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United States General Accounting Office: 
GAO: 

Report to the Chairman, Subcommittee on the District of Columbia, 
Committee on Appropriations, House of Representatives: 

September 2002: 

District Of Columbia: 
Fiscal Structural Balance Issues: 

GAO-02-1001: 

Contents: 

Letter: 

Results in Brief: 

Background: 

The District’s Definition of Fiscal Structural Imbalance and Its
Contributing Factors: 

Constraints on the District’s Revenue Include Tax-Exempt Property and 
Federal Law Prohibiting a District Tax on the Income of Nonresidents: 

The District’s Estimates of Spending Requirements: 

Impact of the Revitalization Act on the District: 

Fiscal Structural Imbalance: More Comprehensive Approaches Should be 
Explored: 

Conclusions: 

Comments from the District of Columbia And Our Response: 

Appendixes: 

Appendix I: Scope and Methodology: 

Appendix II: The District’s Estimated Financial Net Benefits from the
Revitalization Act: 

Appendix III: Comments from the Mayor of the District of Columbia: 

Appendix IV: Comments from the District of Columbia Chief Financial
Officer: 

Tables: 

Table 1: Projected Net Benefit of the Revitalization Act on the 
District’s Budget (in millions of dollars): 

Table 2: Estimated Reductions in Revenue as a Result of the National 
Capital Revitalization Act (in millions of dollars): 

Table 3: Estimated Reductions in Expenditure as a Result of the 
National Capital Revitalization Act (in millions of dollars): 

Figure: 

Figure 1: The District’s Projected Operating Budget Without Corrective 
Actions: 

[End of section] 

United States General Accounting Office: 
Washington, D.C. 20548: 

September 4, 2002: 

The Honorable Joe Knollenberg: 
Chairman: 
Subcommittee on the District of Columbia: 
House Committee on Appropriations: 

Dear Mr. Chairman: 

The District of Columbia has historically faced many challenges due to 
its unique circumstances and role as the nation’s capital. After 
several years of struggling with financial crises and insolvency in the 
early 1990s, the District has significantly improved its financial 
condition by achieving five consecutive balanced budgets, an upgraded 
bond rating, and unqualified,[Footnote 1] or “clean,” opinions on its 
financial statements. 

More recently, however, District officials have sounded the alarm that 
the District faces an imbalance between its long-term expenditure needs 
for program services and capital investment, and its capacity to 
generate revenues over the long run. These officials assert that the 
District faces a fiscal structural imbalance as a result of several 
factors, many stemming from the federal government’s presence in the 
city, the absence of a state to provide funding for the state-like 
services provided by the District, and restrictions on the District’s 
tax base. 

In response to your June 26, 2002, letter, this report provides our
preliminary assessment of several elements of the District’s reported 
fiscal structural imbalance. However, we have not yet completed the work
necessary to conclude whether, or to what extent, a fiscal structural
imbalance may exist in the District. Specifically, you asked us to 
provide information on the following: 

* the District’s definition of fiscal structural imbalance and its
contributing factors; 

* the constraints on the District’s revenue, including the prohibition 
of an income tax on nonresidents; 

* the District’s estimates of its spending requirements, including its 
cost estimates for providing services to the federal government and its
spending for state-like functions; 

* changes in the District’s financial relationship with the federal 
government resulting from the National Capital and Self-Government 
Improvement Revitalization Act of 1997 (Revitalization Act);[Footnote 
2] and; 

* alternative approaches to measuring structural imbalance in the
District. 

The information being presented in this report is based on our work
performed to date on this issue. We currently have ongoing work in this
area and plan to issue a future report which will provide a more
comprehensive analysis of the District’s reported fiscal structural
imbalance. 

Results in Brief: 

Like many cities, the District faces a series of substantial, long-term
challenges to its financial position. The key question is whether city
officials can provide an acceptable level of services to address the 
District’s needs with their current tax base. The District argues that 
it faces a fiscal structural imbalance between revenues and its 
expenditures that undermines its capacity to meet its current 
responsibilities. In contrast with a cyclical fiscal imbalance caused 
by temporary economic downturns, the District suggests that its 
imbalance is longer term and more fundamental—and therefore, structural 
in nature. The District’s estimated measures of fiscal structural 
imbalance are premised on the continuation of current budget policy 
over a longer term period spanning economic cycles, but do not consider 
the results of policy alternatives. 

District officials have cited constraints they face in raising revenues 
as well as what they assert are unique expenditure responsibilities 
stemming from the District’s position as a federal city that must also 
provide state-like functions. On the revenue side, unlike state 
governments, the District is prohibited by federal law from taxing the 
incomes of nonresidents working in the District. District officials 
also point to the fact that the District is unable to tax a significant 
portion of property due to the federal presence. 

While federal tax exempt property does constitute a substantial amount 
of property in the District, the federal presence also draws substantial
economic activity which provides the District with additional revenues
from sales and income taxes generally not available to other cities of 
its size. 

On the spending side, the District officials state that they are 
uniquely burdened by the responsibilities of a state and by 
requirements to provide services to the federal establishment. However, 
the District’s estimated costs associated with providing state-like 
services are not supported by detailed analysis and data, and are 
derived from cost allocation formulas largely based on the judgment of 
District officials. Moreover, while the District does have 
responsibilities similar to those of many states, it also has state-
like types of revenues. Similarly, the District’s estimates of its 
costs for providing services to the federal government lack detailed
support, and do not consider the services provided by the federal
government for its own property in the District. 

Perhaps most importantly, the District’s estimates of its fiscal 
structural imbalance are premised on the maintenance of the existing 
level and costs of services now provided into the future. As a result, 
the estimates do not consider the potential for mitigating an imbalance 
with cost savings through management efficiencies, reassessing current 
policies, and restructuring of key programs. For instance, a 2002 
McKinsey & Company, Inc. study concluded that about $110 million to 
$160 million of cost savings could be achieved annually in such areas 
as health, human services, education, and transportation if the 
District’s costs were brought into line with those of comparable 
cities. 

The District received some federal relief through the 1997 
Revitalization Act, which required the federal government to take over 
certain services in such areas as criminal justice, transferring their 
financing from DC taxpayers to the nation’s taxpayers as a whole. In 
addition, the federal government assumed financial and administrative 
responsibilities for one of the District’s largest fiscal burdens, 
which it inherited from the federal government as part of the 
transition to Home Rule in 1973—its unfunded pension liability for 
vested teachers, police, firefighters, and judges. Also, the federal 
government’s share of the District’s Medicaid payments was increased 
from 50 to 70 percent. At the same time, the Revitalization Act 
eliminated the federal government’s annual payment to the District, 
which had reached $660 million per year. As a result of the above 
changes, the District estimates net financial benefits ranging from a 
low of $79.1 million to a high of $203 million per year during the 
period from 1998 through 2002. Although District officials state that 
the Revitalization Act did not fully address their challenges, they 
indicate it was an excellent first step in helping the city move toward 
longer term financial stability. 

While the District’s estimates point to many specific factors they do 
not constitute a comprehensive assessment of imbalances between
expenditures and revenue capacity. The District has not performed the
analysis to determine whether it has the capacity to provide a level of
services comparable to those provided by other cities with similar needs
and costs. As a practical matter, such an analysis is key to 
determining the presence of an underlying structural imbalance in the 
District’s finances. Compared to the District’s estimates, this 
approach has the advantage of not being tied to current service levels, 
costs, management approaches, or tax policies. From the perspective of 
this more comprehensive, comparative approach, a jurisdiction could 
suffer from a fiscal structural imbalance even if its current budget 
were balanced—for example, the imbalance would be reflected in lower 
services, higher taxes, or deterioration of infrastructure when 
compared to averages in other communities. On the other hand, a 
jurisdiction with chronic current deficits may not have a structural 
imbalance if its deficits were prompted by spending levels or tax rates 
out of line with comparable jurisdictions with similar needs. 

At the present time, however, comprehensive data and analysis are not
readily available to say with confidence how the District’s financial
situation compares to that of other jurisdictions. Preliminary 
indications suggest that the District would have to sustain a high 
level of expenditures compared to other state and local areas to 
provide at least an average level of services after adjusting for its 
unique demographic profile and costs. However, when compared to other 
entities, previous studies suggest that the city also has among the 
highest revenue capacity, or the ability to raise revenues from its own 
sources, even accounting for the federally imposed constraints on the 
city’s revenue-raising authority. Importantly, the two sides of the 
equation need to be put together to address whether the District has 
the revenue capacity to provide for its unique workload and costs with 
an average tax burden. Such a comparative analysis would need to adjust 
for the fact that the District is not strictly comparable to any 
current jurisdiction in the nation, due to its unique combination of 
state and city functions and revenues and its role as the nation’s 
capital. We are currently undertaking such an assessment and plan to 
report the results of our study in the future. 

