This is the accessible text file for GAO report number GAO-10-11 
entitled 'Budget Issues: Electronic Processing of Non-IRS Collections 
Has Increased but Better Understanding of Cost Structure Is Needed' 
which was released on November 20, 2009. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

November 2009: 

Budget Issues: 

Electronic Processing of Non-IRS Collections Has Increased but Better 
Understanding of Cost Structure Is Needed: 

GAO-10-11: 

GAO Highlights: 

Highlights of GAO-10-11, a report to congressional requesters. 

Why GAO Did This Study: 

The Department of the Treasury’s Financial Management Service (FMS) 
collections program provides services to agencies to collect, deposit, 
and account for collections through a variety of methods. Electronic 
collection methods can reduce government borrowing costs and agency 
administrative costs, while improving compliance and security. GAO was 
asked to identify (1) the extent to which agencies other than IRS use 
various collection methods, (2) ways to maximize the benefits of and 
overcome any barriers to agency use of the various collection methods, 
and (3) issues that FMS should consider in its plans to improve the 
efficiency and security of collections. GAO analyzed collections data, 
plans, and documents from FMS and five case-study agencies in the 
Departments of the Interior and Commerce that use a variety of 
collection methods, observed fee collection methods, and interviewed 
FMS and case-study agency officials. GAO also interviewed selected 
payer groups for case study agencies. 

What GAO Found: 

Over the past 5 years, more than 80 percent of funds collected by 
agencies other than the Internal Revenue Service (IRS) were collected 
using fully electronic methods, including wire transfers and credit 
cards. As shown in the figure below, from fiscal year 2005 through 2009 
there was a significant shift from nonelectronic collection methods to 
partly electronic methods. This shift was largely a result of a growth 
in electronic check-processing capacity. 

Moving to electronic collection methods can reduce costs and mitigate 
risks, such as theft, but the specific circumstances of individual 
agencies and payers have affected agencies’ ability to fully adopt 
these methods. Use of electronic methods can result in cost savings, 
increased processing speed and accuracy, and improved security of staff 
and deposits. Specifically, FMS reports that on average the government 
saves 78 cents for each electronic transaction. Additionally, case-
study agencies and payer groups GAO spoke with reported reduced costs 
when using electronic collection methods. Despite the advantages, payer 
characteristics, other agency considerations, and set-up costs or 
required system changes have limited agencies’ adoption of electronic 
collection methods. Also, agencies may not have enough information to 
make cost-effective decisions about their choice of collection method. 

FMS is implementing a plan to improve the efficiency and effectiveness 
of federal collections, but the plan excludes important cost 
considerations and does not use all available incentives. Specifically, 
the plan does not consider the cost differences among different 
electronic methods or ensure the consistent application of policies on 
reimbursement for certain services. The FMS plan also does not include 
a strategy for incorporating key lessons-learned from agency reviews 
into its guidance and communicating that information to agencies. With 
such information, agencies not scheduled for review until later years 
could begin to transition to more efficient methods. 

Figure: Growth in Use of Partly Electronic Collection Methods, Fiscal 
Years 2005-2009: 

[Refer to PDF for image: stacked line graph] 

Fiscal year: 2005  
Partly electronic collection methods: 1.6%; 
Nonelectronic collection methods: 98.4v 

Fiscal year: 2006  
Partly electronic collection methods: 7.4%; 
Nonelectronic collection methods: 92.6%. 

Fiscal year: 2007  
Partly electronic collection methods: 17.2%; 
Nonelectronic collection methods: 82.8%. 

Fiscal year: 2008  
Partly electronic collection methods: 34.4%; 
Nonelectronic collection methods: 65.6%. 

Fiscal year: 2009  
Partly electronic collection methods: 46.1%; 
Nonelectronic collection methods: 53.9%. 

Source: GAO analysis of FMS data. 

[End of figure] 

What GAO Recommends: 

GAO is making recommendations to the Secretary of the Treasury to 
facilitate transition to more cost-effective collection methods and to 
the Secretaries of the Interior and Commerce to consider all collection 
costs, including FMS’s, as available, in managing their programs. All 
three agencies generally agreed with GAO’s findings and 
recommendations. 

View GAO-10-11 or key components. For more information, contact Susan 
J. Irving at (202) 512-6806 or irvings@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Use of Electronic Collection Methods Has Increased: 

Movement to Electronic Collection Methods Can Reduce Costs and Mitigate 
Some Risks, but Agency-Specific Circumstances Have Affected Adoption of 
These Methods: 

FMS Is Working to Improve the Efficiency of Collections, but Reviews 
Exclude Important Considerations and Do Not Make Full Use of Available 
Incentives: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Minerals Management Service Collections: 

Appendix III: National Park Service Collections: 

Appendix IV: United States Geological Survey Collections: 

Appendix V: U.S. Patent and Trademark Office Collections: 

Appendix VI: National Oceanic and Atmospheric Administration 
Collections: 

Appendix VII: Comments from the Department of the Treasury's Financial 
Management Service: 

Appendix VIII: Comments from the Department of the Interior: 

Appendix IX: Comments from the Department of Commerce: 

Appendix X: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Federal Collection Methods: 

Table 2: Case-Study Agency Collections--Percent of Dollars Collected, 
by Collection Method, Fiscal Year 2008: 

Table 3: Collection Processing Times, by Collection Method: 

Figures: 

Figure 1: Collection Methods Flowchart: 

Figure 2: Growth in Use of Partly Electronic Collection Methods by 
Agencies other than IRS, Fiscal Years 2005-2009: 

Figure 3: MMS Collections by Type and Method: 

Figure 4: NPS Collections by Type and Method: 

Figure 5: USGS Collections by Type and Method: 

Figure 6: USPTO Collections by Type and Method: 

Figure 7: NOAA Collections by Type and Method: 

Abbreviations: 

ACHPAD: automated clearing house pre-authorized debits: 

CCC: Commodity Credit Corporation: 

ECP: electronic check processing: 

FMS: Financial Management Service: 

FRB: Federal Reserve Bank: 

IOAA: Independent Offices Appropriation Act of 1952: 

IRS: Internal Revenue Service: 

ITGA: International Treasury General Account: 

MMS: Minerals Management Service: 

NESDIS: National Environmental Satellite, Data, and Information 
Service: 

NMFS: National Marine Fisheries Service: 

NOAA: National Oceanic and Atmospheric Administration: 

NPS: National Park Service: 

OMB: Office of Management and Budget: 

PCC: paper check conversion: 

TGA: Treasury General Account: 

Treasury: Department of the Treasury: 

USGS: U.S. Geological Survey: 

USPTO: United States Patent and Trademark Office: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

November 20, 2009: 

The Honorable Richard J. Durbin: 
Chairman: 
Subcommittee on Financial Services and General Government: 
Committee on Appropriations: 
United States Senate: 

The Honorable José E. Serrano: 
Chairman: 
Subcommittee on Financial Services and General Government: 
Committee on Appropriations: 
House of Representatives: 

The Department of the Treasury's (Treasury) Financial Management 
Service (FMS) collected almost $509 billion in funds received by 
agencies other than the Internal Revenue Service (non-IRS collections) 
in fiscal year 2009. In prior work we found that the method used to 
collect payments can affect compliance with payment requirements as 
well as administrative costs for both agencies and fee payers.[Footnote 
1] Although certain FMS collections services can reduce government 
borrowing costs, reduce agency/payer administrative costs, and improve 
the security of collections, some agencies do not use these services 
for collections, relying instead on agency deposit of paper-based 
collections. As a result we reported there were delays between the time 
payments were received and the time they were deposited into the 
Treasury, thus increasing government borrowing costs.[Footnote 2] 

This report responds to your request that we examine opportunities to 
improve the efficiency of federal collections governmentwide. 
Specifically, we examined (1) the extent to which agencies other than 
IRS use collection methods in FMS's collections program, (2) how FMS 
and these agencies can maximize the benefits of and overcome any 
barriers to use of the various collection methods, and (3) issues FMS 
should consider as it implements its plans for improving the efficiency 
and security of these collections. As agreed with your offices, we did 
not review IRS collections. Also excluded from the review are 
collections of the Commodity Credit Corporation (CCC), a federal 
corporation within the U.S. Department of Agriculture.[Footnote 3] 

To assess the extent to which agencies use various collection methods, 
we analyzed FMS data on collections received by agencies other than IRS 
for fiscal years 2005 through 2009, by collection method.[Footnote 4] 
We reviewed FMS guidance and interviewed FMS officials to gather 
operational information on each collection method and understand why 
use of the various collection methods changed over time. To identify 
ways FMS and selected agencies can maximize the benefits of and 
overcome any barriers to the use of collection methods, we conducted 
case-study reviews of five agencies within two departments: the 
Minerals Management Service (MMS), the National Park Service (NPS), and 
the U.S. Geological Survey (USGS) in the Department of the Interior; 
and the United States Patent and Trademark Office (USPTO) and the 
National Oceanic and Atmospheric Administration (NOAA) in the 
Department of Commerce. The case-study agencies selected permitted us 
to cover the variety of collection methods and payer characteristics, 
however the findings cannot be generalized across the government. For 
each case-study agency, we analyzed collections data; observed agency 
collection processes; reviewed relevant legislation, regulations, 
agency guidance, and audit reports; and interviewed agency officials. 
We also reviewed FMS regulations and guidance, analyzed FMS data 
related to the costs and benefits of the various collection methods, 
and interviewed FMS officials. We also met with four payer groups 
identified by case-study agencies to gain an understanding of the 
effects of the shift to electronic collections on payers. These payer 
groups were trade organizations, one private-sector company, and 
representatives from state governments. To identify the issues FMS 
should consider in implementing its plans for improving the efficiency 
and security of collections, we reviewed legislation and FMS plans and 
agency agreements, applied relevant findings from our case studies, and 
interviewed FMS and case-study agency officials. We assessed the 
reliability of the data we used for this review and determined that 
they were sufficiently reliable for our purposes. Appendix I provides 
additional details about the scope and methodology of our review. 

We conducted this performance audit from October 2008 through November 
2009 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

As the government's financial manager, FMS establishes and implements 
collections policies, regulations, standards, and procedures for the 
federal government.[Footnote 5] Through its collections program, FMS 
also provides services to federal agencies to collect, deposit, and 
account for federal collections.[Footnote 6] Its collections program 
provides a means for individuals and organizations, including 
businesses, state and local governments, and nonprofit organizations, 
to remit funds such as taxes, duties, fees, sales, leases, and loan 
repayments to the government. FMS offers a range of fully electronic, 
partly electronic,[Footnote 7] and nonelectronic collection methods 
(see table 1 and figure 1). 

Table 1: Federal Collection Methods: 

Collection type: Fully electronic; 
Collection method: Wire transfers; 
Description: Fedwire: The payer initiates a real-time transfer of funds 
from its bank to the Treasury's account in the Federal Reserve Bank 
(FRB). 

