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Approach, but Needs to Improve Its Oversight of Project Costs' which 
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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

July 2009: 

Federal-Aid Highways: 

FHWA Has Improved Its Risk Management Approach, but Needs to Improve 
Its Oversight of Project Costs: 

GAO-09-751: 

GAO Highlights: 

Highlights of GAO-09-751, a report to congressional requesters. 

Why GAO Did This Study: 

The federal-aid highway program provides about $33 billion a year to 
states for highway projects. The federal government provides funding 
for and oversees this program, while states largely choose and manage 
the projects. As requested, GAO reviewed the Federal Highway 
Administration’s (FHWA) implementation of several requirements in the 
Safe, Accountable, Flexible, Efficient Transportation Equity Act: A 
Legacy for Users (SAFETEA-LU): (1) oversight of states using a risk 
management approach; (2) efforts to develop minimum standards for 
estimating project costs, and periodically evaluate states’ cost 
estimating practices; and (3) reviews of states’ financial management 
systems. GAO also reviewed FHWA’s policy on presenting an estimate of 
financing costs in financial plans for major projects (i.e., projects 
estimated to cost over $500 million). GAO reviewed FHWA plans, risk 
assessments, reviews, and other documents; visited five FHWA field 
offices and reviewed financial management reviews in an additional five 
field offices; and interviewed FHWA officials. 

What GAO Found: 

FHWA has improved its approach to managing risks to the federal-aid 
highway program by requiring field offices to identify risks, assess 
them on the basis of the potential impact and the likelihood they will 
occur, and develop response strategies for key risks in their planned 
oversight activities. For fiscal years 2007 through 2009, most of the 
field offices GAO visited had oversight activities to address a 
majority of the key risks. However, most of the field offices that GAO 
visited were not fully tracking risk mitigation activities, thereby 
limiting the effectiveness of FHWA’s efforts to mitigate risks to the 
federal-aid highway program. 

FHWA has made limited progress in meeting SAFETEA-LU’s requirement to 
develop minimum standards that states must follow when estimating 
project costs. GAO has reported that project cost estimates typically 
have not been reliable predictors of project costs or financing needs. 
While FHWA has efforts under way, it is unlikely to issue standards 
until 2011, at the earliest. In addition, FHWA has not established a 
process to periodically evaluate states’ cost estimating practices, and 
four of the five field offices GAO visited were doing little in this 
regard. However, for major projects, FHWA has established a process for 
evaluating the credibility of states’ cost estimates. Establishing 
standards for cost estimates and periodically evaluating states’ cost 
estimating practices could help to ensure that highway projects are 
effectively and efficiently managed. 

FHWA’s guidance and documentation for reviews of state departments of 
transportation’s financial management systems and practices generally 
meet key federal standards and principles, but they lack specific steps 
and documentation in some key areas. For example, FHWA’s guidance does 
not require reviewers to provide certain specific information on 
improper payments. In addition, while the 10 field offices that GAO 
reviewed generally covered the required areas in their financial 
management reviews in 2008, their documentation sometimes lacked 
information on the specific procedures performed or issues identified 
by reviewers. Without this information, it is difficult for FHWA to 
monitor and follow up on field offices’ and states’ progress in 
correcting deficiencies. 

FHWA does not require states’ financial plans for major projects to 
present an estimate of the projects’ financing costs. According to a 
senior FHWA official, this is partly because it is difficult to develop 
accurate estimates. While uncertainty about a major project’s financing 
cost can exist, and presenting estimates of financing costs for all 
projects could be impractical, financing costs on major projects can 
represent a significant cost to a state, and can, when combined with 
payments on the principal portion of the debt, tie up large shares of 
future federal transportation funding. Presenting an estimate of a 
project’s financing costs would help ensure that decision makers who 
approve funding for these projects have key information that is 
relevant to such decisions. 

What GAO Recommends: 

GAO is making recommendations to improve FHWA’s tracking of risks and 
its oversight of states’ estimates of project costs, financial 
management systems, and financial plans for major projects. The 
Department of Transportation stated it would consider the report's 
recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-09-751] or key 
components. For more information, contact Phillip Herr at (202) 512-
2834 or herrp@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

FHWA Has Improved Its Risk Management Approach but Is Not Fully 
Tracking Risk Mitigation Activities: 

FHWA Has Made Limited Progress in Meeting SAFETEA-LU's Requirements for 
Cost Estimating: 

FHWA's Guidance and Documentation for Reviews of State DOTs' Financial 
Management Systems and Practices Generally Meet Key Standards and 
Principles, but Lack Some Important Details: 

Financial Plans for Major Highway Projects Lack Information on 
Financing Costs: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Types of Projects Receiving FHWA Oversight Versus State 
Oversight: 

Figure: 

Figure 1: Stages of a Highway or Bridge Project and State and FHWA 
Roles and Approval Actions: 

Abbreviations: 

AASHTO: American Association of State Highway and Transportation 
Officials: 

DBE: Disadvantaged Business Enterprise: 

DOT: Department of Transportation: 

FHWA: Federal Highway Administration: 

OMB: Office of Management and Budget: 

SAFETEA-LU: The Safe, Accountable, Flexible, Efficient Transportation 
Equity Act: A Legacy for Users: 

[End of section] 

United States Government Accountability Office: Washington, DC 20548: 

July 24, 2009: 

The Honorable James L. Oberstar: 
Chairman: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

The Honorable Peter A. DeFazio: 
Chairman: 
Subcommittee on Highways and Transit: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

The federal-aid highway program provides about $33 billion a year to 
states for highway and bridge projects, often paying 80 percent of 
these projects' costs. The program is federally financed and state 
administered--that is, the federal government provides funding and 
oversees the program, while the states largely choose and manage the 
projects. These projects can take years of planning, environmental 
review, design, and construction. With highway congestion projected to 
worsen over the next 20 years and freight traffic expected to double, 
widespread consensus exists on the need to maintain and improve the 
nation's surface transportation infrastructure. At the same time, 
revenues to support the Highway Trust Fund--the major source of federal 
highway and transit funding--are eroding. Receipts for the fund are 
derived from motor fuel and truck-related taxes. These receipts are 
declining in purchasing power because the federal motor fuel tax rate-
-which has remained constant at 18.4 cents per gallon since 1993--has 
not kept pace with inflation.[Footnote 1] Furthermore, as vehicles 
become more fuel efficient and increasingly run on alternative fuels, 
fuel taxes may not be a sustainable source of transportation financing. 
As a result, we have designated funding the nation's transportation 
infrastructure as a high-risk issue.[Footnote 2] Ensuring that states 
effectively manage and control the cost and schedule performance of 
federally aided projects, and that federal funds are used efficiently 
and effectively, is critically important. 

