA object  class data we used were extracted by NOAA officials from the agency’s  Management Analysis and Reporting System (MARS). At our request, the  lowest level of detail in the data provided by NOAA officials was at the  program, project, or activity level (PPA).
In the letter portion of this report, we provided information and estimates  related to NOAA’s salaries and expenses at a summary level. To do so, we  aggregated multiple object classes to estimate both salaries and expenses.  In addition, we aggregated object class spending data to make estimates  by activity, for example, the total estimated salaries and expenses for  NMFS. We determined that the object class data were sufficiently reliable  to report in the aggregate. We based this conclusion on interviews with  NOAA officials, who stated they adhere to internal controls and  consistently use the Office of Management and Budget’s object class  standards and object class definitions throughout NOAA. In addition, we  reviewed documentation including yearly audit reports on Commerce’s  and NOAA’s financial statements and reports outlining findings and  corrective actions from internal reviews of NOAA’s information  technology systems. Nonetheless, the apparent precision of object class  data can be misleading because similar types of spending can be assigned  to different object classes even though they are for the same type of  service. For example, for personal services contracts with federal  employees, basic pay and compensation above the basic pay would be  classified in object class 11, personnel compensation. On the other hand,  payments for personal services contracts for operation and maintenance  of facilities would be classified under object class 25, other contractual  services. In this example, even though both instances of spending were for  labor, they were assigned to different object classes. In addition, the data  may lack precision if NOAA did not include a salary or expense spending  amount in 1 of the 10 object classes we used to estimate salaries and  expenses. In that case, the expense would not be included in our estimate.  For example, NOAA line office officials also told us that object class 77 is  used by some line offices to record obligations that may include salaries  and expenses.
More detailed estimates of NOAA’s salaries and expenses for fiscal year  2009, on the basis of obligations data reported by NOAA for selected  object classes, are listed in appendix II. We organized the information by  NOAA’s six budget activities: NESDIS, NMFS, NOS, NWS, OAR, and  Program Support. The data are presented at the line item level of detail.  We did not determine the reliability of the data at the line item level  presented in appendix II. Specifically, we were unable to determine  whether the amounts reported for a given line item and object class were  accurate because validating these data would involve reviewing and  validating millions of transactions provided through hundreds of data  systems and would consequently involve a significant investment of time  and resources. Such work was beyond the scope of this engagement.
We conducted this performance audit from March 2010 through January  2011 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: Salaries and Expenses Data for NOAA’s Budget for Fiscal Year 2009
paragraphs: We based our estimates of salaries presented in this appendix on data for  object classes (11) personnel compensation, (12) personnel benefits, and  (13) benefits for former personnel. We based our estimates of expenses  not including contractual services on data for object classes (21) travel  and transportation of persons, (22) transportation of things, (23) rent,  communications and utilities, (24) printing and reproduction, (26) supplies  and materials, and (31) equipment. Finally, we based our estimates of  expenses for contractual services on data for object class (25) other  contractual services. The obligations data by object class used to estimate  salaries and expenses were extracted by NOAA officials from NOAA’s  MARS. Our estimates are approximate because salaries and expenses  could be higher if they were accounted for in object classes that we did  not include in our estimate. See appendix I for a more detailed description  of the methodology we used to create our estimates of salaries and  expenses and the limitations associated with these data. NOAA provided  the data we used to estimate salaries and expenses at the PPA level.  However, NOAA did not include reimbursable funds in the data provided.  Also, there may be multiple PPAs within each line item. The data  presented in this appendix have been subtotaled at the line item level. We  did not combine or delete any line items, even those with all amounts  listed as zeros. We did not determine the reliability of the data at the line  item level reported in this appendix.
section_title: Appendix III: Comments from the Department of Commerce
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Stephen D. Secrist, Assistant  Director; Mark A. Braza; Antoinette Capaccio; Candace Carpenter; Heather  Dowey; Emily Eischen; Jacqueline M. Nowicki, Christopher Ramig; Carol  Herrnstadt Shulman; Jack Warner; and Rebecca Yurman made key  contributions to this report.