We have been conducting our work on this issue since February 2002 in
accordance with generally accepted government auditing standards, and
our work is ongoing.[Footnote 3] The information presented in this 
report provides our preliminary assessment of several elements of the 
District’s estimates of its reported structural imbalance. However, we 
have not completed the work necessary to conclude whether or to what 
extent a structural imbalance may exist in the District. 

In responding to a draft of this report, both the Mayor and the Chief
Financial Officer (CFO) of the District stated their belief that the 
District faces a fiscal structural imbalance. However, they endorsed 
our conclusion to analyze this issue further, in greater detail, and 
with additional sophistication to discern the degree to which the 
District might face a structural imbalance. We continue to conclude 
that there is insufficient information to determine whether and to what 
degree the District faces a fiscal structural imbalance. Our ongoing 
work will provide more comprehensive information and clarify the 
appropriateness of additional information and estimates provided by the 
District’s CFO. The comments we received from the District’s Mayor and 
CFO are reprinted in appendixes III and IV, respectively, and have been 
addressed in the report as appropriate. 

Background: 

One of the most significant challenges facing the District is to 
maintain the financial viability of the city. Earlier this year, 
District officials sounded the alarm that the District faces an 
imbalance between its long-term expenditure needs for program services 
and capital investment, and its capacity to generate revenues over the 
long run. In contrast with a cyclical imbalance caused by temporary 
economic downturns, the District suggests its imbalance is more 
fundamental in nature. These officials assert that the District faces a 
fiscal structural imbalance as the result of several factors, many 
stemming from the federal government’s presence in the city, the
absence of a state to provide funding for the state-like services 
provided by the District, and restrictions on the District’s tax base. 
District officials have stated that the factors contributing to a 
fiscal structural imbalance have existed for years but that their 
effects had been masked during recent years of national and regional 
economic growth and increased tax revenues. 

As shown in figure 1, the District has projected operating budget 
shortfalls ranging from $67 million to $139 million between anticipated 
revenues and estimated baseline expenditures for each year during 
fiscal years 2002 through 2006 if corrections are not made. These 
projections assume a continuation of current tax policies and service 
levels into the future, without implementing changes to address the 
projected fiscal shortfalls. 

Figure 1: The District’s Projected Operating Budget Without Corrective 
Actions: 

[See PDF for image] 

This figure is a multiple line graph depicting the following data: 

Fiscal year: 2002; 
Projected expenditures (GAAP adjusted): approximately $5.36 billion; 
Projected revenues: approximately $5.25 billion; 
Shortfall: $110 million. 

Fiscal year: 2003; 
Projected expenditures (GAAP adjusted): approximately $5.5 billion; 
Projected revenues: approximately $5.38 billion; 
Shortfall: $119 million. 

Fiscal year: 2004; 
Projected expenditures (GAAP adjusted): approximately $5.75 billion; 
Projected revenues: approximately %5.68 billion; 
Shortfall: $67 million. 

Fiscal year: 2005; 
Projected expenditures (GAAP adjusted): approximately $5.9 billion; 
Projected revenues: approximately $5.83 billion; 
Shortfall: $75 million. 

Fiscal year: 2006; 
Projected expenditures (GAAP adjusted): approximately $6.25 billion; 
Projected revenues: approximately $6.11 billion. 
Shortfall: $139 million. 

GAAP – Generally accepted accounting principles. 

Source: District of Columbia Chief Financial Officer, January 2002 
(unaudited). 

[End of table] 

The operating deficit projections in figure 1 include the operating 
budget only and exclude the capital expenditure budget. Therefore, 
certain probable expenditures are not included in the above budget 
estimates, such as public schools’ infrastructure needs, needed repair 
of public roads, and Washington Metropolitan Area Transit Authority 
(WMATA) capital needs. District officials have expressed concern that 
if the fiscal structural imbalance issue is not addressed, it will 
cripple the city’s efforts to maintain financial viability and require 
the city to make drastic cuts in its budgets and related services to 
avoid future deficits. 

In addition, a March 14, 2002, study[Footnote 4] commissioned by the 
Federal City Council (FCC)[Footnote 5] concluded that the District is 
on a path leading to budget deficits. The study estimated that without 
corrective action, the District could face budget deficits of at least 
$500 million by fiscal year 2005 due to a substantial decrease in 
revenue growth and unbudgeted spending increases in several key areas. 
[Footnote 6] The study cited spending for public schools (including 
spending for special education), Medicaid, and WMATA as the most 
significant drivers of the growth in projected expenditure levels. 

The District’s Definition of Fiscal Structural Imbalance and Its 
Contributing Factors: 

The District’s definition of fiscal structural imbalance is premised on 
an imbalance between projected expenditures necessary to maintain the
current level of services and revenues that will be raised under 
current tax and other revenue policies. Under the District’s 
definition, a current services analysis assumes the current level of 
services and revenue structure as the baseline for concluding whether a 
fiscal structural imbalance exists. A current services imbalance can 
develop for a variety of reasons, including expenditures growing more 
rapidly than expected revenues due to increasing workloads such as 
number of program recipients, a rapid growth rate in health care costs, 
or a decline in tax revenues. The District also points to its 
uniqueness and the fiscal issues stemming from its being the nation’s 
capital and having the federal presence, as well as its responsibility 
for services ordinarily provided by state government. 

Some current services imbalances are cyclical, rather than structural, 
in that revenues become insufficient to support existing levels of 
services during periods of economic decline but then return to 
sufficiency when the economy rebounds. In its August 2001 
study,[Footnote 7] the Center on Budget and Policy Priorities (CBPP) 
notes that it is extremely difficult to determine the degree to which a 
fiscal imbalance in any state is structural, rather than cyclical. The 
CBPP reported that states are currently facing their worst financial 
crisis in 20 years, and they are responding to their budget shortfalls 
in a variety of ways. Some are using short-term fixes, such as tapping 
into rainy day funds or imposing temporary tax increases or spending 
cuts; others are using long-term fixes, such as imposing permanent tax 
increases or spending cuts. 

The revenue shortfalls projected by District officials for fiscal years 
2002 through 2006, if accurate, would represent recurring deficits in 
the District’s current services budget position if corrective action is 
not taken. These projected shortfalls are premised on the continuation 
of current budget policy over a long-term period spanning economic 
cycles. They do not contemplate changes in budget policy, nor do they 
compare the District’s current budget policy with other jurisdictions. 
However, District officials also suggest that their current environment 
constrains their ability to respond to the projected imbalance through 
spending cuts, tax increases, or borrowing. For example, District 
officials point to deferred infrastructure improvements in public 
schools, roads, and utilities as the legacy of the long-term presence 
of a structural imbalance, low levels of service delivery in some 
programs, such as public education, and high tax rates in comparison to 
other states and local jurisdictions. 

Although District officials have not formally estimated the size of 
their reported fiscal imbalance, they have cited the following 
expenditure responsibilities as the primary factors contributing to 
such an imbalance: 

* the District is not directly compensated for services provided to the
federal government such as public works and public safety, which the
District values at $240 million annually; 

* the District is responsible for state-like services such as human 
services, mental health services, Medicaid, and the University of the 
District of Columbia, which the District values at $487 million 
annually; and; 

* the District estimates that approximately 400,000 out-of-state 
vehicles travel on city roads per day and do not pay for road repair 
the District values at $150 million per year.[Footnote 8] 

District officials also cite the following factors as contributing to 
limited revenue-raising capacity:[Footnote 9] 

* 66 percent of the income earned by employees working in the District
cannot be taxed by the District because the employees are nonresidents; 

* 42 percent of the real property (or 27 percent of assessed property
value) in the District is owned by the federal government and is thus
exempt from taxation;[Footnote 10] 

* an additional 11 percent of real property (excludes District-owned
property, but includes nonprofit organizations and embassies) also is
tax exempt; 

* District buildings have congressionally imposed height restrictions 
[Footnote 11] that have reduced the population and the economic 
density; and; 

* District tax rates and burdens on households and businesses are high 
in comparison to Virginia and Maryland and its tax base is limited, thus
making it difficult to expand the tax base. 