The Federal Highway Administration (FHWA), under the Department of 
Transportation (DOT), is responsible for overseeing the federal-aid 
highway program. FHWA oversees the program through its headquarters in 
Washington, D.C., and its 52 field offices in the 50 states, the 
District of Columbia, and Puerto Rico. FHWA delegates much decision 
making and program implementation authority to these field offices. 
FHWA reviews and approves the transportation plans and environmental 
impact assessments that states periodically prepare, as well as states' 
property acquisition activities; it also enforces a variety of 
requirements, such as civil rights laws, that states accept as a 
condition of federal aid. FHWA also oversees the design and 
construction of federally aided projects, but this oversight has 
evolved over the years and currently focuses on two broad areas: (1) 
for selected projects, direct review and approval of state design 
plans, contract awards, and construction progress and (2) process 
reviews--that is, reviews of state management processes--to ensure that 
the states have adequate controls to effectively manage federally 
assisted projects. FHWA requires its field offices to use a risk 
management approach to allocate oversight resources. Risk management 
typically includes assessments to identify and prioritize risks, and is 
used in a variety of contexts, including the management of government 
programs. For the federal-aid highway program, examples of risks that 
FHWA has identified include inadequate construction practices that 
could degrade the quality of state highway projects, and the risk that 
projects delegated by states to local governments may not meet federal 
requirements and could have cost or schedule overruns. FHWA has 
additional requirements for "major projects"--that is, generally those 
projects estimated to cost over $500 million--such as reviewing and 
approving annual finance plans required by law.[Footnote 3] 

We and others have raised concerns regarding FHWA's oversight of the 
federal-aid highway program. For example, in reports that we issued 
from 1997 to 2005, we highlighted several problems, including a lack of 
useful project cost estimates, which typically had not been reliable 
predictors of the project costs or financing needs. We also found that 
the guidance that FHWA provided to states on developing cost estimates 
was voluntary and covered only major projects. In addition, we found 
that although FHWA field offices were assessing risks to the highway 
programs in their states, they were not always using their risk 
assessments to direct their process reviews. In 2005, Congress enacted 
the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A 
Legacy for Users (SAFETEA-LU), which authorized funding for the federal 
surface transportation programs from fiscal years 2005 through 2009. 
[Footnote 4] SAFETEA-LU also established the following requirements for 
FHWA's oversight of the federal-aid highway program: 

* annually review elements of each state Department of Transportation's 
(DOT) project delivery system;[Footnote 5] 

* develop minimum standards that state DOTs must follow when estimating 
project costs, and periodically evaluate state DOTs' practices for 
estimating project costs; and: 

* annually review elements of each state DOT's financial management 
system that affect projects. 

SAFETEA-LU continued an earlier requirement for sponsors of major 
projects to submit a financial plan based on detailed cost estimates to 
complete the project and on reasonable assumptions, as determined by 
FHWA. FHWA evaluates states' cost estimates for major projects to 
assess the reasonableness of their assumptions. SAFETEA-LU also lowered 
the threshold for a project to be classified as major from $1 billion 
to $500 million. 

You asked us to review FHWA's implementation of several requirements in 
SAFETEA-LU, including its (1) oversight of states' project delivery 
systems, in particular, its use of a risk management approach to 
allocate their oversight resources; (2) efforts to develop minimum 
standards for states to follow when estimating project costs, and to 
periodically evaluate states' cost estimating practices; and (3) 
efforts to review elements of states' financial management systems and 
practices that affect projects. You also asked us to review FHWA's 
policy on presenting an estimate of financing costs in financial plans 
for major projects. 

To address these objectives, we reviewed key agency and state documents 
and relevant regulations and legislation. We conducted interviews with 
FHWA and state DOT officials and representatives from the American 
Association of State Highway and Transportation Officials (AASHTO). In 
addition, we observed a risk management training class that is 
available to FHWA staff. We also visited 5 FHWA field offices that 
oversee states that receive a range of federal-aid dollars, several of 
which were overseeing a major project. Because we used a nonprobability 
sample, information obtained from the field offices that we visited 
cannot be generalized to all field offices. Also, we assessed financial 
management reviews in 5 additional randomly selected field offices, for 
a total of 10 field offices. We conducted this performance audit from 
June 2008 through July 2009 in accordance with generally accepted 
government auditing standards. Those standards require that we plan and 
perform the audit to obtain sufficient, appropriate evidence to provide 
a reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 
See appendix I for a more complete description of our scope and 
methodology. 

Background: 

Federal funding for highways is provided to the states mostly through a 
series of formula grant programs collectively known as the federal-aid 
highway program. Periodically, Congress enacts multiyear legislation 
that authorizes the nation's surface transportation programs. In 2005, 
Congress enacted SAFETEA-LU, which authorized $193.2 billion for the 
federal-aid highway program from fiscal years 2005 through 2009. 

FHWA oversees the federal-aid highway program and distributes most 
funds to the states through annual apportionments established by 
statutory formulas. Once FHWA apportions these funds, they are 
available for states to obligate for construction, reconstruction, and 
improvement of highways and bridges on eligible federal-aid highway 
routes and for other purposes. About 1 million of the nation's 4 
million miles of roads are eligible for federal aid--including the 
161,000 mile National Highway System, of which the 47,000 mile 
Interstate Highway System is a part.[Footnote 6] While FHWA oversees 
and funds the program, the responsibility for selecting specific 
highway projects generally rests with state DOTs and local planning 
organizations, which have considerable discretion in determining how to 
allocate available federal funds among various projects. The federal- 
aid highway program is generally referred to as a federally assisted, 
state-administered partnership. 