Collection type: Fully electronic; 
Collection method: Automated clearing house (ACH) transfers[A]; 
Description: ACH Remittance Express: The payer electronically sends an 
ACH credit through its financial institution to a unique routing number 
at the FRB. 

Collection type: Fully electronic; 
Collection method: Automated clearing house (ACH) transfers[A]; 
Description: ACH pre-authorized debits (ACH PAD): An electronic 
transfer of funds from the payer's bank through the ACH network to the 
Treasury's account, authorized in advance by the payer. 

Collection type: Fully electronic; 
Collection method: Automated clearing house (ACH) transfers[A]; 
Description: Lockbox ACH: The payer sends payment information to a 
designated lockbox bank through its financial institution. The lockbox 
bank then deposits funds into the Treasury's account using the payer's 
financial information. 

Collection type: Fully electronic; 
Collection method: Credit or debit cards[A]; 
Description: Credit/debit card: Agencies collect credit or debit card 
payments through a Web interface, at the point of sale, or by mail, 
phone, or fax and transmit the data through a designated financial 
agent, which transfers the funds to the Treasury's account. 

Collection type: Partly electronic; 
Collection method: Electronic check processing; 
Description: Agency paper check conversion (PCC): Agencies collect 
paper checks over-the-counter at the point of sale or by mail, which 
are then converted on site to an electronic transaction or substitute 
check[B] and deposited into the Treasury's account. 

Collection type: Partly electronic; 
Collection method: Electronic check processing; 
Description: Lockbox[C] electronic check processing (ECP): Paper checks 
received through the general lockbox network are converted into an 
electronic transaction or substitute check for deposit into the 
Treasury's account. 

Collection type: Nonelectronic; 
Collection method: Paper checks and cash; 
Description: Federal Reserve Bank deposits: Checks and cash received by 
the agency are mailed or taken by courier or armored car to the nearest 
FRB for deposit to the Treasury's account. 

Collection type: Nonelectronic; 
Collection method: Paper checks and cash; 
Description: Treasury General Account (TGA) and International Treasury 
General Account (ITGA) deposits: Agencies collect cash and checks and 
deposit them at a local TGA bank (if domestic) or an ITGA bank (if 
international). The bank then transfers the funds to the Treasury's 
account. 

Collection type: Nonelectronic; 
Collection method: Paper checks and cash; 
Description: Lockbox[C] General: Paper checks are mailed to a post 
office box designated by the collecting agency and FMS, where they are 
picked up by a courier and delivered to a lockbox bank, and then 
processed and deposited into the Treasury's account. 

Source: GAO analysis of FMS information. 

[A] Pay.gov, FMS's Web-based, governmentwide collections portal, 
processes collections made by ACH transfer and credit card. 

[B] A substitute check is a paper copy of an image of the front and 
back of the original check. 

[C] FMS enters into lockbox service agreements with commercial banks to 
collect certain payments on behalf of federal agencies. FMS uses two 
lockbox networks: the general network for all payments except federal 
taxes and the Internal Revenue Service (IRS) lockbox network for 
federal tax payments. The banks establish post office boxes and 
electronic accounts to receive payments. 

[End of table] 

Figure 1: Collection Methods Flowchart: 

[Refer to PDF for image: illustration] 

Fully electronic: 

Wire transfers; 
ACH Transfers: through Pay.gov; 
ACH Transfers: Lockbox[A]; 
Credit or debit card payments: through Pay.gov; to Card processor; 
Credit or debit card payments: through Agency: to Card processor. 

All of the above flow to: 
Treasury accounts in Federal Reserve Banks. 

Partly electronic: 
Paper checks: through Agency: to electronic check processing; or; 
Paper checks: Mailed to post office box, then physically transported to 
lockbox bank: to electronic check processing. 

Flow is to: 
Treasury accounts in Federal Reserve Banks. 

Nonelectronic: 

Paper checks or cash: through Agency: Physically transported to Bank: 
TGA or ITGA bank[B]; or: 
Paper checks or cash: Mailed to post office box, then physically 
transported to lockbox bank. 

Flow is to: 
Treasury accounts in Federal Reserve Banks. 

Source: GAO analysis of FMS information. 

[A] A few lockbox accounts also accept and process payments by wire 
transfer, credit/debit cards, or both. 

[B] Some TGA and ITGA banks process checks using electronic check 
processing. 

[End of figure] 

The agencies we examined for our case studies use a variety of these 
collection methods (see table 2). 

Table 2: Case-Study Agency Collections--Percent of Dollars Collected, 
by Collection Method, Fiscal Year 2008: 

Agency: Minerals Management Service (MMS); 
Collections: Rents, royalties, lease sales, other cost recovery 
services and payments; 
Fully electronic: collection methods: Wire transfers: 93; 
Fully electronic: ACH transfers: 5; 
Fully electronic: Credit/debit cards: < 1; 
Partly electronic collection methods: Electronic check processing: 0; 
Nonelectronic collection methods: Paper checks and cash: 2. 

Agency: National Park Service (NPS); 
Collections: Recreation, special park use, concessions, and commercial 
use fees; 
other reimbursables; 
Fully electronic: collection methods: Wire transfers: 14; 
Fully electronic: ACH transfers: 13; 
Fully electronic: Credit/debit cards: 12; 
Partly electronic collection methods: Electronic check processing: 0; 
Nonelectronic collection methods: Paper checks and cash: 61. 

Agency: U.S. Geological Survey (USGS); 
Collections: Payments for cooperative water programs, reimbursable 
programs, product sales; 
Fully electronic: collection methods: Wire transfers: 2; 
Fully electronic: ACH transfers: 0; 
Fully electronic: Credit/debit cards: 5; 
Partly electronic collection methods: Electronic check processing: 73; 
Nonelectronic collection methods: Paper checks and cash: 21. 

Agency: U.S. Patent and Trademark Office (USPTO); 
Collections: Patent fees, trademark fees; 
Fully electronic: collection methods: Wire transfers: 28; 
Fully electronic: ACH transfers: 15; 
Fully electronic: Credit/debit cards: 24; 
Partly electronic collection methods: Electronic check processing: 9; 
Nonelectronic collection methods: Paper checks and cash: 24. 

Agency: National Oceanic and Atmospheric Administration (NOAA); 
Collections: Data sales, inspection fees, permit fees, civil monetary 
penalties, other reimbursables; 
Fully electronic: collection methods: Wire transfers: 8; 
Fully electronic: ACH transfers: 9; 
Fully electronic: Credit/debit cards: 4; 
Partly electronic collection methods: Electronic check processing: 45; 
Nonelectronic collection methods: Paper checks and cash: 35. 

Source: GAO analysis of FMS data and agency information. 

Note: Totals do not always sum to 100 because of rounding. 

[End of table] 

FMS manages the services through which all federal collections are 
deposited in the Treasury and strives to minimize the time between when 
funds are collected and when they are deposited in the Treasury. 
Treasury regulations state that when it is cost effective, practicable, 
and consistent with current statutory authority, electronic transfers 
of funds are the optimal method for federal collections, especially 
when fees are recurring or of large dollar amounts.[Footnote 8] 
Accordingly, FMS may require an agency wishing to use a collection 
method other than electronic transfer to provide a cost-benefit 
analysis to justify this selection. In past work, we highlighted the 
benefits of electronic collection processing. Specifically, we reported 
that electronic collections provide better accuracy, lower mailing and 
processing costs, and fewer delinquencies and defaults.[Footnote 9] 
When the Federal Reserve moved to electronic conversions of paper 
checks, work hours spent on check processing decreased by almost half 
and transportation costs associated with check processing decreased by 
about 11 percent. In recent years FMS has made it a priority to 
increase the use of electronic collection methods and reduce collection 
costs.[Footnote 10] FMS has begun an initiative, called the Holistic 
Approach, to further these goals. 

Selection of the best collection mechanism is a joint responsibility of 
agencies and FMS.[Footnote 11] Agencies have responsibility for working 
with FMS to conduct cash-management reviews, gathering volume and 
dollar data relative to the operation of the systems, and funding any 
implementation and operational costs above those normally funded by 
Treasury. FMS provides guidance to agencies in its Treasury Financial 
Manual regarding the selection and cost-effective use of collection 
mechanisms. Agencies must provide FMS with a recommended mechanism for 
any new or modified cash flows. FMS reviews the recommendations, 
approves a mechanism, and assists with implementation. 

FMS's oversight of federal agencies' cash-management activities 
includes review of collections.[Footnote 12] FMS uses findings from 
such reviews to develop initiatives to improve an agency's collections 
and set and monitor dates by which the agency must implement changes. 
Moreover, FMS may charge agencies that do not meet the implementation 
deadlines for the amount of interest savings that would have been 
realized by timely implementation.[Footnote 13] According to Treasury 
regulations, when funds are not collected electronically, agencies 
generally must deposit funds into the Treasury or a designated 
depositary on the day of receipt.[Footnote 14] 

FMS's collections program is funded in part by permanent and indefinite 
appropriations for all financial agent (banking) services required or 
directed by Treasury.[Footnote 15] In some cases federal agencies 
reimburse FMS for a part or all of these costs. For fiscal year 2009, 
FMS obligated $568 million for banking services, an 8 percent increase 
over the $528 million obligated in fiscal year 2008.[Footnote 16] 
Fiscal year 2009 reimbursements for these banking services were $92 
million. Such reimbursements are deposited in the Treasury's general 
fund. 

Use of Electronic Collection Methods Has Increased: 

Since 2005, agency use of collection methods has reflected FMS's 
increased focus on electronic payments. Fully electronic payments 
accounted for more than 80 percent of dollars collected by agencies 
other than IRS for fiscal years 2005 through 2009, with $441 billion of 
the almost $509 billion collected using fully electronic methods in 
fiscal year 2009. While the percentage of funds collected through 
nonelectronic methods in 2009 was low, it constituted over $36 billion. 
Nor does it represent a similarly low percentage of transactions. For 
example, in fiscal year 2008, MMS's Minerals Revenue Management program 
collected over $23 billion in federal rents and royalties from the 
public; while payments by check represented only 2 percent of the 
dollars collected, they represented 77 percent of the total number of 
its transactions. 

In fiscal year 2009, of the almost $509 billion in non-IRS collections, 
about $68 billion was collected as cash or checks and processed using 
either partly electronic or nonelectronic collection methods. As shown 
in figure 2, there was a significant shift from nonelectronic to partly 
electronic methods from 2005 to 2009. In 2005, partly electronic 
collection methods accounted for just under 2 percent of cash and check 
collections, but by 2009 this share had increased to over 46 percent. 
Given the significant process and cost differences between fully 
electronic and partly electronic collection methods, we distinguish 
between them in this analysis. 

