Credit Programs:

Key Agencies Should Better Document Procedures for Estimating Subsidy Costs

GAO-16-269: Published: Jul 13, 2016. Publicly Released: Jul 13, 2016.

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What GAO Found

The Federal Credit Reform Act of 1990 requires agencies to estimate the cost to the government of extending or guaranteeing credit. This cost, referred to as subsidy cost, equals the net present value of estimated cash flows from the government (e.g., loan disbursements and claim payments to lenders) minus estimated cash flows to the government (e.g., loan repayments, interest payments, fees, and recoveries on defaulted loans) over the life of the loan, excluding administrative costs. Agencies use established methods and data to estimate the future costs of a program based on what is known today. Based on budgeting and accounting guidance, GAO determined that agencies' estimation processes should include various key elements to help ensure that estimates are supported, reliable, and reasonable. For example, agency management should compare estimated and actual cash flows to identify potential trends. The figure below lists the key elements GAO identified based on relevance to creating credible cost estimates.

To assess how agencies addressed these key elements in their subsidy cost estimation processes, GAO assessed (1) the Department of Agriculture's (USDA) Export Credit Guarantee (GSM-102) Program, (2) the Department of Housing and Urban Development's (HUD) Mutual Mortgage Insurance Fund, and (3) the Department of Education's (Education) William D. Ford Federal Direct Loan Program (Direct Student Loan Program). GAO found that these agencies varied in their implementation of these key elements, as shown below.

Key Elements of the Subsidy Cost Estimation Process

Key Elements of the Subsidy Cost Estimation Process

While USDA documented the key elements of the estimation process for the GSM-102 program, HUD and Education lacked policies and procedures and adequate documentation for certain other key elements. Until these key elements are fully addressed, HUD and Education have increased the risk that institutional knowledge used in the estimation process may be lost and estimates may not be supported, reliable, and reasonable.

Why GAO Did This Study

Federal direct loans and loan guarantees outstanding have doubled from $1.5 trillion as of September 30, 2008, to $3.0 trillion as of September 30, 2015, as reported in the financial reports of the U.S. government. In light of the growing portfolio of outstanding direct loans and loan guarantees, questions have been raised about how agencies estimate the subsidy cost of credit programs.

GAO was asked to review the process federal agencies use to develop subsidy cost estimates for credit programs. This report examines (1) the key elements federal agencies should consider when developing subsidy cost estimates and (2) the extent to which certain agencies addressed these key elements when estimating the subsidy costs for selected federal credit programs. GAO analyzed budgeting and accounting guidance to identify a list of key elements agencies should consider when estimating subsidy costs and assessed the subsidy cost estimation processes used for three credit programs against these key elements. The three programs were selected based on average loan amounts and/or loan volume.

What GAO Recommends

GAO recommends that HUD and Education develop and document additional procedures related to the subsidy cost estimation process. HUD and Education concurred with GAO's recommendations and described ongoing and planned actions to address them.

For more information, contact Cheryl E. Clark at (202) 512-9377 or clarkce@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: In response to our recommendation, HUD said that a new contract was issued that will address documentation of the MMI cash flow model and the subsidy cost estimation process. HUD also said that it was in the process of developing a solicitation for a contractor to perform an independent verification and validation of the MMI cash flow model. HUD stated that completing this documentation of the subsidy cost estimation process will help management oversee the program as required by internal control standards and help support its subsidy cost estimates.

    Recommendation: To help ensure that subsidy cost estimates for the Mutual Mortgage Insurance Fund are supported, reliable, and reasonable, the Secretary of Housing and Urban Development should direct the Principal Deputy Assistant Secretary for the Office of Housing to develop detailed policies and procedures over the subsidy cost estimation process that address, at a minimum, the documentation that should be prepared and maintained to support subsidy cost estimates and the process to document management review and approval of subsidy costs estimates.

    Agency Affected: Department of Housing and Urban Development

  2. Status: Open

    Comments: In response to our recommendation, the Education department said that it is committed to ensuring that its subsidy cost estimates are adequately documented and that it has begun drafting more detailed policies and procedures and hopes to complete this documentation in a matter of months.

    Recommendation: To help ensure that subsidy cost estimates for the Direct Student Loan Program are supported, reliable, and reasonable, the Secretary of Education should direct the Assistant Secretary for the Office of Planning, Evaluation and Policy Development to develop detailed policies and procedures over the subsidy cost estimation process that address, at a minimum, the documentation that should be prepared and maintained to support subsidy cost estimates and the process to document management review and approval of subsidy cost estimates.

    Agency Affected: Department of Education

  3. Status: Open

    Comments: In response to our recommendations to Education, the department said that it is committed to ensuring that its subsidy cost estimates are adequately documented. Regarding our second recommendation that Education develop detailed documentation of its cash flow model used to estimate subsidy costs, Education said that it will update its model documentation and has invested staff and resources into developing a new cash flow model to estimate subsidy costs. Education also said that detailed documentation of this new cash flow model will be prepared before the model becomes operational.

    Recommendation: To help ensure that subsidy cost estimates for the Direct Student Loan Program are supported, reliable, and reasonable, the Secretary of Education should direct the Assistant Secretary for the Office of Planning, Evaluation and Policy Development to develop detailed documentation of the cash flow model used to estimate subsidy costs, including the rationale for model calculations, all formulas and assumptions used in the model, data sources, the process to update and document changes to the model, and the process to document management review and approval of the model, which may be based on an independent verification and validation of the model to ensure that calculations are accurate and consistent with the model documentation.

    Agency Affected: Department of Education

  4. Status: Open

    Comments: In response to our recommendation, Education said that it is committed to ensuring that its subsidy cost estimates are adequately documented and said that the detailed policies and procedures developed in response to our first recommendation will address these key elements.

    Recommendation: To help ensure that subsidy cost estimates for the Direct Student Loan Program are supported, reliable, and reasonable, the Secretary of Education should direct the Assistant Secretary for the Office of Planning, Evaluation and Policy Development to document the procedures and results of such procedures used to develop or support key elements of the subsidy cost estimation process, addressing at a minimum (1) the reliability of historical data, (2) the rationale for informed opinion when applicable, (3) the methods used to calculate cash flow assumptions, (4) the process to ensure that subsidy cost estimates are consistent with the terms and conditions of the program, (5) the process to assess estimated cash flows for reasonableness, and (6) the process used to perform sensitivity analysis.

    Agency Affected: Department of Education

 

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