A highway or bridge construction or repair project usually has four 
stages: planning, environmental review, design and property 
acquisition, and construction. FHWA reviews and approves long-term and 
short-term state transportation plans and programs, environmental 
documents, and the acquisition of property for all highway projects. 
[Footnote 7] However, its role in overseeing the design and 
construction of projects varies. On selected projects, FHWA exercises 
what is often considered "full" oversight, meaning that FHWA (1) 
prescribes design and construction standards, (2) approves design plans 
and estimates, (3) approves the selection of the contract award, (4) 
periodically inspects the progress of construction, and (5) renders 
final acceptance on projects when they are completed. However, 
relatively few projects are subject to this full FHWA oversight. Under 
current law, FHWA exercises full oversight of certain high-cost 
interstate system projects, while states oversee design and 
construction on other federal-aid projects. Figure 1 shows the stages 
of a highway or bridge project and the corresponding state role and 
FHWA approval actions. Table 1 shows the types of projects for which 
FHWA exercises full oversight, as compared with state oversight. 

Figure 1: Stages of a Highway or Bridge Project and State and FHWA 
Roles and Approval Actions: 

[See PDF for image: illustrated table] 

Stage: Planning; 
State's role: Prepare long-range (e.g., 20 years) plans and short-range
(e.g., 4 years) transportation improvement programs; 
FHWA's role: Approve short-range transportation improvement programs. 

Stage: Environmental review; 
State's role: Prepare environmental documents identifying and assessing 
environmental alternatives when required; 
FHWA's role: Approve environmental documents. 

Stage: Design and property acquisition; 
State's role: Acquire property and prepare design plans and 
specifications according to applicable standards; 
FHWA's role, when FHWA has oversight responsibility[A]: Approve
property acquisition and approve design plans and specifications; 
FHWA's role, when state has primary oversight responsibility[A]: Approve
property acquisition, no specific role in design plans and 
specifications. 

Stage: Construction; 
State's role: Advertise bids, award contracts, and oversee 
construction; 
FHWA's role, when FHWA has oversight responsibility[A]: Approve
construction awards, inspect progress, and accept final product; 
FHWA's role, when state has primary oversight responsibility[A]: No 
specific role. 

Source: GAO. 

[A] The types of projects for which FHWA exercises full oversight, as 
compared with state oversight, are shown in table 1 of this report. 

[End of figure] 

Table 1: Types of Projects Receiving FHWA Oversight Versus State 
Oversight: 

Type of project: Interstate System; 
Miles of road: 47,000; 
Percentage of federal highway funds obligated in 2006: 8%; 
Design and construction oversight: FHWA oversight; 
Exception: Certain types of projects, or projects below a certain 
dollar threshold, in which FHWA and state determine that state 
oversight is appropriate. 

Type of project: National Highway System, non Interstate routes; 
Miles of road: 115,000; 
Percentage of federal highway funds obligated in 2006: 44; 
Design and construction oversight: FHWA and state agree on which entity 
will provide oversight; 
Exception: State or FHWA determines state oversight is not appropriate. 

Type of project: Federal-aid highways off the National Highway System; 
Miles of road: 798,000; 
Percentage of federal highway funds obligated in 2006: 48; 
Design and construction oversight: State assumes oversight; 
Exception: State determines that state oversight is not appropriate. 

Source: GAO analysis of FHWA data. 

[End of table] 

Over the past 12 years, we and others have identified problems with 
FHWA's oversight of the federal-aid highway program. For example: 

* In 1997, we reported that the overall amount of and reasons for cost 
increases on highway and bridge projects could not be determined 
because data were not readily available from FHWA or the 
states.[Footnote 8] We found on many of the projects for which we could 
obtain information that initial costs estimates--developed in 
connection with the environmental review stage of projects--had 
increased, sometimes significantly. Several factors accounted for the 
increases, including that these initial cost estimates were preliminary 
and were not designed to be reliable predictors of a project's cost. 

* In our May 2002 testimony, we reported that FHWA had begun to improve 
its oversight by implementing Congress's finance plan requirements for 
major projects but opportunities existed for improving the quality of 
cost estimating and developing reliable and accurate information on the 
extent and nature of projects' cost performance to help direct federal 
oversight efforts.[Footnote 9] 

* In 2003, the DOT Inspector General reported progress in FHWA's 
stewardship over major projects but identified improvements needed in 
eight areas, including developing more reliable cost estimates, 
managing project schedules better, and refocusing FHWA's efforts on 
project management and financial oversight.[Footnote 10] 

* We and others have raised concerns regarding FHWA's use of risk 
assessments to identify and prioritize risks to the federal-aid highway 
program. In 2004, the DOT Inspector General reported that FHWA's risk 
assessments did not provide a systematic approach for assessing program 
risks throughout the agency.[Footnote 11] As a result, risk assessment 
results were not reliable or comparable across states. The Inspector 
General recommended that FHWA issue guidance to its field offices to 
ensure that risk assessments are conducted more strategically by 
identifying major programs and program components to be evaluated, 
correlating the assessments with agency priorities, and providing field 
offices with a disciplined methodology for evaluating and classifying 
program risks. In addition, in 2005, we reported that FHWA field 
offices were not always using risk assessments to help guide their 
reviews of state management processes.[Footnote 12] 

FHWA Has Improved Its Risk Management Approach but Is Not Fully 
Tracking Risk Mitigation Activities: 

FHWA has improved its risk management approach by requiring field 
offices to identify risks to the federal-aid highway program in their 
states, assess the risks on the basis of the potential impact and the 
likelihood that they will occur, and include response strategies for 
key risks in the offices' planned oversight activities. FHWA also has 
improved its use of risk assessments to guide oversight activities. 
However, most of the field offices that we visited were not fully 
tracking risk mitigation activities, thereby limiting the effectiveness 
of FHWA's efforts to mitigate risks to the federal-aid highway program. 