Figure 2: Growth in Use of Partly Electronic Collection Methods by 
Agencies other than IRS, Fiscal Years 2005-2009: 

[Refer to PDF for image: stacked line graph] 

Fiscal year: 2005  
Partly electronic collection methods: 1.6%; 
Nonelectronic collection methods: 98.4v 

Fiscal year: 2006  
Partly electronic collection methods: 7.4%; 
Nonelectronic collection methods: 92.6%. 

Fiscal year: 2007  
Partly electronic collection methods: 17.2%; 
Nonelectronic collection methods: 82.8%. 

Fiscal year: 2008  
Partly electronic collection methods: 34.4%; 
Nonelectronic collection methods: 65.6%. 

Fiscal year: 2009  
Partly electronic collection methods: 46.1%; 
Nonelectronic collection methods: 53.9%. 

Source: GAO analysis of FMS data. 

Note: Consistent with FMS's data-collection methods, the chart 
represents dollars collected, not number of transactions. According to 
FMS officials, FMS does not have reliable data on the number of 
transactions for most collection methods but they plan to collect these 
data. 

The data do not contain any dollars collected through methods designed 
for the IRS to collect taxes. IRS collections may be included in other 
categories if the agency or taxpayer used nontax methods to collect or 
pay fees. The data may contain taxes that are not collected by the IRS, 
such as customs excise taxes. 

[End of figure] 

The growth in partly electronic payments largely represents a change in 
agency processes rather than in payer behavior: the shift is largely 
the result of a growth in electronic check processing capacity both at 
agencies and through lockbox banks. In fiscal year 2008 almost $24 
billion in collections settled as paper checks at lockbox banks, but in 
fiscal year 2009 less than $2.4 billion was settled this way.[Footnote 
17] Conversely, collections through electronic check processing were 
about $27 billion in fiscal year 2008, but were over $31 billion in 
fiscal year 2009. FMS attributes this growth to a large marketing 
effort and new electronic check processing locations (according to FMS 
officials, 209 new locations--185 agency PCC and 24 lockbox ECP 
locations--were added in fiscal year 2009). 

FMS plans to discontinue some current electronic collection methods and 
shift programs that use those methods to Pay.gov--a Web-based portal 
that processes collections made through ACH transfer and credit card-- 
which will consolidate and simplify the number of collection methods 
available through FMS. FMS officials told us that they expect ACH pre- 
authorized debits will be phased out and replaced by Pay.gov by the end 
of calendar year 2009. In addition, FMS plans to shift most of the 
existing 32 lockbox ACH accounts to Pay.gov or other electronic 
collection methods, leaving only 2 such accounts in existence at the 
end of calendar year 2010. There are also plans to shift certain 
collections from nonelectronic methods to Pay.gov; for example, MMS is 
currently shifting its rent collections from paper checks to Pay.gov 
and, according to MMS officials, will continue to expand its use of 
Pay.gov in 2010. 

Movement to Electronic Collection Methods Can Reduce Costs and Mitigate 
Some Risks, but Agency-Specific Circumstances Have Affected Adoption of 
These Methods: 

FMS, case-study agencies, and the payer groups we interviewed have 
identified a variety of cost savings stemming from the use of 
electronic collection methods. These savings stem from more efficient 
agency processing, expected lower future costs for system changes, the 
acceleration of deposits to the Treasury, and a lower administrative 
burden for payer groups. The shift to electronic methods has also 
mitigated some security and accuracy risks for agencies. Nevertheless, 
some organizations identified agency-specific circumstances that make 
full adoption of electronic collection methods less beneficial. These 
circumstances were determined by the characteristics of an agency's 
payer base, other agency considerations, and the initial system or 
equipment costs related to the transition. 

Electronic Collection Methods Have Reduced FMS's, Agencies', and 
Customers' Costs: 

Officials from all five case-study agencies cited a decrease in current 
or estimated future costs resulting from the use of electronic 
collection methods but none of the agencies could fully quantify these 
savings. 

* In some cases, agencies increased the efficiency of internal 
processing operations. For example, officials at USGS said their 2008 
move from nonelectronic check processing to partly-electronic paper 
check conversion increased process efficiency. Specifically, according 
to officials in one USGS office that underwent the transition,[Footnote 
18] the change reduced the time it takes staff to process checks, thus 
freeing up staff to undertake additional tasks. This office 
disseminates USGS products such as maps and books and processes checks, 
credit card payments, and small amounts of cash from its sales. Prior 
to the transition, the nonelectronic check process required manual 
preparation of the deposit and a staff member to take the deposit to 
the bank each day. The new partly electronic process permits a Web- 
based deposit process and reduces the need to physically go to the 
bank. 

* In another case, a decrease in agency processing costs has the 
potential to reduce the size of cost-recovery fees. A NOAA regional 
permit official said that an upcoming shift from using a lockbox bank 
to Pay.gov for its fee collections is expected to increase staff 
efficiency and reduce payment processing costs such as the office's 
mailing costs. If these cost savings are realized, the cost reductions 
may be passed along to the payers of the fee. 

* In addition, fully electronic collection methods may incorporate 
electronic submission of remittance data, enabling automatic transfers 
of payment and remittance data to the agency's accounting system. For 
example, to account for ACH transfers after funds are deposited in the 
Treasury, MMS prints out detailed payment information from FMS, matches 
payment information to the correct payer, and manually enters the 
detailed data into MMS's internal accounting system. MMS officials told 
us that they are planning to update their accounting software to make 
this process automatic. They also said they expect that the 
implementation of Pay.gov will be designed to automate this process and 
thus reduce costs. 

* In May 2008 USPTO shifted its credit card processing function to 
Pay.gov both to decrease current costs and avoid future system costs 
for the agency. Adopting Pay.gov enabled USPTO to discontinue the lease 
of a line to a credit card authorization provider, a monthly savings of 
about $1,000. Agency officials also said they expect that costs 
associated with future agency system changes stemming from a change in 
the FMS credit card processor will be eliminated because Pay.gov will 
manage the transition. Potential exists for similar savings at other 
agencies; according to officials at NPS and USGS, they also incurred 
costs for system and equipment changes that were required after FMS 
changed its credit card processor. 

Some payer groups also cited benefits of a shift towards electronic 
collection methods. Three of the four payer groups we spoke with 
reported that the increased use of electronic methods has improved 
efficiency and saved money for their organizations or members by 
reducing administrative time, costs, or both. For example, state 
government representatives agreed that for many organizations, paying 
by ACH transfer is preferred because paying by check is expensive in 
terms of the cost and time of printing, mailing, and reconciling 
payments. More specifically, a representative of the state of 
Mississippi said that the state requires all vendors, besides federal 
agencies, to accept payments from the state electronically. The 
specific challenges faced by these payers when using federal agency 
collection methods is discussed later in this report. 

As we have previously reported, the acceleration of deposits to the 
Treasury can reduce the amount Treasury needs to borrow each day to pay 
government obligations.[Footnote 19] According to FMS, moving to 
electronic check processing reduces processing time by 1 day on 
average, whether done at the agency or at a lockbox bank. These total 
times range from 1 day to 6 days depending on the collection method 
selected and whether mail time is included (see table 3). In the case 
of paper check conversion, this improvement brings check processing on 
par with some fully electronic collection methods such as ACH transfers 
and credit cards. 

Table 3: Collection Processing Times, by Collection Method: 

Collection type: Fully electronic; 
Collection method: Wire transfers; 
Description: Fedwire; 
Average total processing time (in days): 1; 
Average settlement time[A]: Varies. 

Collection type: Fully electronic; 
Collection method: Automated clearing house (ACH) transfers; 
Description: ACH Remittance Express; 
Average total processing time (in days): 2; 
Average settlement time[A]: Varies. 

Collection type: Fully electronic; 
Collection method: Automated clearing house (ACH) transfers; 
Description: ACH PAD; 
Average total processing time (in days): 2; 
Average settlement time[A]: Next day. 

Collection type: Fully electronic; 
Collection method: Automated clearing house (ACH) transfers; 
Description: Lockbox ACH; 
Average total processing time (in days): 2; 
Average settlement time[A]: Next day. 

Collection type: Fully electronic; 
Collection method: Automated clearing house (ACH) transfers; 
Description: Pay.gov ACH; 
Average total processing time (in days): 2; 
Average settlement time[A]: Next day. 

Collection type: Fully electronic; 
Collection method: Credit or debit cards [B]; 
Description: Credit/debit card; 
Average total processing time (in days): 2; 
Average settlement time[A]: Next day. 

Collection type: Partly electronic; 
Collection method: Electronic check processing; 
Description: Agency paper check conversion; 
Average total processing time (in days): 2; 
Average settlement time[A]: Next day. 

Collection type: Partly electronic; 
Collection method: Electronic check processing; 
Description: Lockbox electronic check processing; 
Average total processing time (in days): 5[C]; 
Average settlement time[A]: Next day. 

Collection type: Nonelectronic; 
Collection method: Paper checks and cash; 
Description: Lockbox General; 
Average total processing time (in days): 6[C]; 
Average settlement time[A]: Next day. 

Collection type: Nonelectronic; 
Collection method: Paper checks and cash; 
Description: Federal Reserve Bank deposits; 
Average total processing time (in days): 1 to 2 days; 
Average settlement time[A]: Checks--next day; cash--same day. 

Collection type: Nonelectronic; 
Collection method: Paper checks and cash; 
Description: Treasury General Account and International Treasury 
General Account deposits; 
Average total processing time (in days): 3 to 6 days; 
Average settlement time[A]: Next day. 

Source: GAO analysis of FMS information. 

[A] Settlement cut off times may vary. Later cut off times permit more 
collections to be processed in a given day. 

[B] Amounts collected by credit card may also be processed by Pay.gov. 

[C] Includes typical mailing time estimate of 3 days. 

[End of table] 

Case-Study Agencies Make Collection Decisions without Full Information: 

Although the shift to electronic collection methods has increased 
efficiencies and decreased costs, agencies are generally unable to 
consider the full range of the federal government's expenses-- 
specifically FMS's total collection costs--when analyzing program costs 
and setting fee rates. This is because FMS generally does not provide 
these cost data to agencies, although according to officials, it 
could.[Footnote 20] FMS officials stated that FMS does not track cost 
of collection information by agency, but instead by collection method 
and bank. FMS has this cost information and could provide it, but based 
on past practices, it generally has not. As we have previously 
reported, reliable information on the costs of federal programs and 
activities is crucial for effective management of government 
operations.[Footnote 21] Currently, agencies make decisions about 
collection methods without the benefit of this information. Moreover, 
agencies could determine whether such costs should be considered in the 
design and level of full-cost recovery fees. To the extent such cost 
data are provided, agencies that are authorized to charge full-cost 
recovery fees--for example, fees charged under the Independent Offices 
Appropriation Act of 1952 (IOAA)--could, in some cases, include FMS's 
cost of collections in their fee rates and deposit these funds into the 
Treasury.[Footnote 22] 

Electronic Collection Methods Mitigate Security Concerns and Risks of 
Inaccuracy, Potentially Decreasing Collection Losses: 

Officials from all five case-study agencies and FMS stated that use of 
electronic collection methods have reduced the risk of either security 
problems or processing errors. Four of the five case-study agencies 
stated that electronic collection methods alleviated security concerns 
for staff members, reduced the risk of theft, or both. 