Constraints on the District’s Revenue Include Tax-Exempt Property and 
Federal Law Prohibiting a District Tax on the Income of Nonresidents: 

The District faces some real constraints on revenue. The District, like 
all state and local governments, is unable to tax property owned by the 
federal government. District officials say they face a particular 
hardship because a larger proportion of their property is owned or 
specifically exempted by the federal government than is the case with 
most jurisdictions. The District has stated that, according to its real 
property tax records, 42 percent of its property is federal property. 
It is difficult to estimate the net fiscal impact of the presence of 
the federal government or other tax-exempt entities because of the wide 
variety of indirect contributions that these entities have on District 
revenues and the lack of information on the services they use. The 
presence of tax-exempt entities generates revenues for the District, 
even though they do not pay income or property taxes directly. For 
example, these tax-exempt entities attract residents, tourists, and 
businesses to the District. In addition, employees of the tax-exempt
entities and employees of businesses that provide services to these 
entities pay sales taxes to the District. We have found no 
comprehensive estimates of these revenue contributions; however, 
studies of individual tax-exempt entities suggest that the amounts 
could be significant.[Footnote 12] Further, given the large portion of 
the private sector activity in the District that is linked to the 
presence of the federal government and other tax-exempt entities, it is 
unclear whether commercial property would fill the void if federally 
owned property were reduced to the average seen in other cities. 

In addition to the amount of nontaxable property in the District, the
District government, unlike state governments, is prohibited by federal 
law from taxing the income earned in the District by nonresident 
individuals.[Footnote 13] States that have income taxes typically tax 
the income of nonresidents, although some states have voluntarily 
entered into reciprocity agreements with neighbor states in which they 
agree not to tax the incomes of each other’s residents. States that 
impose income taxes also typically provide tax credits to their 
residents for income taxes paid to other states. In addition, some 
cities that have income taxes tax the incomes of commuters who work 
within their boundaries. These taxes are typically levied at a low flat 
rate (most of the ones we identified were between 1 and 2 percent) on
city-source earnings. Other cities are not authorized to levy commuter
taxes by their state governments.[Footnote 14] However, in cases where 
cities are not authorized to levy commuter taxes, the state governments 
are able to compensate, if they so choose, by redistributing some of 
the state tax revenues collected from residents of suburbs to central 
cities in the form of grants to the city governments, or in the form of 
direct state spending within the cities.[Footnote 15] 

District officials believe that it is unfair for the federal government 
to apply a restriction on their income tax base that does not also 
apply to the 50 states. Another argument that is commonly made in favor 
of removing this particular restriction on the District’s taxing 
authority is that it would enable the District government to defray the 
costs of providing public services, such as road maintenance and fire 
and police protection, that benefit commuters. A recent study estimated 
that the average commuter increased total District expenditures by 
$3,016 per year, of which about $90 was for police and fire protection. 
[Footnote 16] Some local economists that we interviewed noted that 
commuters already contribute to the financing of a portion of these 
services, even without a tax on their income. One recent study 
estimates that a typical daily commuter to the District pays about $250 
per year in sales and excise taxes, parking taxes, and purchases of 
lottery tickets. [Footnote 17] Another study suggests that spending by 
commuters supports many jobs for District residents who are subject to 
the city’s income tax.[Footnote 18] We were unable to find data on the 
amount of taxes paid directly by commuters, the tax revenues 
attributable to jobs supported by them, or the amount of money that the 
District must spend to extend services to them, nor have we assessed 
the accuracy of the estimates cited above. Consequently, we cannot 
determine conclusively whether the net fiscal impact of commuters in 
the absence of a commuter income tax is negative or positive. 

Regardless of the current net fiscal impact of commuters, the District’s
finances clearly would benefit considerably from a tax on nonresidents’
incomes. The ultimate burden of a nonresident income tax for the 
District would not necessarily be borne by commuters into the District. 
The distribution of the burden would depend on the nature of the 
crediting mechanism that would be established under such a tax. For 
example, if the District’s tax were made fully creditable against the 
federal income tax liabilities of the commuters, as is proposed in the 
District of Columbia Fair Federal Compensation Act of 2002, then the 
federal government would bear the cost and would have to either reduce 
spending or make up for this revenue loss by other means. However, if 
the federal income tax credit was not available, and instead the states 
of Maryland and Virginia allowed their residents to fully credit any 
tax paid to the District against their state income tax liabilities, 
then those two states would suffer a revenue loss (relative to the 
current situation). The two states could respond to a District commuter 
tax by taxing the income of District residents who work within their 
jurisdictions or increasing the tax rates on all of their residents. 
[Footnote 19] If the District’s tax were not fully creditable against 
either the federal or state taxes, then the commuters themselves would 
bear additional tax burden. 

The District’s Estimates of Spending Requirements: 

Although the District’s overall warning that it faces structural 
challenges in balancing revenues and spending requirements should be 
taken seriously, the District’s estimates of its spending requirements 
have serious limitations. The District does absorb certain costs 
associated with supporting services typically provided at the state 
level as well as with providing services to the federal government. 
However, the District’s estimates of its costs to provide services to 
the federal government and its costs of providing state-like services 
are not supported with detailed data or analysis. Also, the District’s 
estimates do not reflect municipal-type services provided directly by 
the federal government. In addition, the District’s estimates of its 
fiscal structural imbalance do not include potential cost savings from 
improving management efficiency. Further, the District has developed 
its budget estimates based on the current level of services as the 
baseline going forward. According to District officials, no studies 
have been done to determine the level of services necessary, and the 
District continues to struggle to determine the level of services to
provide, given the perceived political barriers to achieving structural
changes in large programs such as public schools, Medicaid, and human
services. Finally, the District has not considered potential savings in 
its estimates of its fiscal structural imbalance. 

District-Estimated Spending for State-Like Functions: 

According to District officials, the District government performs state-
like functions that contribute to what it considers a structural 
imbalance. Although the District has costs associated with certain 
state-like functions, it is important to note that the District also 
collects and retains state-like income and sales tax revenues to fund 
these functions and support the activities of some agencies. [Footnote 
20] The District estimated the cost of state-like functions to be $487 
million in fiscal year 2002. However, this estimate is based on very 
limited analytic support. Broad assumptions were made and the analysis 
was made based on a review of only one jurisdiction. 

To arrive at its cost estimate, the District has identified state-like 
functions in 10 different District agencies for fiscal year 2002. To 
identify the state-like functions, District officials reviewed the 
State of Maryland’s fiscal year 2002 operating budget to identify state 
funding to local governments and compared this information with the 
District’s fiscal year 2002 operating budget. Based on this review and 
comparison, District officials identified the following 10 District 
agencies that provide some state-like functions: 

* Department of Mental Health, 
* Department of Human Services, 
* Child and Family Services Agency, 
* University of the District of Columbia, 
* Department of Motor Vehicles, 
* Office of Tax and Revenue, 
* Department of Insurance and Securities Regulation, 
* Public Service Commission, 
* Office of Cable and Television Communications, and, 
* District of Columbia National Guard. 

Using the Maryland state budget as a guide, District officials used 
their judgment to assign a “state allocation ratio” to each function in 
the 10 identified District agencies. For example, if a function, such 
as Temporary Assistance to Needy Families, received more than half of 
its funding from the state, then District officials assigned that 
function a 100 percent state allocation percentage. If a function 
received less than half of its funding from the state, the District did 
not consider it a state-like function and gave it a zero state 
allocation ratio. District officials considered the Office of Tax and 
Revenue both a state and local function and assigned it a 50 percent 
state allocation ratio. Two other District agencies, the Department of 
Human Services and the Child and Family Services Agency, also had a 
combination of state and local functions and therefore had a weighted 
state allocation ratio. 

District officials acknowledged that the state allocation ratios used to
create their cost estimates were primarily based on their own judgment 
and knowledge of state and local programs. Other than providing a 
summary of Maryland’s state budget, District officials were unable to 
provide additional documentation to support these decisions. District 
officials emphasized that, as with any of the cost estimates the 
District produced to illustrate what it considers a fiscal structural 
imbalance, these were only estimates. They cautioned that these 
estimates should not be added together to represent an aggregate cost 
resulting in a fiscal structural imbalance. A District official said 
that these estimates were meant only to illustrate different ways of 
understanding the structural imbalance issues that face the District. 

The District’s Estimated Costs of Services Provided to the Federal 
Government: 

The services identified by the District as being provided to support the
federal government’s presence are primarily administered by the 
District’s public works and public safety and justice agencies and 
include: 

* police protection for federal employees and for federally sponsored or
sanctioned events in the District, 

* fire suppression for federal buildings, 

* emergency medical treatment for federal employees, and, 

* snow removal and street repairs on streets used by federal vehicles 
and by federal workers commuting to work in the District. 