FHWA Has Improved Its Risk Management Approach and Is Using Risk 
Assessments to Guide Oversight: 

FHWA has improved its risk management approach by establishing a 
process for field offices to identify, assess, and respond to risks to 
the federal-aid highway program. Following the issuance of the 2004 DOT 
Inspector General report, FHWA issued risk management guidance to field 
offices in 2006, 2007, and 2008, and the Inspector General told us that 
FHWA has implemented the recommendation. FHWA has also developed risk 
management training and offers a class through the National Highway 
Institute. According to an FHWA official, senior management from each 
field office received the training in 2007. 

FHWA's guidance requires field offices to identify risks to the federal-
aid highway program (usually on an annual basis), assess the risks on 
the basis of the potential impact and the likelihood that they will 
occur, develop response strategies for key risks (typically, the top 
10), and include these strategies in the offices' planned oversight 
activities. We assessed FHWA's risk management guidance and training 
against the best practices that we developed in the following four 
areas: strategic planning, identifying and assessing risks, 
implementing and monitoring risk mitigation plans, and evaluating and 
selecting alternatives for responding to risks.[Footnote 13] We found 
that FHWA adequately reflected these best practices in the first three 
areas, but not the fourth. For example, in the area of strategic 
planning, FHWA's guidance directs staff to develop risk planning 
strategies and identify actions that could mitigate the impact of 
negative events. In addition, in the area of assessing risks, the 
guidance and training provide detailed discussion of considering the 
likelihood and potential impact of risks to help field offices 
prioritize identified risks. However, in the area of evaluating and 
selecting alternatives for responding to risk, FHWA's guidance and 
training have limited discussion of evaluating the impact of 
alternative response strategies in terms of their potential to reduce 
risks and their associated costs, or of documenting the basis for 
choosing the selected alternative. 

Since our 2005 report, FHWA has improved its use of risk assessments to 
guide oversight activities. We found that risk assessments were a 
significant factor in determining oversight activities in the field 
offices that we visited for this work. Officials from these five field 
offices said they used risk assessments to inform their planned 
oversight activities for the year. In addition, for fiscal years 2007 
through 2009, three of the five field offices documented planned 
oversight activities to address a majority of the key risks identified 
during their annual risk assessment process. The other two field 
offices addressed one-half or more of the risks in 2 of the 3 years. 
For instance, for fiscal year 2008, one field office identified 10 
risks and documented a planned oversight activity for 9 of these risks 
in its performance plan. For example, to address risks associated with 
projects delegated by the state to local governments or agencies, over 
20 percent of the field office's construction inspections in fiscal 
year 2008 focused on local projects. It found deficiencies in some 
areas, including construction documentation and meeting disadvantaged 
business enterprise goals.[Footnote 14] In another field office we 
visited, staff identified a risk that inadequate construction practices 
could degrade the quality of state highway projects. To respond to the 
risk, the field office initiated a review of the state's practices for 
addressing discrepancies between the construction materials and methods 
used and the plans and specifications for projects. The review found 
that the state's process and guidance were adequate, but made 
recommendations to improve the efficiency and consistency of the 
process. 

The American Recovery and Reinvestment Act of 2009 (Recovery Act) 
provides an additional $26.7 billion in highway spending to the states. 
[Footnote 15] FHWA is taking steps to oversee the increased spending by 
directing its field offices to revise their existing annual plans so 
that they address risks associated with delivering these projects. 
Field offices were required to identify and prioritize their primary 
risks and submit their plans to FHWA's field office directors by late 
March 2009. On the basis of these efforts, in April 2009, FHWA issued a 
risk management framework identifying eight key risks in implementing 
the Recovery Act, including risks associated with weak internal 
controls,[Footnote 16] which may lead to the payment of ineligible 
costs, and difficulty in meeting the public's expectations for 
stimulating economic recovery and delivering transportation projects 
that yield long-term value. The framework also includes eight risk 
mitigation strategies, including reviews of previously identified risks 
in all states and providing guidance on the Recovery Act to funding 
recipients. 

FHWA Is Not Fully Tracking Risk Mitigation Activities and Associated 
Recommendations: 

FHWA's field offices are not fully tracking risk mitigation activities 
and associated recommendations. FHWA field offices often initiate 
reviews of state or local agency processes in response to identified 
risks. These reviews can result in recommendations. Standards for 
internal control state that agencies should have policies and 
procedures that help ensure that actions are taken to address risks and 
enforce recommendations.[Footnote 17] Also, monitoring of internal 
control should include policies and procedures for ensuring that the 
findings of reviews are promptly resolved. However, we found that only 
1 of the 5 field offices that we visited had information about both its 
own progress in addressing risks and its state's progress in resolving 
related review recommendations. Also, in a 2008 survey of its 52 field 
offices, FHWA found that of the 29 field offices that responded to the 
survey, 7 did not have a system for tracking review recommendations. Of 
the 22 field offices with tracking systems, FHWA found 8 different 
systems in use, which could make it difficult to aggregate review 
recommendation tracking information at the national level. 

To improve the situation, FHWA plans to develop an information system 
to track states' progress in addressing review recommendations. FHWA 
has not yet decided whether to require all field offices to use the 
system. Also, FHWA has not yet determined whether it will develop an 
information system for its field offices to track their own progress in 
addressing risks. Without complete and consistent tracking information, 
it is difficult to aggregate national-level information from the field 
offices and to ensure that risks and related review recommendations 
have been addressed. 

FHWA Has Made Limited Progress in Meeting SAFETEA-LU's Requirements for 
Cost Estimating: 

FHWA has made limited progress in meeting SAFETEA-LU's requirements to 
develop minimum standards that states must follow when estimating 
project costs, and to periodically evaluate states' practices for 
estimating project costs. Although FHWA field offices are doing little 
to periodically evaluate states' cost estimating practices overall, 
FHWA has established a process for evaluating the credibility of 
states' cost estimates for major projects. 