* As noted above, prior to the move to paper check conversion, USGS 
staff drove deposits to a local bank, exposing staff to risk of theft 
or injury. USGS officials said that the move to paper check conversion 
reduced these safety concerns. Alternatively, some agencies reduced 
concerns about staff safety by making bank deposits by means of a 
courier service. However, using couriers poses other security risks and 
adds costs to the collections process.[Footnote 23] For example, MMS 
officials said that courier costs at its Denver office are 
approximately $80,000 a year for two daily mail deliveries and one 
daily bank deposit. 

* NPS guidance also deals with security concerns pertaining to cash 
collections and the use of personnel to collect fees. For example, this 
guidance notes that parks' implementation of a type of ACH transfer 
that is primarily used for commercial tour groups reduces the amount of 
cash handled by staff and therefore improves security.[Footnote 24] In 
addition, officials at the Rocky Mountain National Park said that 
permitting unattended entrance stations to accept only credit cards, 
rather than both cash and credit cards, reduced collection costs and 
made the machines less vulnerable to attempted theft. 

Officials from three of our case-study agencies stated that the 
electronic collection or provision of payment data has lowered the risk 
of processing errors, reducing repeated work and lost time and effort. 

* USGS staff said that using paper check conversion has reduced the 
errors in the process because the system confirms deposit totals before 
completing a deposit. 

* Similarly, MMS officials reported a decrease in administrative errors 
stemming from the use of Pay.gov for a selection of its fees. 

* USPTO's adoption of an automated method for uploading remittance 
information for organizations making multiple payments also reduced 
errors. In some cases, USPTO may receive several thousand patent 
renewals in one submission from a single company that manages these 
renewals for multiple customers. In the past, these renewals would be 
sent to a lockbox bank and remittance information would be entered 
manually. This new system allows maintenance fee payment information to 
be submitted on a single compact disc and the data file on the disc to 
be uploaded directly into USPTO's internal accounting system. 

Agency-Specific Circumstances Can Affect Adoption of Electronic 
Collection Methods: 

An agency's payer base characteristics and other issues can influence 
collection method selection, sometimes causing agencies to leave 
nonelectronic collection methods in place and incur costs associated 
with maintaining separate collection methods. In its work with 
agencies, FMS recognizes the importance of considering an agency's 
payer base and whether those payers are likely to accept electronic 
collection methods. All five of our case-study agencies stated that 
payer characteristics and customer needs affected the selection of 
collection methods. In some cases, customer preferences as well as 
customer access to banks and online banking systems have influenced the 
different payment methods that agencies offer. 

* MMS said that its customers, while typically large companies, also 
include smaller operations that may not be amenable to electronic 
collections. When MMS mandated electronic submission of royalty 
collections, it granted waivers for those that appealed the 
requirement--approximately 100 of the 2,100 entities for which it 
processes royalty revenues. Although a small percentage, such 
accommodation requires that the agency manage a waiver system and 
requires the maintenance of a nonelectronic or partly electronic 
collection method alongside the new fully electronic collection method. 
In the case of MMS, the agency maintained its nonelectronic check 
processing for collections other than royalties, so the nonelectronic 
processes were not solely maintained for those customers with waivers. 

* A representative of a commercial tour operator industry group stated 
that smaller operators in his membership would prefer the maintenance 
of a more flexible method of payment for NPS entrance fees than that 
preferred by larger operators. NPS is considering adopting Pay.gov to 
allow customers to use a Web portal to make online purchases. The tour 
representative recommended that NPS continue to accept credit cards 
from commercial operators at its entrances in order to accommodate 
smaller operators as the agency shifts to Pay.gov. While credit cards 
are an electronic collection method, the desire to maintain this 
alternative payment option in order to better serve its customers 
imposes costs on the agency, such as the purchase of necessary 
equipment.[Footnote 25] 

Other agency considerations also influence the selection and adoption 
of collection methods. MMS officials told us that they decided to 
pursue Pay.gov for MMS's rent collections rather than selecting a 
commercial lockbox because a lockbox service would not meet their 
internal process needs. Although the shift to Pay.gov is underway, 
officials acknowledge there will always be some paper check collections 
to manage. In another case, NPS officials told us that the services 
provided by those performing collection activities go beyond the 
collection itself. They explained that they do not wish to remove all 
representatives from entrance fee collection stations--even if it were 
possible--because fee collectors are often "ambassadors" for the park 
and provide an important public service. Nonetheless, it requires that 
NPS incur some level of labor costs related to collections. 

For two case-study agencies the setup costs or required system changes 
necessary to implement electronic collection methods affected the 
ability or the extent to which the agency or program office could adopt 
or maintain electronic collection methods. 

* In 2002 and 2003, one NOAA regional permit office used Pay.gov as a 
payment method. The office discontinued the use of Pay.gov because of 
changes to the office's database system and lack of information 
technology support required to establish the new system's connection to 
Pay.gov. Nonetheless, a current project aims to reestablish the link to 
Pay.gov. 

* NPS reports that at some remote park locations the telephone and 
Internet access necessary to support electronic collection methods may 
be difficult to establish. Even in less remote areas, geographic 
dispersion may create challenges, such as the need to maintain and 
purchase equipment for multiple collection or processing points within 
one park. For example, Rocky Mountain National Park, which covers 
265,800 acres and has four entrances, maintains two remittance offices 
to prepare collections for deposit because the road crossing the park 
also crosses the continental divide and is impassable during winter 
months. Therefore, collections cannot be transported from one side of 
the park to the other and must be prepared for deposit separately. 

Finally, meeting the varying system requirements for some electronic 
collection methods can also be a barrier for customer use. Officials 
from three state governments that submit payments to USGS told us that, 
while they prefer electronic collection methods such as ACH transfers, 
the differing technical requirements and data formats at each federal 
agency can make such transfers a burdensome, manual process. Our prior 
work has found a similar lack of standardization across federal grant- 
making agencies. For example, the use of multiple payment systems has 
resulted in an excessive administrative burden for grantees.[Footnote 
26] FMS officials stated that limited funding is often cited as a 
barrier to agency adoption of new collection methods. 

FMS Is Working to Improve the Efficiency of Collections, but Reviews 
Exclude Important Considerations and Do Not Make Full Use of Available 
Incentives: 

FMS Reviews of Agency Collections Exclude Important Considerations: 

As the financial manager and principal fiscal agent for the federal 
government, FMS is responsible for planning and managing federal 
collections and has oversight responsibilities to ensure that agencies 
are making adequate progress in improving their cash-management 
practices. Consistent with these responsibilities, FMS developed a 5- 
year "Holistic Approach" plan, which establishes a framework for 
increasing the use of electronic collection mechanisms governmentwide; 
streamlining the collections process; offering collection mechanisms 
that are easy to use, convenient, and secure; managing depositary 
services that banks provide to federal agencies; and providing timely 
collection of federal receipts.[Footnote 27] To implement this plan, 
FMS ranked agencies for review based largely on their dollar volume of 
collections using nonelectronic methods. It plans to review the 
collections of and draft Strategic Cash Management Agreements with 112 
agencies spread about evenly over fiscal years 2009 through 2013. 
[Footnote 28] During the development of the agreements, FMS reviews all 
agency collections, including those already using electronic methods, 
to see if a more efficient method could be adopted. According to FMS 
officials and as described above, the payer and type of collection are 
key factors in choosing a collection method. Each interagency Strategic 
Cash Management Agreement will outline the methods currently used by 
the agency for each of its collections; recommend electronic collection 
mechanisms; set conversion timelines, agencywide goals, and metrics; 
and estimate savings from conversion. The agreements commit both FMS 
and the agencies to implement improvements to agencies' overall cash-
management practices. 

As laid out in its Holistic Approach plan, FMS estimates savings of 
conversion from nonelectronic to electronic collection methods as part 
of each agency review. FMS estimates that average per transaction 
collection costs are $1.679 for nonelectronic methods and $0.897 for 
electronic methods.[Footnote 29] Using these figures, FMS estimates 
that shifting to electronic collections will save an average of $0.78 
per transaction.[Footnote 30] However, there are significant 
differences in cost per transaction between different electronic 
collection methods which may be obscured by using only these two broad 
categories to estimate savings. For example, FMS estimates that, on 
average, ACH transfers processed through Pay.gov cost $0.64 per 
transaction, credit card transactions cost $1.30 per transaction, and 
lockbox ECP costs $0.58 per transaction.[Footnote 31] 

Although the cost of using different collection methods also can vary 
by the dollar amount of the transaction, FMS officials said they do not 
use volume threshold guidelines when working with agencies to select 
payment methods. Specifically, credit card merchant fees are, in part, 
a percentage of the value of the transaction. Though it may be less 
costly to process a small collection by credit card than by check, the 
reverse may be the case for large-dollar-value collections. We recently 
reported that the average merchant discount rate FMS paid in fiscal 
year 2007 was 1.43 percent.[Footnote 32] In a hypothetical example 
using this rate, the total fees for a $100 transaction would be $1.43 
and the fees for a $10,000 transaction would be $143. FMS limits 
individual credit card transactions to under $100,000 in order to limit 
merchant fees. 

FMS's Holistic Approach plan does not provide for all available 
incentives to encourage agencies to increase the use of more cost 
effective collection methods. By using FMS services, agencies can 
reduce their own costs of collection. Specifically, as noted earlier, 
agencies that collect credit card payments through Pay.gov would be 
able to avoid the costs of future system changes because with Pay.gov 
those changes would be handled by FMS. The Holistic Approach plan 
includes a provision for an inefficiency charge of $1.00 per 
transaction for any collection not converted by the deadline as 
outlined in the agreement. Although FMS has the authority to assess 
inefficiency charges against agencies regardless of an agreement, 
according to FMS officials, the charge is only assessed on agencies 
that voluntarily sign an agreement and then only if the agency misses 
agreed-upon and likely flexible deadlines. Furthermore, FMS officials 
said they are not using the Holistic Approach to review whether 
agencies are paying for certain collection services as required. FMS 
guidance--Treasury Bulletin 94-07--requires that agencies reimburse FMS 
for ancillary services and for standard lockbox collection services 
unless lockbox processing provides a net financial benefit to the 
Treasury's general fund.[Footnote 33] In one case, we found that 
charges for a NOAA lockbox were initiated by FMS and then halted for an 
unknown reason. In the past, NOAA reimbursed FMS for services on one of 
its lockboxes. However, when the lockbox was moved to a different bank 
in 2005, the reimbursement charge was discontinued.[Footnote 34] FMS 
officials do not have any records of why they ceased to charge NOAA; 
NOAA officials were also not aware of the reason why the charges were 
discontinued. By not reviewing agency responsibility to pay for 
collection services, FMS does not make use of an available incentive to 
agencies to move to more efficient collection methods. FMS officials 
stated that as part of the review, FMS negotiates the collections 
proposals with the agency, but that agencies may have other, higher 
priorities than making the investments needed for a change. If FMS also 
reviewed whether the agency should reimburse FMS for the collection 
services and charged the agency based on the findings of that review, 
the agency would have a financial incentive to adopt the more cost- 
effective method. 