District officials estimated the services provided to the federal 
government cost the District up to $240 million annually. However, the 
District did not have a detailed list of actual services provided to 
the federal government to support its cost estimate. District officials 
estimated that 27 percent of the total assessed value of property in 
the District is owned by the federal government. As such, District 
officials have estimated that the cost of services provided to support 
the federal government’s presence in the District is based on 27 
percent of the proposed budgets for all of the District’s public works 
and public safety and justice agencies. However, these budgets include 
functions, such as the Department of Motor Vehicles, that provide 
minimal services to the federal government. 

The District’s cost estimate for services provided to the federal 
government does not consider the services provided by the federal 
government to the District or expenditures made by the federal 
government for its own property, when in fact, many federal agencies 
and properties provide for their own public safety and security and 
public works services. The National Park Service, for example, provides 
an extensive network of historical, educational, and recreational 
opportunities within the District. The federal government provides 
upkeep, maintenance, and restoration of facilities including not only 
well-known national sites such as the National Mall or Ford’s Theatre, 
but also parks such as those on Capitol Hill, including inner city 
medians, squares, and traffic circles, as well as other areas that 
provide urban green space within the city. According to the U.S. 
Department of Interior’s fiscal year 2003 budget request, operating 
costs for these parks will be $59 million. 

Federal law enforcement agencies operating within the District include
large forces, such as the U.S. Capitol Police with more than 1,400 
officers, and smaller forces, such as the Smithsonian Institution 
Protective Services with an estimated 600 officers. In addition, the 
General Services Administration’s Federal Protective Service provides 
law enforcement services to some federal properties throughout the 
District. These services include a share of police protection from 
disruptions by major demonstrations, perimeter security for federal 
buildings, criminal investigations to reduce crime, and training of 
security personnel. 

District’s Estimates of Imbalance Do Not Address Potential Cost 
Savings: 

The District’s estimates of its fiscal structural imbalance are 
premised on the maintenance of the existing level and costs of services 
now provided into the future. The District’s estimates did not address 
potential cost savings that could be achieved by improving management 
efficiency at the agency level. Reducing expenditures by improving 
efficiency could reduce any imbalance between the District’s revenues 
and expenditures without negatively impacting program service delivery 
to its citizens. For example, the March 2002 McKinsey & Company, Inc. 
study on the District’s financial position [Footnote 21] concluded that 
approximately $110 million to $160 million in annual cost savings could 
be achieved in health, human services, public safety, transportation, 
and the District of Columbia Public Schools (DCPS) by fiscal year 2005. 
If achieved, these potential savings could mitigate a fiscal structural 
imbalance in the District. However, considerable uncertainty exists 
about these estimates. 

Potentially the District could also achieve cost savings by correcting
problems that have resulted in disallowed Medicaid costs for the 
District. The District will not be receiving over $100 million of 
Medical Assistance Administration cost reimbursements for costs 
incurred in prior years. These cost reimbursements were disallowed for 
reasons including failure to file timely claims or provide adequate 
support for claims submitted.[Footnote 22] Nonreimbursed costs are paid 
out of local funds, not federal funds. 

Another example where potential cost savings could be achieved is the
DCPS. In the DCPS’ fiscal year 2001 Comprehensive Annual Financial
Reports (CAFRs), District officials reported a $64.5 million deficit in 
locally appropriated funds. During the fiscal year 2001 audit, the 
District’s financial statement auditors identified material weaknesses 
within the DCPS accounting and financial reporting processes, such as 
the monitoring of expenditures and accounting for Medicaid expenditures 
related to services provided to special education students. DCPS could 
become more efficient by improving its internal controls over financial 
accounting and reporting and reducing the risk of overspending within 
the DCPS programs. Public education has been a large driver of 
expenditures in the District, representing $1.1 billion of expenditures 
in fiscal year 2001.[Footnote 23] Since 1999, the annual increase in 
the District’s spending for public education has ranged between 19.4 
and 21.9 percent. Clearly, such spending increases are difficult to 
sustain. 

Impact of the Revitalization Act on the District: 

On August 5, 1997, the Congress passed the National Capital 
Revitalization and Self-Government Improvement Act, referred to as the 
Revitalization Act. The Revitalization Act made substantial changes in 
the financial relationship between the federal government and the 
District of Columbia as well as in the management of the District 
government. The District and several nonprofit public interest 
organizations have stated that the Revitalization Act, while not fully 
addressing the District’s fiscal challenges, is an excellent first step 
in helping the District to move towards long-term financial stability. 

The Revitalization Act made the following adjustments in the financial
relationship between the District and the federal government: 

* eliminated the federal government’s annual federal payment to the
District, and; 

* shifted to the federal government the financial responsibilities and, 
in some instances, administrative responsibilities, for the following 
justice functions in the District: 
- incarceration of sentenced adult felons (the Federal Bureau of 
Prisons assumed responsibility, and the District’s Lorton Correctional
Complex was recently closed); 
- the Superior Court, Appeals Court, and Court System (the Pretrial 
Services Agency and Public Defender Service functions, and the D.C.
Parole Board were abolished); and; 
- the District Retirement Program covering judges. 

Also under the Revitalization Act, the federal government assumed
financial and administrative responsibilities for one of the District’s 
largest fiscal burdens, which it inherited from the federal government 
as part of the transition to Home Rule in 1973—its unfunded pension 
liability for vested teachers, police, firefighters, and judges. In 
1998, the federal government assumed the accrued pension cost of $3.5 
billion that existed at the close of 1997. The District remains 
responsible for funding benefits for services rendered after June 30, 
1997, and continues the plan under substantially the same terms. In 
addition, the Revitalization Act was part of a larger act— the Balanced 
Budget Act of 1997—that increased the federal share of District 
Medicaid payments from 50 to 70 percent. 

Prior to the Revitalization Act, the District had been receiving a 
federal payment since the mid-1800s due to the District’s unique 
relationship with the federal government. The Congress recognized that 
the District’s ability to raise revenues was affected by a number of 
legal and practical limitations on its authority—the immunity of 
federal property from taxation; the building height restriction, which 
has a limiting effect on commercial property values; the prohibition on 
the District from passing a law to tax the income of nonresidents; and 
the restriction on imposing sales taxes on military and diplomatic 
purchases. 

Although the Revitalization Act repealed the federal payment to the 
District of Columbia, it also authorized a federal contribution. The 
Revitalization Act does not present a formula or methodology for 
translating the generalized notion of compensating the District for the 
federal government’s presence into a predictable dollar amount, nor 
does it require that a contribution be made. 

The changes to the District’s finances resulting from the 
Revitalization Act impacted both the District’s revenues and 
expenditures. The District estimates that the net benefit of the 
Revitalization Act has ranged from a net positive low of $79.1 million 
to a high of $203 million per year during the period 1998 through 2002. 
A detailed breakout of the estimated financial impact of the act on the 
District’s revenues and expenditures is presented in appendix II. 

Fiscal Structural Imbalance: More Comprehensive Approaches Should be
Explored: 

The District’s estimates of its fiscal structural imbalance point to 
many specific factors but do not constitute a comprehensive assessment 
of underlying imbalances between its expenditures and revenue capacity. 
The District has not yet determined whether even under the constraints 
they assert, it has the capacity to provide a level of services 
comparable to those provided by other cities with similar needs and 
costs. 

The District’s estimates essentially use a current services approach to
analyzing its fiscal structural imbalance. Even if the District is able 
to resolve the measurement and analytical problems discussed in this 
report, this approach would be limited because it assumes the 
desirability and continuation of current service levels and tax 
policies. An alternative approach would measure the existence of a 
fiscal structural imbalance by comparing the District’s spending and 
revenue capacity to levels in comparable jurisdictions. This approach 
assesses the ability of the District to provide at least an average 
level of services adjusted for its unique demographic profile and costs 
at an average tax burden. 

The main advantage of this approach is that the measure of fiscal 
structural imbalance reflects the underlying social and economic 
conditions affecting the cost of providing public services as well as 
the underlying strength of the tax base.[Footnote 24] For instance, 
this measure takes into account the specific factors influencing the 
demand for public services (e.g., a large number of school age 
children, road infrastructure) and its ability to fund these services 
with a tax burden on local residents that is comparable to other
jurisdictions providing comparable services. 

Under this framework, the structural position of a jurisdiction is not 
tied to current service levels, or spending or tax policies. From the 
perspective of this more comprehensive, comparative approach, a 
jurisdiction could suffer from a fiscal structural imbalance even if 
its current budget were balanced—in this case, the imbalance would be 
reflected in lower services, higher taxes, or deterioration of 
infrastructure when compared to averages in other communities. On the 
other hand, a jurisdiction with chronic current deficits may not have a 
fiscal structural imbalance if its deficits were prompted by spending 
levels or tax rates out of line with comparable jurisdictions with 
similar needs. 