FHWA Has Made Limited Progress in Developing Minimum Standards for 
Estimating Project Costs: 

FHWA has made limited progress in meeting SAFETEA-LU's requirement to 
develop minimum standards that states must follow when estimating 
project costs. In 1997, we reported that project cost estimates 
typically had not been reliable predictors of project costs or 
financing needs.[Footnote 18] Although FHWA has efforts under way, it 
is unlikely to issue standards until 2011, at the earliest. To meet the 
SAFETEA-LU requirement, the agency is participating in AASHTO's effort 
to develop cost estimating guidance for states. As part of this effort, 
AASHTO sponsored the development of such guidance by the National 
Cooperative Highway Research Program, which was completed in 2007. 
[Footnote 19] AASHTO is developing additional cost estimating guidance; 
an AASHTO official who is helping to coordinate this effort told us 
that he expects the guidance to be completed in the latter half of 
2010. FHWA's Director of Program Administration told us that once the 
guidance is complete, FHWA plans to issue a regulation adopting as its 
minimum standards for cost estimating either the guidance developed by 
NCHRP, the additional guidance being developed by AASHTO, or both. This 
would take more time. For instance, the official provided us with an 
example in which it took about 18 months from the time AASHTO issued 
guidance until FHWA regulation took effect. 

FHWA Has Not Established a Process for Evaluating States' Cost 
Estimating Practices: 

FHWA has not established a process to meet SAFETEA-LU's requirement 
that it periodically evaluate states' cost estimating practices. FHWA's 
Director of Program Administration told us that the agency has not 
established such a process because it has been focused on developing 
minimum cost estimating standards. 

Four of the five FHWA field offices that we visited were doing little 
to periodically evaluate states' cost estimating practices. For 
example, one field office has not recently evaluated states' cost 
estimating practices because, officials stated, most of the state's 
cost estimates that they evaluate before contracts are awarded for 
construction are reasonably accurate, in that they are close to the 
lowest bid received from bidders. However, estimates that are close to 
the lowest bid are not always a good indicator of sound cost estimating 
practices. As we reported in 1997, most of a project's cost growth can 
occur before a project goes to construction.[Footnote 20] In addition, 
cost increases can also occur after a contract is awarded. Another 
field office is working with its state DOT to refine the state's cost 
estimating guidance, but the field office will not be formally 
evaluating the state's current practices as part of this effort. In 
2008, however, one field office evaluated its state DOT's practices for 
documenting cost estimates, and it is conducting an evaluation of the 
state DOT's cost estimating practices to determine if they produce 
accurate and reliable estimates. Periodically evaluating states' cost 
estimating practices could help to enhance the credibility of states' 
cost estimates. 

FHWA Has Established a Process for Evaluating the Credibility of 
States' Cost Estimates on Major Projects: 

Although FHWA field offices are doing little to periodically evaluate 
states' cost estimating practices overall, for major projects--those 
estimated to cost over $500 million--FHWA has established a process for 
evaluating the credibility of states' cost estimates. SAFETEA-LU 
requires sponsors of major projects to submit a financial plan that is 
based on detailed cost estimates to complete the project and on 
reasonable assumptions, as determined by FHWA. To help meet this 
requirement, FHWA evaluates states' cost estimates for major projects. 
We assessed FHWA's evaluations of cost estimates for two major 
projects--an expansion of 21 miles of a highway to a four-lane 
expressway in Wisconsin and an expansion of 11 miles of an expressway 
to a six-lane freeway in Colorado. We found that, consistent with GAO's 
best practices for estimating project costs[Footnote 21], both of the 
evaluations involved conducting and documenting an analysis of risks 
and uncertainties related to the cost estimate.[Footnote 22] These 
analyses (1) identified the effects on the estimate of changing 
assumptions about key cost drivers; (2) developed a probability 
distribution of the expected cost using a Monte Carlo simulation tool; 
[Footnote 23] and (3) identified a point estimate, along with the 
probability that the actual cost will not exceed the point 
estimate.[Footnote 24] 

FHWA's Guidance and Documentation for Reviews of State DOTs' Financial 
Management Systems and Practices Generally Meet Key Standards and 
Principles, but Lack Some Important Details: 

FHWA's guidance to its field offices on reviewing state DOTs' financial 
management systems and practices generally follows key federal 
standards and principles, but lacks specific steps and documentation in 
some key areas, such as improper payments, that could help improve 
oversight of state projects.[Footnote 25] The Office of Management and 
Budget (OMB) has established standards and principles related to 
financial management systems in circulars on internal control, improper 
payments, financial systems, and audits of state and local governments. 
[Footnote 26] To implement these circulars, FHWA has established a 
program in which its field offices conduct annual reviews of state DOTs 
designed to cover the following five areas: (1) a key financial process 
or system (e.g., reviewing states' procedures for recouping costs 
incurred on federal-aid highway projects), (2) improper payments, (3) 
unobligated balances on inactive projects, (4) findings reported 
pursuant to the Single Audit Act,[Footnote 27] and (5) findings 
reported by the DOT Inspector General and GAO. FHWA's guidance to its 
field offices on how to conduct the reviews generally follows OMB's 
standards and principles in the circulars. However, the guidance 
sometimes does not provide enough direction about the specific steps 
that reviewers are supposed to complete to help ensure that the 
reviewer provides sufficient evidence to support the work performed and 
the reviewer's conclusions as required by generally accepted government 
auditing standards.[Footnote 28] For example, in one of the five areas--
improper payments--the guidance does not require reviewers to identify 
the causes of improper payments and the actions taken to correct those 
causes, assess related information systems, and determine whether a 
plan has been developed to reduce the outstanding amount. Without 
requiring this information, FHWA is missing an opportunity to improve 
its oversight of state-managed projects. 

The 10 field offices we assessed generally documented coverage of the 
required areas in their financial management reviews in 2008, when 5 of 
the field offices documented coverage of all five areas and 4 of the 
field offices documented coverage of four areas. This represents an 
improvement over 2006, when 7 of the field offices documented coverage 
of three areas, and the other 3 the field offices documented coverage 
of two areas. However, the field offices' documentation sometimes 
lacked information on the specific procedures performed or any issues 
identified by reviewers, as required by generally accepted government 
auditing standards.[Footnote 29] A reason why the information is 
lacking is because the template that FHWA developed and that the field 
offices used to report the results of their reviews does not call for 
this information. As a result, it is more difficult for headquarters 
staff to monitor and follow up on field offices' and states' progress. 