FMS Plan Does Not Include Strategy for Communicating and Incorporating 
Lessons Learned from Agency Reviews as It Proceeds with Expanded 
Implementation: 

The Holistic Approach plan does not include a strategy for 
communicating lessons-learned from earlier reviews to agencies. Without 
such information, agencies not scheduled for review until later 
years[Footnote 35] might not have an opportunity to correct common 
problems. As part of the reviews, FMS assesses whether the agencies use 
unauthorized or inefficient cash management practices. In its reviews 
to date, FMS found that two agencies were holding funds outside of TGA 
banks and is aware of some inefficient collection practices that do not 
rise to the level of being unauthorized cash-management practices. 
[Footnote 36] In our case-study reviews we also found examples of 
inefficient collection practices, including the following: 

* On a few occasions, USPTO accepted credit cards as payment for 
multiple, individual sale transactions processed on the same day to the 
same credit card account number. This resulted in the sum of the 
payments to the same credit card account number to be at or near the 
dollar limit for credit card transactions. Because credit card fees are 
based in part on a percentage of the dollar amount charged, the cost of 
processing large collections by credit card may be more than by other 
methods. 

* NOAA maintains some lockbox accounts with volumes below what FMS 
officials told us was their rule-of-thumb for lockbox services. FMS 
does not have an official volume threshold for lockboxes, but officials 
stated that processing checks through a lockbox might be a good choice 
for a program collecting a minimum of 1,000 checks and $1 million per 
month. Of the eight NOAA lockboxes,[Footnote 37] all had calendar year 
2008 collections volume that averaged less than 1,000 checks per month 
and only one processed over $1 million per month on average; one 
lockbox processed 208 checks totaling less than $5,000 that year. Check 
volume affects the per-transaction cost of lockbox services because 
some lockbox bank charges are fixed (e.g., monthly account maintenance 
charges). 

* As a standard practice for one NOAA regional permit office, payers 
mailed checks to the office and then NOAA mailed the checks to the 
lockbox bank for processing on a weekly basis. This practice delays 
deposit of the collections. 

Agencies not scheduled for review until later years also may lack 
information on how to overcome barriers to the use of electronic 
collection methods or invest in more cost-effective collection methods. 
Such barriers include agency regulations that define the methods an 
agency uses to make collections, and payers that are less amenable to 
electronic collection methods. With better information about the 
capabilities and benefits of the various collection methods, agencies 
could in turn communicate that information to their payer groups. 
According to payer groups we spoke with, their members would be more 
likely to adopt electronic collection methods if agencies encouraged 
them. According to FMS, existing agency collection contracts and 
systems can be a barrier to adoption of more efficient collection 
methods. 

Some FMS collections guidance is outdated, but the Holistic Approach 
plan does not include a strategy for updating guidance based on lessons-
learned from the agency reviews. The primary guidance to agencies on 
the various options for collection methods--FMS's Cash Management Made 
Easy--was last updated in April 2002 and includes outdated descriptions 
of some methods. FMS's guidance for the situations in which agencies 
must reimburse FMS for costs of lockbox services--Treasury Bulletin 94-
07--is, in some respects, also outdated.[Footnote 38] It bases the 
responsibility to pay for the costs of standard lockbox services on the 
net benefit to the Treasury's general account of accelerated deposits. 
However, since the time the bulletin was issued, electronic processing 
of checks has become an option for agencies. In some cases, this new 
option may be a more cost-effective choice. 

Conclusions: 

FMS has made important progress helping the federal government improve 
the efficiency and effectiveness of non-IRS collections; in fiscal year 
2009, almost 87 percent of these funds were collected using fully 
electronic methods. As work continues to overcome barriers to 
electronic collection methods, several benefits continue to accrue: the 
cost of government borrowing is decreased as the time to process 
collections is reduced; agencies, customers, and FMS may enjoy lower 
costs of collection; and security of collections and staff are 
improved. 

Reliable information on the costs of federal programs and activities is 
crucial for effective management of government operations. However, it 
can be difficult for agencies to effectively manage their programs or 
make informed choices among collection options because FMS generally 
does not provide agencies data or information on FMS's costs of 
collections for a given agency, program, or collection method. FMS has 
cost information by collection method but generally does not provide it 
to agencies. While FMS officials said that they could and have provided 
cost information upon request, we believe provision of such data should 
not be ad hoc. Rather, data should be distributed systematically to 
facilitate agency program management. The lack of information on FMS's 
costs of collections means that agencies do not have complete 
information for analysis of their fee structure and level. For some 
full-cost recovery fees this means that the federal government may be 
inappropriately foregoing revenues. 

FMS's ongoing initiative to analyze and review the collection activity 
in each agency through implementation of its Holistic Approach plan 
facilitates growth in the use of electronic collection methods. 
However, two aspects of the approach may lead to decisions that are not 
the most cost-effective. First, FMS groups all fully and partially 
electronic methods together when developing an estimate of the cost 
savings of shifts from nonelectronic to other collection methods. 
Second, FMS does not make use of all available financial incentives-- 
including enforcing its own guidance by requiring agencies to reimburse 
it for certain collection services. 

Finally, some inefficient agency collection practices may persist 
longer than necessary because FMS's Holistic Approach plan does not 
include either a strategy to communicate key lessons-learned from early 
agency reviews to other agencies whose reviews are scheduled for future 
years or a way to use the information to update FMS guidance to 
agencies. Interim updates of collections guidance and regulations could 
allow agencies to benefit from key lessons-learned during FMS reviews. 

Recommendations for Executive Action: 

We are making five recommendations in this report. 

To strengthen oversight of the costs of collecting federal fees and 
other receipts, we recommend that the Secretary of the Treasury direct 
the FMS Commissioner to take the following four actions: 

(1) Provide each agency with information on FMS's annual costs of 
processing related to that agency's collections by, for example, 
providing information on the agency's total collections, by collection 
method, and FMS's costs by collection method. 

(2) Revise FMS's Holistic Approach plan to assure that the reviews of 
agency collections will consider the differences in costs of the 
various electronic collection methods. 

(3) Enforce FMS guidance by: 

a. specifying criteria for determining whether FMS collection services 
are either ancillary or are lockbox services not providing a net 
benefit to the Treasury's general account and so should be reimbursed 
by the agency; and: 

b. using these criteria during Holistic Approach plan reviews to 
determine whether each agency should reimburse FMS for services and 
document that decision. 

(4) Establish a process for updating collections guidance and 
regulations based on key lessons-learned from its reviews and 
communicating that information to all agencies so that agencies whose 
review is scheduled for later years can begin to implement changes. 

We recommend that the Secretaries of the Interior and Commerce include 
FMS's costs of collection, as available, in analyzing MMS, NPS, USGS, 
USPTO, and NOAA programs and, as appropriate, the design and level of 
user fees. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Secretaries of the Treasury, 
the Interior, and Commerce for review. We received written comments 
from the Department of the Treasury's Financial Management Service, the 
Department of the Interior, and the Department of Commerce, which are 
reprinted in appendixes VII, VIII, and IX, respectively. In addition, 
Treasury provided technical comments, which we incorporated as 
appropriate. We also provided portions of the report to nonfederal 
stakeholders for their review and made technical corrections as 
appropriate. 

FMS agreed with our recommendations and stated that it will develop an 
action plan to address each recommendation. Initially, the draft's 
third recommendation said that, while implementing the Holistic 
Approach reviews, FMS should specify criteria for determining whether 
its collection services are ancillary and should therefore be 
reimbursed by the agency. FMS commented that it is working on 
establishing such criteria in an initiative separate from the Holistic 
Approach. In describing this initiative to us, FMS officials explained 
that by separating the two initiatives they expect to be able to review 
and update the policy on reimbursement more quickly. They expect to 
complete the review of the reimbursement policy by April 2010. The 
officials also noted that enforcement of the policy may need to be 
phased-in over time as agencies will need to ensure that their 
appropriations allow reimbursement to FMS for certain collection 
services. In response to these comments, we revised the recommendation 
to clarify that the reimbursement criteria need not be developed as 
part of the Holistic Approach plan, only that, to consistently enforce 
FMS policies, the criteria should be applied as part of the reviews. 

The Department of the Interior concurred with our findings and 
recommendation and stated that the report accurately depicts their 
efforts to implement electronic collection methods. 

The Department of Commerce also agreed with our recommendation and 
expressed its commitment to implementing the recommendation and to 
working with Treasury to improve the efficiency and effectiveness of 
collection processes. It also provided technical comments specifically 
with regard to the USPTO, which we incorporated as appropriate. 

We are sending copies of this report to the Honorable Timothy F. 
Geithner, Secretary of the Treasury; the Honorable Ken Salazar, 
Secretary of the Interior; and the Honorable Gary Locke, Secretary of 
Commerce. This report is also available at no charge on the GAO Web 
site at [hyperlink, http://www.gao.gov]. 

Should you or your staff have any questions about this report, please 
contact me on (202) 512-6806 or irvings@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made major contributions to 
this report are listed in Appendix X. 

Signed by: 

Susan J. Irving: 
Director for Federal Budget Analysis, Strategic Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

To analyze opportunities to improve the efficiency of federal 
collections governmentwide we examined (1) the extent to which agencies 
other than the Internal Revenue Service (IRS) use collection methods in 
the Financial Management Service's (FMS) collections program, (2) how 
FMS and these agencies can maximize the benefits of and overcome 
barriers to use of the various collection methods, and (3) issues FMS 
should consider as it implements its plans for improving the efficiency 
and security of these collections. 

To assess the extent to which agencies use various collection methods, 
we analyzed data on governmentwide collections by collection method 
from FMS's Total Collections Report for fiscal years 2005 through 2009. 
We worked with FMS to group collection methods consistently over time 
and to categorize them as fully electronic, partly electronic, and 
nonelectronic. In order to focus our analysis on nontax collections, we 
excluded collections FMS identified as IRS collections. However, 
according to FMS, some IRS collections may nonetheless be included in 
the remaining data. We also excluded collections of the Commodity 
Credit Corporation (CCC)--a federal corporation within the U.S. 
Department of Agriculture--because, according to FMS officials, CCC 
does not use the FMS collections program in the same way as other 
agencies. CCC uses its own network of banks to process collections. We 
reviewed FMS guidance and interviewed FMS officials to gather 
operational information on each collection method and understand why 
use of the various collection methods changed over time. 