At the present time, however, comprehensive data are not readily 
available to do such a comparative assessment. Preliminary indications 
suggest that the District would have to sustain a high level of 
expenditures compared to other state and local areas to provide an 
average level of services adjusted for its unique demographic profile 
and costs. However, when compared to other entities, the city also has 
among the highest revenue capacity, or ability to raise revenue from 
its own sources, even accounting for the federally imposed constraints 
on the city’s revenue-raising authority. 

The most recent comprehensive comparison that we found uses the 
Representative Expenditure System (RES) to estimate the relative 
expenditure needs of states together with their localities, or in the 
terms used in this report, the benchmarked expenditures of the states 
and localities.[Footnote 25] This study indicates that, in 1996, the 
District’s per capita relative expenditures were higher than those of 
any state. However, this measure has certain shortcomings that could 
result in understatements of the District’s relative expenditures. 

The two most recent cross-state comparisons of revenue capacity indicate
that the District’s revenue capacity per capita compares favorably to 
that of most states.[Footnote 26] These studies use two fundamentally 
different measures of revenue capacity, both of which largely take into 
account the fact that the District is prohibited from taxing the 
District-source incomes of nonresidents. For 1999, the most recent year 
for which the Department of the Treasury has estimated the Total 
Taxable Resources (TTR) of states, the District’s value for this 
particular measure of revenue capacity exceeded that of every state, 
except Connecticut.[Footnote 27] In 1997 and 1998, the District’s value 
was higher than that of every state. The most recent available study 
that uses the Representative Tax System (RTS) methodology for 
estimating revenue capacity indicates that, in 1996, the District’s 
revenue capacity per capita exceeded that of 46 states.[Footnote 28] 

However, results of these studies are imprecise and do not allow for
conclusions on whether the District has a structural imbalance. The
measures of the benchmarked expenditures and revenue capacity used in
these studies are out of date. Moreover, as acknowledged by the author 
of the referenced study on expenditures, the estimates of the spending
needed to realize average levels of service do not reflect certain 
relevant workload and cost differences across jurisdictions. 

Ultimately, the revenue capacity and expenditure needs would have to be
put together to address whether the District has the revenue capacity to
provide for at least average levels of services for its unique workload 
and costs with an average tax burden. Such a comparative analysis would 
need to adjust for the fact that the District may not directly compare 
to any current jurisdiction in the nation, owing to its unique 
combination of state and city functions and revenues. GAO is currently 
undertaking such an assessment and will report the results of our study 
next year. 

Conclusions: 

While it has made significant progress over the past several years, the
District, similar to many other jurisdictions, continues to face a 
series of substantial, long-term challenges to its financial viability. 
Addressing these challenges requires continued dedicated leadership to 
make the difficult decisions and trade-offs among competing needs and 
priorities. 

Presently, insufficient data or analysis exist to discern whether or to 
what extent the District is, in fact, facing a fiscal structural 
imbalance. On the revenue side, the District clearly has constraints in 
its ability to increase its tax base. However, the District’s estimates 
of its possible fiscal structural imbalance have limitations and did 
not address the levels or costs of services for its citizens in the 
long term, whether such services could be supported by its present tax 
structure or tax base, or cost savings that can be achieved from 
management efficiencies. The available studies comparing revenue 
capacity and expenditures across jurisdictions are imprecise and some 
may not be applicable to the District. 

As such, the Congress would benefit from more systematic information
about the District as it considers proposals for addressing the fiscal
structural imbalance that the District is currently asserting exists. A
fundamental analysis of the District’s underlying capacity to finance 
at least an average service level in relation to its needs can help 
determine if there is a fiscal structural imbalance. Such an analysis 
would provide a stronger foundation for decision makers at all levels 
to address the District’s financial condition. 

We currently have ongoing work in this area and plan to issue a future
report with a more comprehensive analysis of the District’s long-term
financial condition. Therefore, we are not making any recommendations at
this time. 

Comments from the District of Columbia and Our Response: 

In responding to a draft of this report, both the Mayor and the Chief
Financial Officer of the District stated their belief that the District 
faces a fiscal structural imbalance, but agreed that further analysis 
of the District’s fiscal situation is needed because existing data and 
analysis are not sufficient to discern the degree to which the District 
is, in fact, facing a structural imbalance. The District reiterated the 
general areas it believes are drivers of the reported fiscal imbalance, 
and, in the District CFO’s response, suggested that the annual 
imbalance was roughly twice the amount reported earlier this year. 
However, as we stated in our report, we concluded that insufficient 
data and analysis exist to substantiate the District’s earlier 
estimates of its reported structural imbalance. In addition, as stated 
in our report, the District’s estimates of its costs for providing 
services to the federal government and state-like services lack detailed
support and have limitations. 

We have work ongoing in this area and plan to issue a future report 
with a more comprehensive analysis of the District’s long-term financial
condition. Our future analysis will consider the extent to which the
components of the District CFO’s estimates and other important factors,
including those where the District has advantages and disadvantages
relative to other jurisdictions, impact the District’s overall fiscal 
situation. The Mayor and the District’s CFO stated that the District 
will support our efforts by providing necessary information and 
assistance. 

We are sending copies of this report to the Ranking Minority Member of 
the Subcommittee on the District of Columbia, House Committee on
Appropriations, and to other interested congressional committees. We are
also sending copies to the Mayor of the District of Columbia, the 
Chair, DC Council, City Administrator/Deputy Mayor for Operations, 
Chief Financial Officer, and Inspector General. Copies of this report 
will also be made available to others upon request. 

Please contact me at (202) 512-9471 or Patricia Dalton at (202) 512-
6737 or by e-mail at franzelj@gao.gov or daltonp@gao.gov if you or your 
staff have any questions concerning this report. 

Sincerely yours, 

Signed by: 

Jeanette M. Franzel: 
Director, Financial Management and Assurance: 

[End of section] 

Appendix I: Scope and Methodology: 

To determine how the District and other jurisdictions define fiscal
structural imbalance, including the factors that contribute to the 
District’s reported imbalance, we: 

* interviewed and obtained information about fiscal structural balance
and imbalance from officials in various District offices, 

* analyzed reports and information received to define a fiscal 
structural imbalance, and, 

* analyzed the District’s general fund revenue and expenditures in 
fiscal year 2001 and prior years to identify significant fluctuations 
and programs that were driving costs. 

To provide information on the constraints on the District’s revenues, we
interviewed officials from the office of the District’s CFO and several 
local experts on the District’s economy and finances. We also reviewed a
number of studies prepared by the District, independent commissions, and
other researchers that contained information, evaluations, and estimates
relating to these constraints. 

To provide information on the District’s estimates of its spending
requirements, we interviewed District officials and analyzed District
budget documents and financial statements. To analyze the services
provided by the District to support the federal government, we 
interviewed District officials and analyzed relevant supporting 
information, such as budgets and financial plans. We also reviewed 
relevant information from the General Services Administration and other 
federal agencies on the costs and the types of services the federal 
government provides to its own property in the District. 

To identify and analyze the functions that the District contends are 
state-like functions, we interviewed District officials and requested 
and analyzed pertinent supporting information. We also reviewed an 
April 15, 1997, study by the D.C. Financial Control Board entitled, 
“Toward A More Equitable Relationship: Structuring the District of 
Columbia’s State Functions.” This study compared the District’s 
governmental functions to eight similar cities that were selected based 
on population size, degree of urbanization, the ratio of employed 
persons to total population, and other factors. In addition, we 
interviewed several local experts on the District’s economy and 
finances to obtain their perspective on the state-like functions 
performed by the District and the expenditures the District makes 
related to the federal presence. 

To address the question of the financial adjustments to the District of
Columbia’s finances as a result of the Revitalization Act, we reviewed: 

* relevant provisions of the Balanced Budget Act of 1997; [Footnote 29] 

* relevant provisions of the Revitalization Act; 

* relevant provisions of the District of Columbia Home Rule Act; 

* the District of Columbia Appropriations Acts for fiscal years 1998
through 2002; 

* analyses of the impact of the Revitalization Act on the District’s 
budget prepared by the Congressional Research Service; 

* the Operating Budget and Financial Plans of the District of Columbia 
for fiscal years 1998 through 2002 and the Proposed Operating and 
Financial Plan for fiscal year 2003; 

* prior GAO reports on District government financial operations; and; 

* the Department of the Treasury Accountability Report, Fiscal Years 
1998 through 2001. 

We also met with District officials and obtained their documentation
related to their projected net savings from the Revitalization Act. 