For the five field offices that we visited, we also assessed the field 
offices' tracking of states' progress in responding to recommendations 
from the field offices' reviews of state DOTs. The five field offices 
did not use consistent approaches to track states' progress. However, 
four of the five field offices had useful approaches for tracking 
states' progress on recommendations. For example, one field office 
conducted a follow-up review in 2008, which found that the state had 
addressed most findings from a 2007 review of local projects, and the 
field office also tracked the state's progress through written 
correspondence. Three other field offices periodically updated tracking 
sheets with specific information on actions that states have taken to 
address recommendations. In contrast, another field office also used a 
tracking sheet, but for most recommendations that had not yet been 
implemented, the status field in the database said either "mostly 
complete" or "ongoing," but did not provide any information on what 
steps have been taken to address the recommendations. The agencywide 
tracking system that FHWA plans to develop is partly intended to help 
improve the tracking of these recommendations. 

Financial Plans for Major Highway Projects Lack Information on 
Financing Costs: 

FHWA does not require states' financial plans for major highway 
projects to present an estimate of the projects' financing costs. 
FHWA's guidance on financial plans for major projects states that the 
plan should reflect the project's cost estimate and revenue sources and 
amounts and provide reasonable assurance that there will be sufficient 
financial resources available to implement and complete the project as 
planned. FHWA's guidance also states that financial plans are to 
provide information on immediate and long-term financial implications 
of projects, and to provide reasonable assurance that the project's 
impact on the state's transportation capital improvement program has 
been assessed. However, FHWA's guidance does not require, and states' 
plans generally do not present, an estimate of financing costs. 

According to FHWA's Major Projects Team Leader, the agency does not 
require states to include an estimate of financing costs in the 
project's financial plan, in part because (1) financing costs are 
already reflected in statewide transportation planning documents and 
(2) accurately estimating financing costs for individual projects is 
difficult because states often fund multiple projects from a single 
bond issuance. However, while some uncertainty about a major project's 
financing cost is expected, and presenting estimates of financing costs 
for projects of all dollar amounts may be impractical, the costs of 
major projects can represent a significant cost to a state. These costs 
can, when combined with payments on the principal portion of the debt, 
consume large shares of future federal transportation funding, 
potentially impacting a state's transportation capital improvement 
program. For example, Maryland DOT officials provided us the estimated 
financing costs associated with the Intercounty Connector project, 
which are $1.4 billion, more than half as much as the $2.5 billion cost 
of designing and constructing the project. The financing costs are 
scheduled to be paid over a 34-year period, with annual payments on the 
portion of the debt repayable with future federal-aid highway funds 
scheduled to peak in 2010, requiring 14 percent of the federal-aid 
highway funds that Maryland is expected to receive that year.[Footnote 
30] While estimating a project's financing costs can be complicated due 
to market conditions and other factors that can change over time, 
without presenting an estimate of these costs, a financial plan may not 
be meeting its intended purposes of providing information on immediate 
and long-term financial implications of projects, and providing 
reasonable assurance that a project's impact on the state's 
transportation capital improvement program has been assessed. 

Conclusions: 

FHWA has strengthened its oversight of the federal-aid highway program 
by making improvements to its risk management approach, implementing a 
process to evaluate the credibility of major project cost estimates, 
and issuing financial management review guidance to its field offices 
that generally follows OMB's standards and principles. The agency is 
targeting its resources by systematically analyzing risks that could 
have a significant impact on the federal aid highway program and 
developing response strategies. FHWA's evaluations of major project 
cost estimates assess, quantify, and document how risks and 
uncertainties could affect a project's cost. Also, FHWA's guidance on 
financial management reviews could help ensure that federal funds are 
used efficiently and effectively. 

While FWHA has made substantial improvements, further progress in 
tracking risk mitigation activities, overseeing state cost estimates, 
providing guidance and documentation for financial management reviews, 
and including information in financial plans, would enhance its ability 
to ensure that states effectively manage and control the cost and 
schedule performance of federally aided projects. First, while FHWA 
plans to develop a new system for tracking states' progress in 
addressing review recommendations, it has not yet committed to 
requiring its field offices to use the planned system, nor has it 
determined whether it will develop an information system for its field 
offices to track its own progress in addressing risks. As a result, 
FHWA may not be able to fully ensure that identified risks to the 
federal-aid highway program are mitigated or detect broader trends or 
concerns across states. Second, because FHWA has made limited progress 
in meeting SAFETEA-LU's requirement to periodically review states' cost 
estimating practices, it cannot ensure that states' estimates are 
credible or that highway projects are effectively and efficiently 
managed. Third, while FHWA's guidance and documentation for reviews of 
state financial management systems and practices generally meet key 
standards and principles, requiring more information on the procedures 
reviewers should and do perform, such as identifying the causes of 
improper payments and the actions taken to correct those causes, would 
enhance the agency's ability to oversee these systems and practices. 
Finally, while financial plans for major projects are designed to 
provide reasonable assurance that sufficient financial resources will 
be available to complete a project, requiring states to present an 
estimate of the financing costs of major projects would help decision 
makers consider and make fully informed decisions about whether to 
approve the substantial investment of public funds that major projects 
require. 

Because FHWA has actions under way to meet SAFETEA-LU's requirement to 
issue minimum standards that states must follow when estimating project 
costs, we are not making any recommendations in this area. However, to 
have the greatest impact on the quality of states' cost estimates, it 
will be important for FHWA to issue the standards in a timely manner 
and to ensure that the standards are consistent with our best practices 
for cost estimating. Some best practices, such as conducting and 
documenting an analysis of risks and uncertainties related to the cost 
estimate, could be costly and would not be appropriate for smaller- 
dollar projects if the anticipated benefit of the practice is exceeded 
by its anticipated cost. 

Recommendations for Executive Action: 

To help ensure effective and efficient management and oversight of the 
federal-aid highway program, we recommend that the Secretary of 
Transportation direct the Administrator, FHWA, to take the following 
five actions: 

* Require all field offices to use the agency's planned new system for 
tracking states' progress in addressing FHWA's review recommendations. 

