[Question Concerning Printing and Distribution Requirements]

The Pension Benefit Guaranty Corporation (PBGC) requested an opinion on whether it was exempt from the legislative provisions which require federal agencies to have their printing and distribution needs handled by the Government Printing Office (GPO). GAO noted that: (1) legislative history clearly shows that Congress meant PBGC to be subject to the GPO printing requirements after an initial start-up period of 270 days; (2) the authority granted to PBGC was not as broad as the authority granted to other agencies exempted from the GPO requirements; and (3) those agencies which were previously found exempt from the requirements were given the authority to determine the propriety of their expenditures, notwithstanding the provisions of any other laws governing the expenditure of public funds. GAO found that: (1) legislative provisions enumerate a number of exceptions which do not include a general exemption for PBGC; (2) where Congress expressly enumerates certain exceptions to a general requirement, additional exceptions may not be implied; (3) the statutes creating PBGC did not provide sufficient authority to constitute an exemption from the requirements; and (4) Congress exempted PBGC from the requirements only for the first 270 days of the corporation's existence. Accordingly, PBGC is not exempt from the statutory requirements.