To provide information on the District’s revenue capacity compared to
other jurisdictions, we reviewed and summarized studies from the 
District’s CFO’s Office, the U.S. Department of the Treasury, and the
relevant economic literature. 

We conducted the work used to prepare this report from February to July
2002 in accordance with generally accepted government auditing 
standards. As stated previously, our work on this matter is ongoing. The
Mayor and the CFO of the District of Columbia provided comments on a 
draft of this report. Those comments are reprinted in appendixes III 
and IV, respectively, and have been incorporated in the report as 
appropriate. 

[End of section] 

Appendix II: The District’s Estimated Financial Net Benefits from the 
Revitalization Act: 

Tables 1, 2, and 3 present the District’s calculations of the projected 
net benefits from the Revitalization Act on the District’s budget for 
fiscal years 1998 through 2002. As shown in table 1, the District 
estimates that the net benefit of the Revitalization Act has ranged 
from a net positive low of $79.1 million to a high of $203 million a 
year during the period 1998 through 2002. 

Table 1: Projected Net Benefit of the Revitalization Act on the 
District’s Budget (in millions of dollars): 

Fiscal year: 1998; 
Total revenue impact: ($476.9); 
Total expenditure impact: $678.0; 
Net benefit: $201.1; 
Net benefit as a % of total general fund revenue: 4.6%. 

Fiscal year: 1999; 
Total revenue impact: ($666.9); 
Total expenditure impact: $746.0; 
Net benefit: $79.1; 
Net benefit as a % of total general fund revenue: 1.6%. 

Fiscal year: 2000; 
Total revenue impact: ($667.1); 
Total expenditure impact: $784.6; 
Net benefit: $117.5; 
Net benefit as a % of total general fund revenue: 2.2%. 

Fiscal year: 2001; 
Total revenue impact: ($667.1); 
Total expenditure impact: $825.1; 
Net benefit: $158.0; 
Net benefit as a % of total general fund revenue: 2.9%. 

Fiscal year: 2002; 
Total revenue impact: ($667.1); 
Total expenditure impact: $870.3; 
Net benefit: $203.2; 
Net benefit as a % of total general fund revenue: 3.8%[A]. 

Note: Differences due to rounding. 

[A] Fiscal year 2002 ratio is based on estimated revenues. 

Source: Fiscal year 1999 Operating Budget and Financial Plan, 
Government of the District of Columbia (unaudited). 

[End of table] 

Table 2: Estimated Reductions in Revenue as a Result of the National 
Capital Revitalization Act (in millions of dollars): 

Fiscal year: 1998; 
Loss of federal payment: ($660.0); 
Federal contribution: $190.0; 
Loss of court fees[A]: ($6.9); 
Total reductions in revenue: ($476.9); 

Fiscal year: 1999; 
Loss of federal payment: ($660.0); 
Federal contribution: 0; 
Loss of court fees[A]: ($6.9); 
Total reductions in revenue: ($666.9). 

Fiscal year: 2000; 
Loss of federal payment: ($660.0); 
Federal contribution: 0; 
Loss of court fees[A]: ($7.1); 
Total reductions in revenue: ($667.1). 

Fiscal year: 2001; 2002
Loss of federal payment: ($660.0); 
Federal contribution: 0; 
Loss of court fees[A]: ($7.1); 
Total reductions in revenue: ($667.1). 

Fiscal year: 2002; 
Loss of federal payment: ($660.0); 
Federal contribution: 0; 
Loss of court fees[A]: ($7.1); 
Total reductions in revenue: ($667.1). 

Note: Differences due to rounding. 

[A] The fees are deposited in the DC Crime Victims Fund and used to pay 
the costs of the District’s Crime Victim program. 

Source: Fiscal year 1999 Operating Budget and Financial Plan, 
Government of the District of Columbia (unaudited). 

[End of table] 

Table 3: Estimated Reductions in Expenditures as a Result of the 
National Capital Revitalization Act (in millions of dollars): 

Fiscal year: 1998; 
Adult Felony Prisoners[A]: $169.0; 
Pretrial Services: $4.6; 
Parole Board: $5.8; 
Court of Appeals: $6.0; 
Public Defender: $7.8; 
Superior Court: $73.0; 
DC Court System: $35.2; 
Medicaid: $136.2; 
Pensions: $250.0; 
Debt Service[B]: ($9.5); 
Total reductions in expenditures: $678.1. 

Fiscal year: 1999; 
Adult Felony Prisoners[A]: $185.0; 
Pretrial Services: $4.7; 
Parole Board: $5.9; 
Court of Appeals: $6.1; 
Public Defender: $7.9; 
Superior Court: $74.6; 
DC Court System: $36.1; 
Medicaid: $166.2; 
Pensions: $269.0; 
Debt Service[B]: ($9.5); 
Total reductions in expenditures: $746.0. 

Fiscal year: 2000; 
Adult Felony Prisoners[A]: $190.6; 
Pretrial Services: $4.7; 
Parole Board: $6.1; 
Court of Appeals: $6.2; 
Public Defender: $8.1; 
Superior Court: $76.0; 
DC Court System: $37.0; 
Medicaid: $175.4; 
Pensions: $290.0; 
Debt Service[B]: ($9.5); 
Total reductions in expenditures: $784.6. 

Fiscal year: 2001; 
Adult Felony Prisoners[A]: $196.3; 
Pretrial Services: $4.8; 
Parole Board: $6.2; 
Court of Appeals: $6.4; 
Public Defender: $8.2; 
Superior Court: $77.7; 
DC Court System: $38.0; 
Medicaid: $185.1; 
Pensions: $312.0; 
Debt Service[B]: ($9.5); 
Total reductions in expenditures: $825.2. 

Fiscal year: 2002; 
Adult Felony Prisoners[A]: $202.2; 
Pretrial Services: $5.0; 
Parole Board: $6.4; 
Court of Appeals: $6.5; 
Public Defender: $8.4; 
Superior Court: $80.0; 
DC Court System: $39.2; 
Medicaid: $196.2; 
Pensions: $335.9; 
Debt Service[B]: ($9.5); 
Total reductions in expenditures: $870.3. 

Note: Differences due to rounding. 

[A] Adult felony prisoner savings for fiscal year 1999 are based on the 
amount proposed in the President’s fiscal year 1999 budget with a 3 
percent growth in fiscal years 2000 to 2002. 

[B] Debt service impact is based on $110 million intermediate-term 
borrowing in fiscal year 1998, and short-term borrowing of $200 million 
in each year for seasonal cash needs. 

Source: Fiscal year 1999 Operating Budget and Financial Plan, 
Government of the District of Columbia (unaudited). 

[End of table] 

[End of section] 

Appendix III: Comments from the Mayor of the District of Columbia: 

District of Columbia: 
Anthony A. Williams: 
Mayor: 

August 16, 2002: 

Ms. Jeanette M. Franzel: 
Director, Financial Management and Assurance: 
Attn: Ms. Norma Samuel: 
United States General Accounting Office: 
441 G. St. NW: 
Washington, D.C. 20548: 

Dear Ms. Franzel: 

The purpose of this letter is to comment on the interim report to be 
issued on the District's structural imbalance. As an interim product, 
this report serves to outline the issues to be addressed in the full 
analysis currently under development by GAO. In so doing, it recognizes 
several key challenges faced by the District, including: 

* major responsibilities for state level services; 

* unique mandates for providing services to the federal government; 
and; 

* restrictions on taxing authority faced by no other state in the 
union. 

This interim report also acknowledges, however, that further analysis 
must be completed to assess the degree to which the District's 
constraints can be offset by greater revenue collection and by 
efficiency gains. The District is actively reviewing all measures 
available to address this structural imbalance, and is working closely 
with the GAO to provide the information necessary to assist in 
identifying such opportunities. 

As stated by our Independent Chief Financial Officer, however, meeting 
higher levels of revenue collection and operational efficiency can only 
partially offset the constraints placed by the federal government. 
Therefore, federal leaders must ultimately decide to either reduce 
their uncompensated service demands on the District, provide some 
direct compensation for those services, eliminate the restrictions on 
the District's tax base, or enact some combination of these actions. 

I look forward to our continued cooperation with the GAO and federal 
leaders in finding an appropriate federal response to this challenge. 