* Develop the capability for all field offices to uniformly track the 
status of their efforts to mitigate risks to the federal-aid highway 
program. 

* Develop and implement a process to periodically evaluate states' cost 
estimating practices. 

* Supplement FHWA's guidance for reviewing improper payments by 
including information on the specific steps reviewers are supposed to 
complete, such as identifying the causes of improper payments and 
actions taken to correct those causes. In addition, enhance FHWA's 
reporting template for its reviews of states' financial management 
systems by requiring reviewers to document the specific procedures 
performed. 

* For major projects, require states to present an estimate of 
financing costs in the project's financial plan. 

Agency Comments: 

We provided a draft of this report to DOT for its review and comment. 
The department did not offer overall comments on the draft report, but 
it provided technical comments, which we incorporated as appropriate. 
DOT also stated it would consider the report's recommendations. 

We are sending copies of this report to the appropriate congressional 
committees, the Secretary of Transportation, the Director of the Office 
of Management and Budget, and other parties. The report will also be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-2834 or herrp@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made major contributions to 
this report are listed in appendix II. 

Signed by: 

Phillip R. Herr: 
Director, Physical Infrastructure Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To assist Congress in the upcoming reauthorization of the federal-aid 
highway program, we examined the Federal Highway Administration's 
(FHWA) implementation of several requirements in the Safe, Accountable, 
Flexible, Efficient Transportation Equity Act: A Legacy for Users 
(SAFETEA-LU), specifically its (1) oversight of states' project 
delivery systems, in particular, its use of a risk management approach 
to allocate their oversight resources; (2) efforts to develop minimum 
standards for states to follow when estimating project costs, and to 
periodically evaluate states' cost estimating practices; and (3) 
efforts to review elements of states' financial management systems and 
practices that affect projects. We also examined FHWA's policy on 
presenting an estimate of financing costs in financial plans for major 
projects. To address these objectives, we reviewed key agency and state 
departments of transportation (DOT) documents and relevant regulations 
and legislation. We conducted interviews with FHWA, and state DOT 
officials and representatives from the American Association of State 
Highway and Transportation Officials (AASHTO). In addition, we observed 
a risk management training class available to FHWA staff. We also 
visited five FHWA field offices--specifically Colorado, Delaware/ 
Maryland, Pennsylvania, Washington, and Wisconsin--which were selected 
to cover a range of sizes in terms of federal-aid dollars and include 
some offices that were overseeing a major project. Because we used a 
nonprobability sample, information obtained from the field offices that 
we visited cannot be generalized to all field offices. In addition, we 
assessed financial management reviews in five randomly selected field 
offices, specifically Arizona, Arkansas, Connecticut, Idaho, and Iowa. 

To evaluate FHWA's risk-based approach to oversight, we reviewed a 
report from DOT's Inspector General (IG) on FHWA's risk management 
approach and interviewed a DOT IG official to obtain information on 
FWHA's progress in addressing the report's recommendations. We reviewed 
FHWA's risk management guidance and training materials and compared 
them with GAO's internal risk management guide for analysts.[Footnote 
31] In addition, we reviewed FHWA field office risk assessments, annual 
performance plans and other related planning documents, and field 
office documentation of risk and recommendation tracking efforts. To 
evaluate FHWA's efforts related to cost estimating, we assessed FHWA 
cost estimating guidance and its evaluations of states' cost estimates 
for two major projects against criteria in GAO's cost estimating and 
assessment guide.[Footnote 32] We also assessed draft cost estimating 
guidance being developed by AASHTO against criteria in GAO's guide. We 
also reviewed FHWA field office efforts to periodically assess states' 
cost estimating practices by conducting interviews with FHWA 
headquarters and field office staff and reviewing field office reports 
related to state DOT cost estimating practices. To assess FHWA's 
reviews of financial management systems and practices, we reviewed 
FHWA's guidance and financial management work papers from field offices 
and compared them with relevant federal standards and principles 
established by the Office of Management and Budget in circulars on 
internal control, improper payments, financial systems, and audits of 
state and local governments; and with generally accepted government 
auditing standards. We also assessed whether the field offices' 
financial management work papers covered all of the areas required by 
FHWA's guidance and reviewed field offices' efforts to track related 
recommendations. Finally, to examine FHWA's policy on presenting 
financing costs in financial plans for major projects, we reviewed 
FHWA's financial plan guidance and estimates of financing costs on a 
major project. We also interviewed a state official to obtain views on 
presenting estimates of financing costs in major projects' financial 
plans. 

We conducted this performance audit from June 2008 through July 2009 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. 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Phillip Herr, (202) 512-2834 or herrp@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Steve Cohen, Assistant 
Director; Daniel Cain; Jennifer Echard; Fred Evans; Colin Fallon; 
Kathleen Gilhooly; David Goldstein; Jason Lee; Flavio Martinez; Amanda 
Miller; Karen Richey; Amanda Seese; Laura Shumway; and Jack Warner made 
key contributions to this report. 

[End of section] 

Footnotes: 

[1] GAO, Highway Trust Fund: Improved Solvency Mechanisms and 
Communication Needed to Help Avoid Shortfalls in the Highway Account, 
[hyperlink, http://www.gao.gov/products/GAO-09-316] (Washington, D.C.: 
Feb. 6, 2009). 

[2] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January 
2009); and High-Risk Series: An Update, GAO-07-310 (Washington, D.C.: 
January 2007). 

[3] FHWA's oversight also applies to projects between $100 million and 
$500 million. FHWA reviews and approves financial plans for major 
projects. For projects between $100 million and $500 million, financial 
plans have to be prepared, but FHWA does not approve them. 

[4] Pub. L. No. 109-59 (Aug. 10, 2005). 

[5] A project delivery system is the process used to move a project 
from a concept to a constructed facility, and the system includes 
planning, environmental review, design, property acquisition, and 
construction. 

[6] The 1 million miles of roads eligible for federal aid accounted for 
about 83 percent of the vehicle miles traveled on the nation's roadways 
in 2007. The 3 million miles of roads that are generally ineligible are 
functionally classified as local roads or rural minor collectors. 