To analyze ways FMS and selected agencies can maximize the benefits of 
and overcome barriers to the use of collection methods, we conducted 
case-study reviews of five agencies: the Minerals Management Service 
(MMS), the National Park Service (NPS), the United States Geological 
Survey (USGS), the United States Patent and Trademark Office (USPTO), 
and the National Oceanic and Atmospheric Administration (NOAA). We 
selected this set of case-study agencies to cover the use of the 
variety of collection methods, a variety of payer and payment 
characteristics, programs with significant collection totals, 
representation of at least two departments, potential for improved 
efficiency, and instances of a recent change in collection method. 
These case studies are not intended to be representative and therefore 
the information gleaned from them cannot be generalized across the 
government. We used fiscal year 2006 OMB data on fee collections and 
fiscal year 2008 FMS data on collections by method to identify the case-
study agencies. For each case-study agency, we analyzed collections 
data, interviewed agency officials, and reviewed relevant legislation, 
regulations, agency guidance, and audit reports. We performed site 
visits at NPS's Rocky Mountain National Park in Estes Park, Colorado, 
and USGS's Central Region Geospatial Information Office and MMS's 
Minerals Revenue Management office both in Denver, Colorado. At each 
site-visit location, we observed collection processes and interviewed 
agency officials. We also observed the lockbox process and interviewed 
bank officials at a U.S. Bank lockbox location in St. Louis, Missouri 
that provides lockbox services to NOAA and USPTO. We also interviewed 
representatives or members from four payer organizations--the American 
Petroleum Institute, the National Tour Association, Computer Packages 
Inc., and the National Association of State Auditors, Comptrollers and 
Treasurers--to gain an understanding of the effects of the shift to 
electronic collections on payers. We selected these organizations from 
stakeholder or payer organizations suggested by each case-study agency. 
We also reviewed FMS regulations and guidance, analyzed FMS data 
related to the costs and benefits of the various collection methods, 
and interviewed FMS officials. 

To identify the issues FMS should consider in implementing its plans 
for improving the efficiency and security of collections, we reviewed 
relevant legislation and FMS plans and agency agreements, applied 
relevant findings from our case studies, and interviewed FMS and case- 
study agency officials. 

We assessed the reliability of the data we used for this review and 
determined that it was sufficiently reliable for our purposes. We 
conducted this performance audit from October 2008 through November 
2009 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Minerals Management Service Collections: 

Agency Description: 

The Minerals Management Service (MMS), a bureau in the Department of 
the Interior, manages the nation's natural gas, oil, and other mineral 
resources on the outer continental shelf. The agency also collects, 
accounts for, and disburses more than $8 billion per year in revenues 
from federal offshore mineral leases and from onshore mineral leases on 
federal and Indian lands. 

Types of Collections: 

MMS's Minerals Revenue Management collects rents, royalties, and 
proceeds from lease sales by means of automated clearing house (ACH) 
transfers, wire transfers, and Federal Reserve Bank deposits. Although 
most of the payments MMS receives are transmitted electronically, as of 
October 2008 MMS still received nearly 50,000 checks per year. In 
fiscal year 2008, rents and royalties totaled $13.4 billion and lease 
sales totaled $10.2 billion. Royalty payments are typically high-dollar 
payments, while onshore and offshore rent payments can range from a few 
hundred to several thousand dollars. 

MMS's Offshore Energy and Minerals Management program also collects 
fees for cost-recovery services and payments, public-information 
service fees, and linear rental fees, totaling $11.2 million in fiscal 
year 2008. These collections are solely made through Pay.gov. MMS fee- 
paying customers are often large companies, but also include smaller 
organizations and individuals. 

Figure 3: MMS Collections by Type and Method: 

[Refer to PDF for image: pie-chart and accompanying data] 

Fully electric: 98%; 
Nonelectronic: 2%. 

Collection method: Fully electronic: Fedwire; 
Percent of total: 93; 
Fiscal year 2008 collection amount (dollars): $22,190,869,435. 

Collection method: Fully electronic: ACH remittance express; 
Percent of total: 5; 
Fiscal year 2008 collection amount (dollars): $1,205,198,009. 

Collection method: Fully electronic: Pay.gov ACH; 
Percent of total: 0; 
Fiscal year 2008 collection amount (dollars): $1,762,200. 

Collection method: Fully electronic: Lockbox ACH; 
Percent of total: 0; 
Fiscal year 2008 collection amount (dollars): $58,601,307. 

Collection method: Fully electronic: Credit/debit card; 
Percent of total: 0; 
Fiscal year 2008 collection amount (dollars): $9,472,223. 

Collection method: Nonelectronic: Federal Reserve Bank; 
Percent of total: 2; 
Fiscal year 2008 collection amount (dollars): $361,526,550. 

Collection method: Nonelectronic: TGA and ITGA; 
Percent of total: 0; 
Fiscal year 2008 collection amount (dollars): $360,820. 

Total: 
Percent of total: 100; 
Fiscal year 2008 collection amount (dollars): $23,827,790,543. 

Source: GAO analysis of FMS data. 

Note: Amounts collected by credit card may also be processed by 
Pay.gov. 

[End of figure] 

[End of section] 

Appendix III: National Park Service Collections: 

Agency Description: 

The National Park Service (NPS) is a bureau of the Department of the 
Interior. The national park system is comprised of 391 areas covering 
more than 84 million acres. These areas include national parks, 
monuments, battlefields, military parks, historical parks, historic 
sites, lakeshores, seashores, recreation areas, scenic rivers and 
trails, and the White House. 

Types of Collections: 

NPS collects funds from the public for recreation fees, special park 
use permits and fees, transportation fees, and other collections such 
as payments from concessionaires and commercial use fees and other 
forms of debt collection. Recreation fees include park entrance fees 
and special recreation permit fees. Recreation fees range from $5 to 
$25, or more for large group purchases. Special use fees are charged 
for the use of park lands or facilities for activities that occur in a 
park and provide benefit to an individual, group, or organization 
rather than the public at large. These administrative fees are intended 
to recover full costs and are calculated on a case-by-case basis, but 
range from $50 to $50,000. Transportation fees are collected to recover 
costs associated with an NPS-provided transportation system. 

In fiscal year 2008 NPS collected approximately $179 million in 
recreation fees through credit cards, automated clearing house (ACH) 
transfers, Federal Reserve Bank (FRB) deposits, Treasury General 
Account (TGA) deposits, and Pay.gov. Fiscal year 2008 special park use 
fees totaled $12,938,317 and were collected predominantly through TGA 
deposits and some credit card collections. Transportation fees totaled 
$13,883,451 in fiscal year 2008. NPS fee-paying customers include 
individuals, tour operators, concessionaires, and commercial operators. 

Figure 4: NPS Collections by Type and Method: 

[Refer to PDF for image: pie-chart and accompanying data] 

Fully electric: 39%; 
Nonelectronic: 61%. 

Collection method: Fully electronic: Fedwire; 
Percent of total: 14; 
Fiscal year 2008 collection amount (dollars): $53,336,733. 

Collection method: Fully electronic: ACH remittance express; 
Percent of total: 2; 
Fiscal year 2008 collection amount (dollars): $7,118,224. 

Collection method: Fully electronic: ACH PAD; 
Percent of total: 11; 
Fiscal year 2008 collection amount (dollars): $39,519,488. 

Collection method: Fully electronic: Pay.gov ACH; 
Percent of total: 0; 
Fiscal year 2008 collection amount (dollars): $80,297. 

Collection method: Fully electronic: Credit/debit card; 
Percent of total: 12; 
Fiscal year 2008 collection amount (dollars): $45,358,940. 

Collection method: Nonelectronic: Federal Reserve Bank; 
Percent of total: 14; 
Fiscal year 2008 collection amount (dollars): $52,280,800. 

Collection method: Nonelectronic: TGA and ITGA; 
Percent of total: 46; 
Fiscal year 2008 collection amount (dollars): $171,487,947. 

Total: 
Percent of total: 100; 
Fiscal year 2008 collection amount (dollars): $396,182,422. 

Source: GAO analysis of FMS data. 

Note: Amounts collected by credit card may also be processed by 
Pay.gov. 

[End of figure] 

[End of section] 

Appendix IV: United States Geological Survey Collections: 

Agency Description: 

The U.S. Geological Survey (USGS), a Department of the Interior agency, 
is the nation's largest water, earth, and biological science and 
civilian mapping agency. The USGS collects, monitors, analyzes, and 
provides scientific understanding about natural resource conditions, 
issues, and problems. 

Types of Collections: 

USGS collects funds for products sales (mostly relating to mapping 
products), cooperative water program agreements, and fully- 
reimbursable programs. Under the cooperative water program, cooperators 
partner with USGS and reimburse USGS for a portion of the costs of 
specific USGS data-collection activities, investigations, or studies. 
Payments under these agreements vary, with 40 percent of agreements 
yielding $25,000 per year or less and the largest agreement falling 
between $2 million and $3 million. These funds make up the majority of 
USGS collections and are mostly collected by lockbox electronic check 
processing (ECP). Other collections, including those for product sales 
and reimbursable agreements, are made via agency paper check conversion 
(PCC), Treasury General Account (TGA) deposits, International Treasury 
General Account (ITGA) deposits, credit cards, and wire transfers. 

Fiscal year 2008 collections totaled $217 million, with the majority of 
this amount ($215 million) stemming from reimbursables. Reimbursables 
include reimbursements from nonfederal sources such as states, tribes, 
and municipalities for cooperative efforts and proceeds from the sale 
of photographs and record copies; reimbursements for permits and 
licenses of the Federal Energy Regulatory Commission; and 
reimbursements from foreign countries and international organizations 
for technical assistance. 

Figure 5: USGS Collections by Type and Method: 

[Refer to PDF for image: pie-chart and accompanying data] 

Fully electric: 6%; 
Partly electronic: 73%; 
Nonelectronic: 21%. 

Collection method: Fully electronic: Fedwire; 
Percent of total: 2; 
Fiscal year 2008 collection amount (dollars): $3,733,919. 

Collection method: Fully electronic: Credit/debit card; 
Percent of total: 5; 
Fiscal year 2008 collection amount (dollars): $10,008,197. 

Collection method: Partially electronic: Agency PCC; 
Percent of total: 9; 
Fiscal year 2008 collection amount (dollars): $18,921044. 

Collection method: Partially electronic: Lockbox ECP; 
Percent of total: 64; 
Fiscal year 2008 collection amount (dollars): $138,515,030. 

Collection method: Nonelectronic: TGA and ITGA; 
Percent of total: 1; 
Fiscal year 2008 collection amount (dollars): $2,793,893. 

Collection method: Nonelectronic: Lockbox General; 
Percent of total: 20; 
Fiscal year 2008 collection amount (dollars): $43,195,362. 

Total: 
Percent of total: 100; 
Fiscal year 2008 collection amount (dollars): $217,167,445. 

Source: GAO analysis of FMS data. 