Sincerely, 

Signed by: 

Anthony A. Williams: 

[End of section] 

Government Of The District Of Columbia: 
Office of the Chief Financial Officer: 
Natwar M. Gandhi: 
Chief Financial Officer: 
1350 Pennsylvania Avenue, N.W., Suite 209: 
Washington, D.C. 20004: 
(202) 727-2476: 
[hyperlink, http://www.dccfo.com]: 

August 15, 2002: 

Ms. Jeanette M. Franzel: 
Director, Financial Management and Assurance: 
Attn: Ms. Norma Samuel: 
United States General Accounting Office: 
Washington, D.C. 20548: 

Dear Ms. Franzel: 

Thank you for the opportunity to comment on your draft report entitled 
District of Columbia: Fiscal Structural Imbalance. 

As I read the report, it concludes that the District has not decisively 
proved that there is a long-term structural imbalance because the 
District might be able to reduce spending or increase taxes. It further 
states that the extent of interplay between the costs to the District 
of providing service to the Federal Government and the benefits to the 
District of the Federal presence needs to be refined if a true picture 
of any structural imbalance is to be calculated. 

The Office of the Chief Financial Officer of the District of Columbia 
endorses your recommendation to analyze this issue further, in greater 
detail and with additional sophistication. We will continue to support 
your effort with such information and analyses we have been able to 
develop using our own resources. 

I believe the report should make a clear statement that the District is 
unlike any other U.S. jurisdiction, with the functions of a national 
capital, state, and municipality. Having been said so often, this 
statement has become a virtual truism. However, this difference from 
other municipalities has enormous significance in understanding D.C.'s 
finances and these differences need to be highlighted. 

First, while the District has state-like taxes, especially the 
individual and business income taxes, it does not have state-like tax 
bases. Specifically, the suburban "ring" with its concentration of 
income is largely outside of D.C. boundaries and its taxing authority. 
States use revenue from the suburbs to support the urban core and 
poorer rural areas. Unlike states, D.C. cannot tax incomes earned by 
all those working here; only the much smaller income amount earned by 
residents is in the tax base. 

Second, unlike other cities, D.C. has severe restrictions on its real 
property tax base imposed by the Federal government. These revenues are 
strictly constrained by the amount of federal and other property made 
tax exempt by the federal government or by foreign ownership. This adds 
up to 28 percent of the assessed value of the entire real property tax 
base (including both taxable and tax exempt property) according to real 
property tax records. The taxable base would increase by 48 percent if 
this tax-exempt property were taxed. 

Third, D.C. exists because of the presence of the Federal government 
and clearly benefits from that presence. Other cities may also rely on 
one or a few big businesses for their existence and, usually, as their 
revenue mainstays. The federal government, however, both does not pay 
tax to D.C. and constrains D.C.'s tax bases. Like major companies in 
other cities, the Federal government provides indirect benefits to the 
District. Some sales tax revenues are raised from federal workers and 
visitors who come to the nation's capital. Some federal services 
protect D.C. against threats leveled at the federal government. None of 
these measures, however, change the fundamental imbalance created by 
revenue constraints. 

There are no reductions to D.C.'s expenditure requirements comparable 
to its revenue constraints. This simple relationship between 
expenditures and a constrained tax base sets in place a structural 
imbalance. It is exacerbated by the District's role as the nation's 
capital, a place that is expected to be extraordinary in the eyes of 
the world and the pride of the nation's citizens. 

The existence of a structural imbalance does not mean that D.C.'s 
budget is out of balance, nor does it tell us how efficiently the money 
is spent. In fact, riding the rising national economic tide, D.C.'s 
recent record in balancing budgets is quite good, although cost- 
effective spending remains a top priority for internal management 
reform. The time is upon us when the underlying economics and financial 
constraints imposed on D.C. will result in an inability to maintain 
adequate municipal services without instituting actions that are self-
defeating for a viable community in the long-term. 

In spite of its balanced budget and financial plan, the District 
currently faces severe budget pressures. These pressures are being 
managed in several ways. First, the District plans to improve 
management efficiency and reduce the cost of providing certain services 
by $150 million by FY 2005. Secondly, the District is and has been 
deferring capital expenditures. In FY 2003, $230 million in capital 
expenditures from the prior capital budget were eliminated to reduce 
debt service costs in the operating budget. Over the past two decades, 
about $4 billion in infrastructure needs have accumulated for such 
items as school repair, improvement of the WMATA rail system, and storm-
sanitary sewers. D.C. simply does not have the capacity to fund all of 
these long-term service requirements. In formulating the FY 2003 
budget, about $90 million in reductions were made to current services 
operations across the government. Even these kinds of measures will not 
allow a balanced budget going forward without tax increases deep 
spending cuts or a resolution to the structural imbalance issue. 

Neither can the District's cash reserves[Footnote 30] and budget 
reserve[Footnote 31] protect against a structural problem for long. Any 
money that the District spends from these funds must be replaced the 
following year. Because structural problems are long-term in nature, 
replacing the funds will only exacerbate an underlying problem in the 
year after the funds are used. 

The economic and revenue boom experienced in FY 1997-2000 cannot be the 
premise for revenue expectations going forward. Reliable economic 
growth is slower and more steady and is simply not sufficient to 
maintain current expectations regarding city services or the 
unaddressed backlog of needs from the past. 

The Congress of the United States has always recognized the unique 
status of the District of Columbia and its responsibilities arising 
from that unique status. Its approach to addressing the financing of 
municipal services has varied over the years - from assuming complete 
financial responsibility for the provision of such services, to 
providing a Federal payment to underwrite a portion of those services 
to assuming responsibility for or providing targeted resources for 
selected programs. Currently, the Congress has directed through the 
1997 Revitalization Act that some state-like functions be performed for 
the District by the Federal government. The Act provided expenditure 
relief to the District of roughly $200 million annually, arising from 
assumption of the unfunded portion of the federal pension liability,' 
prison costs, and 20 percent of Medicaid costs. The estimate is net of 
the annual federal payment of $660 million that was revoked. The 
Congress also annually funds selected municipal projects of particular 
interest. 

We have estimated components of the Structural Imbalance in D.C. as 
follows: 

Constrained income tax base: 
Estimated Annual Impact: $540 million[Footnote 32]; 

Inability to tax federal office buildings: 
Estimated Annual Impact: $180 million[Footnote 33]; 

Inability to tax other federal property: 
Estimated Annual Impact: NA[Footnote 34]; 

Services provided to the federal government: 
Estimated Annual Impact: $240 million [Footnote 35]; 

Services provided to D.C. by the federal government: 
Estimated Annual Impact: ($200 million); 

State-like services provided by the District: 
Estimated Annual Impact: $500 million; 

Total: 
Estimated Annual Impact: more than $1 billion. 

These components add to more than $1 billion annually. There is no 
doubt that the District benefits from services provided to the District 
such as additional law enforcement presence. Further analysis might 
also show a more complete picture of the cost of state-like functions, 
but the fact that D.C. carries these functions remains. Improved 
administrative efficiency can also help to balance budgets. With 
respect to taxes, the District competes for residents with other 
jurisdictions in the Metropolitan area. The issue is not what our 
residents could pay given their relative affluence, but what they 
expect to pay when they decide where to locate in the larger 
Metropolitan area. 

We recommend that, with respect to taxes, any subsequent tax analysis 
focus on our metropolitan region and not on a comparison with other 
local or state jurisdictions outside the area. While no means the only 
factor individuals assess in making a determination of where to live, 
tax rates are clearly a very significant factor. Our analysis has shown 
while the District has higher income tax rates and lower real property 
tax rates, its composite tax rate is as high or higher than any of the 
surrounding jurisdictions. The same is true with respect to businesses. 
[Footnote 37] To us, this means the District has little latitude to tax 
its way to fiscal balance. A long-term strategy of taxing residents to 
close fiscal gaps will ultimately erode the tax base itself unless our 
actions are in concert with those of our neighbors. 

Since I joined the District Government in 1997 it has become 
increasingly apparent to me that the District faces unique programmatic 
and financing issues. Taken together these issues create a long-term 
imbalance between spending needs and revenue resources. This is not a 
new insight. Discussions of D.C.'s structural imbalance have been 
around for a long time. The (Dr. Alice) Rivlin Report of 1990 
identifies the problem, as did the work of Dr. Andrew Brimmer in 1986. 
[Footnote 38] Going much further back in time, the U.S. Senate held 
extensive hearings on the issue in 1916 under Public Act 268. 

We recommend that your charter be broadened to speak to the various 
methods the Federal government could use to redress any structural 
imbalance because we believe the real issue is finding a solution to 
the imbalance that meets today's circumstances. At this point your 
recommendations for subsequent analysis do not extend to providing any 
information on how the Congress might best address a structural 
imbalance. I am confident that further study will reveal to the GAO 
that this imbalance exists although your conclusions on the dimensions 
of its current magnitude may differ from ours. We would appreciate your 
bringing our recommendation on this matter to members of the Congress 
when you brief them on the final report. 