[7] Specifically, FHWA approves state short-range transportation 
improvement programs and reviews state and metropolitan planning 
processes. 

[8] GAO, Transportation Infrastructure: Managing the Costs of Large- 
Dollar Highway Projects, [hyperlink, 
http://www.gao.gov/products/GAO/RCED-97-47] (Washington, D.C.: Feb. 27, 
1997). 

[9] GAO, Transportation Infrastructure: Cost and Oversight Issues on 
Major Highway and Bridge Projects, [hyperlink, 
http://www.gao.gov/products/GAO-02-702T] (Washington, D.C.: May 1, 
2002). 

[10] Statement of the Honorable Kenneth H. Mead, Inspector General, 
Department of Transportation, Management of Cost Drivers on Federal-Aid 
Highway Projects, (May 8, 2003). 

[11] U.S. Department of Transportation, Office of Inspector General, 
Managing Risk in the Federal-Aid Highway Program, MH-2005-012 
(Washington, D.C.: Nov. 19, 2004). 

[12] GAO, Federal-Aid Highways: FHWA Needs a Comprehensive Approach to 
Improving Project Oversight, [hyperlink, 
http://www.gao.gov/products/GAO-05-173] (Washington, D.C.: Jan. 31, 
2005). 

[13] GAO, Risk Management: A GAO Analysts' Guide. 

[14] DOT's Disadvantaged Business Enterprise (DBE) program is designed 
to remedy the effects of current and past discrimination against small 
businesses owned and controlled by socially and economically 
disadvantaged individuals and to foster equal opportunity in 
transportation contracting. Federal law generally requires DOT to 
ensure that at least 10 percent of the funds authorized for the highway 
and transit financial assistance programs be expended with DBEs. 

[15] The Recovery Act directs GAO to conduct bimonthly reviews on the 
use of funds by selected states and localities, among other things. We 
have recently completed the first review, which examined a core group 
of 16 states, the District of Columbia, and selected localities. See 
GAO, Recovery Act: As Initial Implementation Unfolds in States and 
Localities, Continued Attention to Accountability Issues Is Essential, 
[hyperlink, http://www.gao.gov/products/GAO-09-580] (Washington, D.C.: 
Apr. 23, 2009) and Recovery Act: States' and Localities' Current and 
Planned Uses of Funds While Facing Fiscal Stresses, [hyperlink, 
http://www.gao.gov/products/GAO-09-829] (Washington, D.C.: July 8, 
2009). We expect to track the activities of these 16 states and the 
District of Columbia over the next few years to provide an ongoing 
longitudinal analysis of the use of Recovery Act funds. 

[16] Internal control is an integral component of an organization's 
management that provides reasonable assurance that the following 
objectives are being achieved: effectiveness and efficiency of 
operations, reliability of financial reporting, and compliance with 
applicable laws and regulations. Internal control also serves as the 
first line of defense in safeguarding assets and preventing and 
detecting errors and fraud. 

[17] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[18] [hyperlink, http://www.gao.gov/products/GAO/RCED-97-47]. 

[19] Stuart Anderson, Keith Molenaar, and Cliff Schexnayder, Guidance 
for Cost Estimation and Management for Highway Projects During 
Planning, Programming, and Preconstruction (Washington, D.C.: National 
Cooperative Highway Research Program, 2007), prepared for the 
Transportation Research Board of the National Academies. 

[20] [hyperlink, http://www.gao.gov/products/GAO/RCED-97-47]. 

[21] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009). 

[22] The term risk and uncertainty refers to the fact that because a 
cost estimate is a forecast, there is always a chance that the actual 
cost will differ from the estimate. Recognizing the potential for error 
and deciding how best to quantify it is the purpose of a risk and 
uncertainty analysis. 

[23] The term Monte Carlo simulation refers to a computer-based 
analysis that uses probability distributions for key variables, selects 
random values from each of the distributions simultaneously, and 
repeats the random selection over and over. Rather than presenting a 
single outcome--such as the mostly likely or average scenario--Monte 
Carlo simulations produce a distribution of outcomes that reflect the 
probability distributions of modeled uncertain variables. 

[24] A point estimate is usually the most likely value for the cost 
estimate, given the underlying data. 

[25] The Improper Payments Information Act of 2002 defines improper 
payments as any payment that should not have been made or that was made 
in an incorrect amount (including overpayments and underpayments) under 
statutory, contractual, administrative, or other legally applicable 
requirements. The act includes any payment to an ineligible recipient, 
any payment for an ineligible service, any duplicate payment, payments 
for services not received, and any payment that does not account for 
credit for applicable discounts. 

[26] OMB, Circular No. A-123 (revised), Management's Responsibility for 
Internal Control (Washington, D.C.: 2004); Circular No. A-123, Appendix 
C, Requirements for Effective Measurement and Remediation of Improper 
Payments (Washington, D.C.: Aug. 10, 2006); Circular No. A-127 
(revised), Financial Management Systems (Washington, D.C.: Jan. 9, 
2009); and Circular No. A-133 (revised), Audits of States, Local 
Governments, and Non-Profit Organizations (Washington, D.C.: June 27, 
2003). 

[27] See 31 U.S.C. §§ 7501-7507. Nonfederal entities that expend 
$500,000 or more a year in federal awards under more than one federal 
program are required by the Single Audit Act to undergo a single audit. 
The single audit replaces multiple grant audits with one audit of an 
entity as a whole. Single audits focus on the recipient's internal 
controls and its compliance with laws and regulations governing federal 
awards. 

[28] GAO, Government Auditing Standards, July 2007 Revision, 
[hyperlink, http://www.gao.gov/products/GAO-07-731G] (Washington, D.C.: 
July 2007). 

[29] [hyperlink, http://www.gao.gov/products/GAO-07-731G]. 

[30] The project is funded by a combination of grant anticipation 
revenue vehicles (state issued bonds or notes repayable with future 
federal-aid), toll-backed bonds, state funds, and federal funds. 

[31] GAO, Risk Management: A GAO Analysts' Guide. 

[32] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009). 

[End of section] 

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