[End of figure] 

[End of section] 

Appendix V: U.S. Patent and Trademark Office Collections: 

Agency Description: 

The U.S. Patent and Trademark Office (USPTO) is an agency of the 
Department of Commerce. The agency's main functions are the examination 
and issuance of patents and the examination and registration of 
trademarks. 

Types of Collections: 

USPTO receives its funding through fees that are paid to obtain and 
renew patents and trademarks. Patent fees, for activities such as 
application filing, maintenance, and patent extensions, totaled $1.6 
billion in fiscal year 2008. These fees can range from $3 for a patent 
copy to over $8,000 for other services such as inter partes 
reexamination. Patent fee payments are accepted through credit cards, 
Pay.gov accepting credit cards or automated clearing house (ACH) 
transfers, lockbox electronic check processing (ECP) and Treasury 
General Account (TGA) deposits. Trademark fees, charged for services 
such as trademark processing and services, totaled $236 million in 
fiscal year 2008. Trademark fees range from $3 to $400 and are paid 
through credit cards, Pay.gov accepting credit cards or ACH transfers, 
and TGA deposits. USPTO also accepts replenishments to deposit accounts 
through wire transfers, lockbox ECP, and TGA deposits. Payments for 
some fees from foreign sources are sent through wire transfers. Payers 
for patent and trademark fees are individuals, attorneys, law firms, 
small businesses, nonprofits, and large corporations. Patent fees are 
also paid by annuity companies. 

Figure 6: USPTO Collections by Type and Method: 

[Refer to PDF for image: pie-chart and accompanying data] 

Fully electric: 67%; 
Partly electronic: 9%; 
Nonelectronic: 24%. 

Collection method: Fully electronic: Fedwire; 
Percent of total: 28; 
Fiscal year 2008 collection amount (dollars): $571,996,867. 

Collection method: Fully electronic: Pay.gov AHC; 
Percent of total: 15; 
Fiscal year 2008 collection amount (dollars): $299,738,355. 

Collection method: Fully electronic: Credit/debit card; 
Percent of total: 24; 
Fiscal year 2008 collection amount (dollars): $497,331,148. 

Collection method: Partially electronic: Lockbox ECP; 
Percent of total: 9; 
Fiscal year 2008 collection amount (dollars): $192,208,448. 

Collection method: Nonelectronic: TGA and ITGA; 
Percent of total: 16; 
Fiscal year 2008 collection amount (dollars): $336,842,585. 

Collection method: Nonelectronic: Lockbox General; 
Percent of total: 7; 
Fiscal year 2008 collection amount (dollars): $153,766,254. 

Total: 
Percent of total: 100; 
Fiscal year 2008 collection amount (dollars): $2,051,883,657. 

Source: GAO analysis of FMS data. 

Note: Amounts collected by credit card may also be processed by 
Pay.gov. FMS and agency accounting of deposits may differ due to 
deposits in transit. Collections totals include normal fee collections, 
as well as other collections for deposit accounts and amounts provided 
to the USPTO that are passed through from and to other entities. 

[End of figure] 

[End of section] 

Appendix VI: National Oceanic and Atmospheric Administration 
Collections: 

Agency Description: 

The National Oceanic and Atmospheric Administration (NOAA) is a science-
based federal agency within the Department of Commerce with regulatory, 
operational, and information-service responsibilities. NOAA's mission 
is to understand and predict changes in the earth's environment and to 
conserve, protect, and manage coastal, marine, and Great Lakes' 
resources to meet our nation's economic, social, and environmental 
needs. NOAA offices include the National Environmental Satellite, Data, 
and Information Service (NESDIS), the National Marine Fisheries Service 
(NMFS), the National Ocean Service, National Weather Service, the 
Office of Marine and Aviation Operations, the Office of Oceanic and 
Atmospheric Research, and the Office of Program Planning and 
Integration. 

Types of Collections: 

NOAA offices receive collections for various programs using a wide 
range of collection methods. In fiscal year 2008, NESDIS received $1.7 
million in revenue for its sales of data. These collections were made 
through a combination of lockbox electronic check processing (ECP), 
Pay.gov, lockbox general, and Treasury General Account (TGA) deposits. 
Pay.gov processed the largest amount of these collections at $1.2 
million. NMFS receives fees for a variety of permits, penalties, and 
inspections, totaling over $48 million in fiscal year 2008. Seafood 
inspection fees, for example, averaged over $23,000 per fee collected 
and were collected by means of wire transfer, Federal Reserve Bank 
deposits, lockbox ECP, Pay.gov, lockbox general, and TGA deposits. 
Other NMFS collections averaged from $26 for tuna permits to over 
$6,000 for civil monetary penalties. Other NOAA collections include 
payments to the Damage Assessment and Restoration Revolving Fund, loan 
and buy back payments, and other reimbursables. Payer groups for NOAA 
fees vary, but include private and corporate customers for NESDIS data 
sales as well as individual fishermen and fishing companies for NMFS 
permit fees. 

Figure 7: NOAA Collections by Type and Method: 

[Refer to PDF for image: pie-chart and accompanying data] 

Fully electric: 20%; 
Partly electronic: 45%; 
Nonelectronic: 35%. 

Collection method: Fully electronic: Fedwire; 
Percent of total: 8; 
Fiscal year 2008 collection amount (dollars): $10,030,891. 

Collection method: Fully electronic: Pay.gov AHC; 
Percent of total: 9; 
Fiscal year 2008 collection amount (dollars): $10,914,559. 

Collection method: Fully electronic: Credit/debit card; 
Percent of total: 4; 
Fiscal year 2008 collection amount (dollars): $5,113,032. 

Collection method: Partially electronic: Agency PCC; 
Percent of total: 1; 
Fiscal year 2008 collection amount (dollars): $783,727. 

Collection method: Partially electronic: Lockbox ECP; 
Percent of total: 44; 
Fiscal year 2008 collection amount (dollars): $55,821,557. 

Collection method: Nonelectronic: Federal Reserve Bank; 
Percent of total: 1; 
Fiscal year 2008 collection amount (dollars): $1,275,595. 

Collection method: Nonelectronic: TGA and ITGA; 
Percent of total: 28; 
Fiscal year 2008 collection amount (dollars): $35,173,788. 

Collection method: Nonelectronic: Lockbox General; 
Percent of total: 6; 
Fiscal year 2008 collection amount (dollars): $8,192,041. 

Total: 
Percent of total: 100; 
Fiscal year 2008 collection amount (dollars): $127,305,190. 

Source: GAO analysis of FMS data. 

Note: Amounts collected by credit card may also be processed by 
Pay.gov. 

[End of figure] 

[End of section] 

Appendix VII: Comments from the Department of the Treasury's Financial 
Management Service: 

Department Of The Treasury: 
Financial Management Service: 
Washington, D.C. 20227: 

October 23, 2009: 

Ms. Susan Irving: 
Director of Strategic Issues: 
US Government Accountability Office: 
441 G Street, NW: 
Room 2908: 
Washington, DC 20548: 

Dear Ms. Irving: 

Thank you for the opportunity to review and comment on the November 
2009 draft report entitled "Budget Issues: Electronic Processing of Non-
IRS Collections Has Increased but Better Understanding of Cost 
Structure is Needed (GA0-10-11)." 

FMS agrees with the four Recommendations for Executive Action and will 
develop a plan of action to address each recommendation. 

Recommendation number three specifies establishing criteria for 
determining whether FMS collection services are ancillary and should be 
reimbursed by the agency while implementing the Holistic Approach 
reviews. FMS will implement actions to address this recommendation; 
however, we are working on this effort as a separate initiative from 
the Holistic Approach. 

If you have any questions, please feel free to call me on (202) 874-
7000 or Sheryl Morrow on (202) 874-6847. 

Sincerely, 

Signed by: 

David A. Lebryk: 

[End of section] 

Appendix VIII: Comments from the Department of the Interior: 

United States Department of the Interior: 
Office Of The Secretary: 
Washington, DC 20240: 

October 23, 2009: 

Ms. Susan J. Irving: 
Director, Federal Budget Analysis, Strategic Issues: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Ms. Irving: 
Thank you for providing the Department of the Interior the opportunity 
to review and comment on the draft Government Accountability Office 
(GAO) Report - Budget Issues: Electronic Processing of Non-IRS 
Collections Has Increased but Better Understanding of Cost Structure is 
Needed, Report No. GAO-10-11. 

The leadership in the Department of the Interior and its bureaus has 
actively promoted the benefits of adopting the electronic collection 
methods offered by Treasury's Financial Management Service (FMS). We 
find that the GAO's draft report accurately depicts our efforts to 
implement these collection methods. 

We concur with GAO's finding and recommendation. As the cost of FMS' 
various collection methods are made available, they will be taken into 
consideration in determining which electronic collection methods to 
implement. 

The Department appreciates the opportunity to participate in GAO's 
review of FMS electronic processing of collections. We hope these 
comments will assist you in preparing the final report. If you have any 
questions, or need additional information, please contact Ms. Karen 
Baker at (703)648-7261. 

Sincerely, 

Signed by: 
Rhea Suh: 
Assistant Secretary for Policy, Management and Budget: 

[End of section] 

Appendix IX: Comments from the Department of Commerce: 

United States Department Of Commerce: 
The Secretary of Commerce: 
Washington, D.C. 20230: 
	
October 27, 2009: 

Ms. Carol Henn: 
Assistant Director, Strategic Issues: 
Government Accountability Office: 
441 G Street, N.W., Room 2440: 
Washington, DC 20548: 

Dear Ms. Henn: 

Thank you for the opportunity to review and provide comments for your 
Government-wide assessment of electronic user fee collection methods. 
The Department of Commerce appreciates the Government Accountability 
Office's (GAO) recommendations concerning agencies' adoption of 
electronic collection methods for Federal fees, and we look forward to 
working with the Department of the Treasury's implementation of a plan 
to improve the efficiency and effectiveness of Federal collections that 
are non-Internal Revenue Service. Our efforts are meant to assist in 
identifying the electronic collections costs for Federal agencies and 
making a determination as to whether these agencies should reimburse 
the Financial Management Service (FMS) for the specific electronic 
services that they provide. Below you will find the Department of 
Commerce's comments on the draft report: 

GAO Recommendation: We recommend that the Secretaries of the Interior 
and Commerce include FMS costs of collection, as available, in 
analyzing MMS, NPS, USGS, USPTO and NOAA programs and, as appropriate, 
the design and level of user fees. 

The following comments are provided specifically with regard to the 
United States Patent and Trademark Office (USPTO): The USPTO agrees 
with the GAO recommendation. If the USPTO is granted fee-setting 
authority for all fees, the available costs of collection in 
calculating the user fee amounts to recover costs of the services would 
be included. Additionally, the following changes in terminology are 
recommended, also regarding the USPTO: 

1. Page 11: change the phrase "collect as cash or checks..." to 
"collected as cash or checks...." 

2. Page 26: change the first bullet that begins, "On a few occasions, 
USPTO accepted..." to read, "On a few occasions, USPTO accepted credit 
cards as payment for multiple individual sale transactions processed on 
the same day to the same credit card account number, which resulted in 
the sum of the payments to the same credit card account number to be at 
or near the dollar limit for credit card transactions." 