I also ask that your next report be completed in time for deliberations 
on the FY 2004 budget. The District of Columbia by organic law is 
required to submit and maintain a balanced budget and we will do so. 
For FY 2003, the District's revenues are approximately $250 million 
lower than projected this time last year. To bring the District's 
budget into balance, policy makers have already reduced planned 
spending, forgone planned tax cuts and increased selected fines and 
fees. While program efficiencies can be a contributor to a balanced 
budget strategy, further program cuts will be required and will soon 
manifest themselves to the public. 

Sincerely, 

Signed by: 

Natwar M. Ghandi: 
Chief Financial Officer: 

[End of section] 

Footnotes: 

[1] An unqualified opinion means that the financial statements are 
presented fairly, in all material respects, in conformity with 
generally accepted accounting principles. 

[2] The Revitalization Act is Title XI of Pub. L. No. 105-33, 111 Stat. 
712 (1997). Public Law 105-33 in its entirety is entitled the Balanced 
Budget Act of 1997. 

[3] Additional detail on our scope and methodology is presented in app. 
I. 

[4] McKinsey & Company, Inc, A Report to the Federal City Council: 
Assessing the District of Columbia’s Financial Position (Washington, 
D.C.: 2002). 

[5] The FCC is a nonprofit and nonpartisan organization dedicated to 
the improvement of the nation’s capital. FCC was established in 1954 
and is composed of and financed by 150 business, professional, 
educational, and civic leaders. 

[6] As discussed in a later section of this report, the McKinsey study 
also points out that the District has opportunities to achieve cost 
savings that would potentially mitigate the projected deficits. 

[7] Center on Budget and Policy Priorities, State Responses to Tight 
Fiscal Conditions: Short Term Fixes May Backfire if the Economy Does 
not Soon Recover; Cyclical Downturn Masks Structural Problems in Some 
States (Washington, D.C.: 2001). 

[8] These figures were provided to us by the District. We did not audit 
or verify the data. 

[9] The figures relating to nonresident income and real property were 
provided to us by the District. We did not audit or verify the data. 

[10] These figures were provided to us by the District based on real 
property tax records. We did not audit or verify the data. 

[11] DC Code, 2001 Ed. §§ 1-206.02 (6) and 6-601.05. 

[12] See Stephen S. Fuller, “The Economic and Fiscal Impacts of the 
Proposed International Monetary Fund Building” and “The Economic Impact 
of George Washington University on the Washington Metropolitan Area,” 
Greater Washington Research Center (Washington D.C.: 2000). 

[13] Section 602(a) (5) of the District of Columbia Home Rule Act, D.C. 
Code, 2001 Ed. 31-206.02(a)(5) states that the District’s Council may 
not “impose any tax on the whole or any portion of the personal income, 
either directly or at the source thereof, of any individual not a 
resident of the District.” 

[14] This general discussion is drawn from the State of Wisconsin, 
Legislative Fiscal Bureau, Individual Income Tax Provisions in the 
States (January 2001); Advisory Commission on Intergovernmental 
Relations, Significant Features of Fiscal Federalism, volume 1, 
(Washington, D.C.: 1995); Carol O’Cleireacain, The Orphaned Capital: 
Adopting the Right Revenues for the District of Columbia (Washington, 
D.C.: 1997); and District of Columbia Department of Finance and 
Revenue, Study of Property, Income and Sales Tax Exemptions in the 
District of Columbia (Washington, D.C.: 1995). The range of tax rates,
in the jurisdictions we identified as levying commuter taxes, was 
verified using publicly available tax descriptions drafted by the 
individual jurisdictions. 

[15] Grants from a state to city government do not represent the net 
fiscal flow between the two jurisdictions. States collect significant 
amounts of tax revenue from individuals, businesses, and transactions 
located in cities. The net fiscal flow would equal state grants and 
direct state spending in a city (excluding any pass-through of federal 
funds), minus all state revenues collected in that city. 

[16] Howard Chernick, “The Effect of Commuters on the Fiscal Costs of 
the District of Columbia” (Washington, D.C.: 2002). 

[17] Philip M. Dearborn, “Effects of Telecommuting on Central City Tax 
Bases,” Brookings Greater Washington Research Program (Washington, 
D.C.: 2002). The study did not attempt to estimate the indirect fiscal 
contributions that commuters may have through taxes on their employers. 

[18] Stephen S. Fuller, “The Economic and Fiscal Impacts of the 
Proposed International Monetary Fund Building at 1900 Pennsylvania 
Avenue, NW on the District of Columbia,” prepared for the International 
Monetary Fund (Washington, D.C.: 2001). 

[19] The District, Maryland, and Virginia currently have reciprocity 
agreements under which each government allows residents to pay income 
tax only in the jurisdiction where they reside. 

[20] Although some cities do levy income and sales taxes, they are 
usually at a relatively lower level than the income and sales taxes at 
the state level. 

[21] McKinsey & Company, Inc, A Report to the Federal City Council: 
Assessing the District of Columbia’s Financial Position (Washington, 
D.C.: 2002). 

[22] The District’s 2003 proposed budget submission includes plans to 
improve Medicaid cost reimbursement in the future. 

[23] The District CAFR, exhibit S-2, p. 115. 

[24] For additional information on analyzing jurisdictions’ 
expenditures and capacity, see U.S. General Accounting Office, State 
and Local Finances: Some Jurisdictions Confronted by Short-and Long-
Term Problems, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/HRD-94-
1] (Washington, D.C.: Oct. 6, 1993) and Robert Tannenwald, “Fiscal 
Disparity Among the States Revisited,” New England Economic Review 
(July/August 1999). 

[25] See Tannenwald. The RES approach estimates the amount of money 
each state, together with its localities, would have to spend in order 
to provide a standard, representative package and level of services. 

[26] U.S. Department of the Treasury, Office of Economic Policy, 2001 
Estimates of TTR (Sept. 28, 2001), and Tannenwald, pp. 3-25. 

[27] TTR is defined as the unduplicated sum of the income flows 
produced within a state and the income flows received by its residents 
that a state can potentially tax. 

[28] The RTS approach evaluates tax capacity by estimating the per 
capita yield that a uniform, hypothetical, representative tax system 
would produce in each state. 

[29] Pub. L. No. 105-33, § 4725(b), 111 Stat. 251 518 (1997). 

[30] Restricted-use cash reserves totally 7% of local source 
expenditure will be in place by October 1, 2002. 

[31] For FY2003, D.C. carries a $70 million budget reserve. It is 
replaced by an unrestricted $50 million cash reserve in FY2004. 

[32] The federal government's assumption of the federal portion of the 
Retirement Program relieved the District of the financial burden that 
it inherited from the federal government (approximately $1.9 billion of 
unfunded actuarial liability and $3.5 billion of accrued pension cost 
for prior service by participants--source - Fr 1997 CAFR Note 1p 
Summary of Significant Accounting Policies). The assets of the pension 
fund were transferred to the federal government in 1997. 

[33] This assumes a wage tax on non-resident earnings of 2 percent. 
With the recent rise in wages, this value is increasing. Recent Bureau 
of Economic Activity data increase the estimate of earnings for the 
second time, putting yield from a 2% tax rate at about $540M annually. 

[34] Federally owned office buildings are in direct competition with 
privately owned buildings. 

[35] This category includes `unique' federal properties. While no loss 
is imputed, in part because the monuments, parks, and official 
buildings bring visitors who help offset other revenues foregone, some 
loss may exist. The Federal government recognized this for 41 states 
having federal forestland in FY 2000 by providing formula-driving 
compensation for schools and transportation (The Secure Rural Schools 
and Community Self-Determination Act of 2000, P.L. 106-393, provided an 
alternative funding option to the revenue sharing arrangement in place 
since 1908). Because Federal property in the District has never been 
revenue-generating forestland, the District receives no payment under 
the system, though the Federal land, in cases such as Rock Creek Park, 
arguably have the same impact on revenues. 

[36] The calculation is simply a proportion of D.C. expenditures on 
Public Works and Public Safety that equals the proportion of federal 
property of all property value in the District. With further work this 
estimate will be perfected. 

[37] The District's individual income tax burden is about 34% higher 
than if District taxpayers were taxed at Virginia rates. It is also 
higher than in Maryland. The District's real property tax burden is 54% 
higher than Montgomery County and 15% above that of the City of 
Alexandria. 

[38] "Fiscal Prospects for the State of New Columbia" presented 
September 11, 1986 to the D.C. Statehood/Compact Commissions by Brimmer 
& Associates. 

[End of section] 

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