3. Page 40, paragraph 3, line 4: change the sentence that begins with 
"USPTO also accepts replenishments..." to read, "USPTO also accepts 
replenishments to deposit accounts via wire transfers, Lockbox ECP, and 
TGA deposits." 

Again, I thank the Government Accountability Office for the opportunity 
to comment on the report. Every effort will be made to meet the 
recommendations in a diligent manner, and we will gratefully accept 
suggestions as we move forward to ensure that the USPTO fee collection 
process is an effective system that will enable us to attain the goals 
of the Department of Commerce. 

Sincerely, 

Signed by: 

Gary Locke: 

[End of section] 

Appendix X: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Susan J. Irving, (202) 512-6806 or irvings@gao.gov: 

Staff Acknowledgments: 

In addition to the individual listed above, Carol Henn, Assistant 
Director; Mallory Bulman; Susan Etzel; Katherine Hamer; and Elizabeth 
Hosler made significant contributions to this report. Charles Fox, Cody 
Goebel, Christine Houle, Paul Kinney, Felicia Lopez, Julie Matta, Anu 
Mittal, Donna Miller, Robin Nazzaro, Jacqueline M. Nowicki, Melanie 
Papasian, Sheila Rajabiun, Thomas Short, and Jay Smale also made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] See GAO, Federal User Fees: A Design Guide, [hyperlink, 
http://www.gao.gov/products/GAO-08-386SP] (Washington, D.C.: May 29, 
2008). 

[2] See GAO, Federal User Fees: Additional Analyses and Timely Reviews 
Could Improve Immigration and Naturalization User Fee Design and USCIS 
Operations, GAO-09-180 (Washington, D.C.: Jan. 23, 2009). 

[3] According to FMS officials, CCC does not use the FMS collections 
program in the same way as other agencies. CCC uses its own network of 
banks to process collections (generally loan repayments), which totaled 
over $4 billion in fiscal year 2009. For the purposes of this report, 
non-IRS collections also exclude CCC collections. 

[4] The almost $509 billion of non-IRS collections was about 18 percent 
of the $2.9 trillion collected through FMS's collections program in 
fiscal year 2009. 

[5] The Secretary of the Treasury has authority to designate fiscal 
agents and depositaries of the U.S. government and to promulgate 
regulations implementing that authority. See 12 U.S.C. § 90. FMS 
implements Treasury regulations pertaining to the designation of such 
fiscal agents and depositaries. See 31 C.F.R. Pt. 202. 

[6] The FMS collections program is a centralized, consolidated 
governmentwide service with one national infrastructure operated by a 
network of commercial financial institutions and Federal Reserve Banks 
designated by FMS. 

[7] FMS tracks collections in two categories: (1) electronic methods 
and (2) nonelectronic methods. 

[8] 31 C.F.R. § 206.4(a). 

[9] GAO, Tax Administration: Increasing EFT Usage for Installment 
Agreements Could Benefit IRS, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-98-112] (Washington, D.C.: June 10, 
1998). Specific to governmentwide efforts to transition to electronic 
conversions of paper checks, we reported that the efforts had not yet 
resulted in economic efficiencies, but that officials expected greater 
efficiencies in the future. See GAO, Check 21 Act: Most Consumers Have 
Accepted and Banks Are Progressing Toward Full Adoption of Check 
Truncation, [hyperlink, http://www.gao.gov/products/GAO-09-8] 
(Washington, D.C.: Oct. 28, 2008). 

[10] Treasury's fiscal year 2009 budget justification outlines several 
performance goals for the collections program, such as the unit cost to 
process a collection transaction and the percent of the dollar amount 
of receipts collected electronically. These goals were reiterated in 
Treasury's fiscal year 2010 budget justification. 

[11] 31 C.F.R. § 206.4(c). 

[12] 31 C.F.R. § 206.6 (d); 1 TFM 6-8075.30. 

[13] Any noncompliance charges are required by law to be deposited into 
the Cash Management Improvement Fund and are available to develop 
systems for the collection and timely deposit of federal funds. 31 
U.S.C. § 3720(a). According to FMS officials, to date Treasury has not 
imposed any such charges. 

[14] 31 C.F.R. § 206.5. Under federal law, federal officials in custody 
of public money must deposit it no later than the third day after 
receiving the money. 31 U.S.C. § 3302(c)(1). However, the Secretary of 
the Treasury is authorized by law to prescribe by regulation a 
different time frame than the one established by statute. 31 U.S.C. § 
3302(c)(2). 

[15] 12 U.S.C. § 391a and 12 U.S.C. § 5018, note. Section 218 of the 
Transportation, Treasury, and Independent Agencies Appropriation Act, 
2004, Pub. L. No. 108-199, Div. F, 118 Stat. 279, 321 (Jan. 23, 2004), 
established a permanent, indefinite appropriation for Treasury to 
reimburse financial institutions for depository and financial services. 
Before 2004, Treasury reimbursed banks for these services with 
compensating balances--noninterest-bearing balances deposited in banks 
to compensate them for collecting tax and nontax receipts. See GAO, 
Debt Management: Backup Funding Options Would Enhance Treasury's 
Resilience to a Financial Market Disruption, GAO-06-1007 (Washington 
D.C.: Sept. 26, 2006). 

[16] According to FMS, the increase was primarily related to lockbox 
collection services for passport and immigration programs as well as 
implementation of an enterprise architecture. 

[17] According to FMS, as of August 2009, 99 percent of checks and 
dollars collected through lockbox banks are settled using electronic 
check processing. According to FMS officials, a few lockbox accounts 
have not converted to ECP either because the collection will soon move 
to a different collection method and the lockbox contract will end or 
because some aspect of the collection makes conversion to ECP 
exceptionally complicated. 

[18] USGS's Central Region Geospatial Information Office in Denver, 
Colorado. 

[19] See GAO, IRS Lockbox Banks: More Effective Oversight, Stronger 
Controls, and Further Study of Costs and Benefits Are Needed, 
[hyperlink, http://www.gao.gov/products/GAO-03-299] (Washington, D.C.: 
Jan. 15, 2003). 

[20] FMS officials told us that they have provided collection cost 
information upon an agency's request. 

[21] As discussed in Statement of Federal Financial Accounting 
Standards No. 4, Managerial Cost Accounting Concepts and Standards for 
the Federal Government (July 31, 1995). See GAO-08-386SP. 

[22] Whether an agency can recover certain costs will be limited by the 
statute providing authority to charge a particular fee and the 
application of federal case law regarding the proper scope of fee- 
setting authority. For a discussion on the legal parameters of setting 
fees and other user charges, see GAO, Principles of Federal 
Appropriations Law, Vol. III, 3rd ed., Ch. 12D. Office of Management 
and Budget (OMB) Circular No. A-25 specifies that "full cost" includes 
all direct and indirect costs to any part of the federal government 
(such as collection costs). User fees may be assessed under specific 
statutory authority or under the broad authority of the IOAA, 31 U.S.C. 
§ 9701. OMB Circular No. A-25 provides guidance regarding assessments 
of user charges not only under IOAA, but also under other more specific 
fee statutes to the extent permitted by law--that is, the provisions of 
a more specific user fee statute take precedence over the circular's 
guidance, and indeed over the more general provisions of IOAA itself 
(see GAO, Federal User Fees: Substantive Reviews Needed to Align Port- 
Related Fees with the Programs They Support, GAO-08-321 (Washington, 
D.C.: Feb. 22, 2008). 

[23] Recently we reported instances of couriers not properly 
safeguarding IRS receipts in transit to depositary institutions. See 
GAO, Management Report: Improvements Are Needed to Enhance IRS's 
Internal Controls and Operating Effectiveness, [hyperlink, 
http://www.gao.gov/products/GAO-09-513R] (Washington, D.C.: June 24, 
2009). 

[24] NPS recently replaced this type of ACH transfer with transfers 
through Pay.gov. 

[25] In all of the case studies done for this engagement, we found no 
evidence that the cost associated with maintaining separate collection 
methods eliminated the net benefit of even a partial move to electronic 
collection methods. 

[26] See GAO, Grants Management: Grantees' Concerns with Efforts to 
Streamline and Simplify Processes, [hyperlink, 
http://www.gao.gov/products/GAO-06-566] (Washington, D.C.: July 28, 
2006). 

[27] For prior work related to FMS efforts to increase the use of 
electronic collections and payments, see GAO, Credit and Debit Cards: 
Federal Entities Are Taking Actions to Limit Their Interchange Fees, 
but Additional Revenue Collection Cost Savings May Exist, [hyperlink, 
http://www.gao.gov/products/GAO-08-558] (Washington, D.C.: May 15, 
2008) and GAO, Electronic Payments: Many Programs Electronically 
Disburse Federal Benefits, and More Outreach Could Increase Use, 
[hyperlink, http://www.gao.gov/products/GAO-08-645] (Washington, D.C.: 
June 23, 2008). 

[28] As of September 30, 2009, FMS had signed agreements with 10 
agencies and draft agreements were under review by an additional 6 
agencies. 

[29] FMS groups partly electronic transactions--electronic check 
processing--with other electronic methods. 

[30] FMS's estimates include only costs borne by FMS, not any potential 
savings realized by federal agencies. 

[31] The average cost of lockbox ECP processing reflects costs of both 
electronic and paper services provided by the banks. 

[32] The type of card, the method in which it is accepted, and other 
factors affect the rate charged for any particular transaction. See GAO-
08-558. 

[33] Examples of ancillary services are special handling of remittances 
including notation, date stamping, document matching, assembly, and 
stapling as well as special or detailed sorting. Reimbursements to the 
Treasury for ancillary services may be authorized under The Economy Act 
(31 U.S.C. § 1535) or 31 U.S.C. § 327. 31 U.S.C. § 327 authorizes 
Treasury to be reimbursed or advanced costs for services for which the 
Treasury does not receive an appropriation. 

[34] The current lockbox agreement states that NOAA will be responsible 
for paying the costs of the lockbox account. 

[35] FMS plans to review the collections of approximately 22 agencies 
per year in fiscal years 2009 through 2013. 

[36] FMS officials stated that they work with agencies to immediately 
eliminate unauthorized practices and negotiate with agencies to change 
inefficient practices when developing Strategic Cash Management 
Agreements. 

[37] NOAA maintains nine lockboxes, but the collections for two of the 
lockboxes are processed together. 

[38] In commenting on a draft of this report, FMS said that it was in 
the process of rewriting the Cash Management Made Easy guidance and 
updating Treasury Bulletin 94-07. According to FMS officials the 
updated guidance will set criteria for determining what FMS collection 
services are ancillary and should be reimbursed by agencies. 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 
[hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 
information. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: