Recommendation: FERC should provide standard language and procedures to its staff on how to record information collected during inspections, including how and where to record information about safety deficiencies, in order to facilitate analysis of safety deficiencies across FERC's portfolio of regulated dams. (Recommendation 1)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: In February 2020, GAO confirmed that FERC had developed new standard operating procedures related for tracking deficiencies and follow-up items arising from dam safety inspections and other dam safety reviews. In addition, FERC told GAO that they plan to update their tracking system beginning in fiscal year 2021, which will facilitate the complete recording and subsequent analysis of safety deficiencies from inspections across FERC's portfolio of regulated dams. GAO will continue to monitor FERC's efforts to implement this recommendation.

Recommendation: FERC should use information from its inspections to assess safety risks across its portfolio of regulated dams to identify and prioritize safety risks at a national level. (Recommendation 2)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: In January 2019, FERC told GAO that it had begun developing a screening-level risk-assessment program to assess safety risks across the inventory of regulated dams and to help guide safety decisions. In February 2020, GAO confirmed that FERC had completed this screening-level risk assessment, and conducted some preliminary analysis of the results. In addition, FERC told GAO that the results of the screening level risk analyses will be used to revise the potential timing, frequency, and technical disciplines represented on dam safety inspections; to confirm or revise the urgency of existing and potential new follow up dam safety actions; and to identify previously unrecognized dam safety concerns and issues; to identify new dam safety priorities. GAO will continue to monitor FERC's efforts to implement this program.

Recommendation: The Commissioner of Internal Revenue should ensure that the Deputy Commissioner for Services and Enforcement develops and documents improved controls for the validity, completeness, and accuracy of data on FBAR exams and enforcement actions. (Recommendation 2)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In a letter dated October 15, 2018, IRS's Deputy Commissioner for Services and Enforcement stated that IRS is in the process of designing a new FBAR database solution using the FISMA-compliant Entellitrak case management system. The solution will include data fields and systemic controls to ensure the accurate recording and reporting of FBAR case information essential to the whistleblower program. As of December 2019, IRS officials said they are on track to complete this action by June 2020. When we can confirm that IRS has completed this action, we will provide updated information.

Recommendation: The Director of OMB should direct the leaders of the Leveraging Data as a Strategic Asset CAP Goal to ensure future updates to the action plan, and the resulting federal data strategy, provide additional details on improving the use of data, including performance information, more extensively within federal agencies. The action plan should identify performance goals; contributing agencies, organizations, programs, and other activities; those responsible for leading implementation within these contributors; planned actions; time frames; and means to assess progress. (Recommendation 1)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: As of October 2020, the Office of Management and Budget (OMB), and contributors to the Leveraging Data as a Strategic Asset cross-agency priority (CAP) goal, have taken some actions to address this recommendation. For example, in May 2019 they released a set of recommended practices designed to support agency implementation of the federal data strategy. In particular, several of these practices relate to data-driven decision making, encouraging agencies to "champion data use," "use data to guide decision making," and "use data to increase accountability." However, as of September 2020, the action plans for the implementation of the federal data strategy, and the overall CAP goal, did not include all of the required information. For example, they did not include a means to assess progress related to efforts to improve data-driven decision making in the federal government. We will continue to monitor OMB's actions related to implementing this recommendation.

Recommendation: The Director of OMB, in coordination with the PIC, should prioritize efforts to identify and share among agencies proven practices for increasing, and challenges that hamper, the use of performance information in decision making more extensively within agencies. At a minimum, this effort should involve the agencies that our survey suggests may offer such insights. (Recommendation 2)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: As of October 2020, the Office of Management and Budget (OMB) and the Performance Improvement Council (PIC) have taken some actions towards addressing this recommendation. For example, in 2018 and 2019, the PIC hosted a series of workshops focused on relevant topics, such as how agency staff can develop performance measures and analyze data, and how data-driven reviews are used across the federal government. However, as of October 2020, they had not yet undertaken efforts to directly address the recommendation. They have not engaged the agencies highlighted by our survey results to identify proven practices that would increase, or challenges that are hampering, data-driven decision making within agencies. We will continue to monitor actions related to implementing this recommendation.

Recommendation: The Director of OMB should ensure the consistent application of the requirement for respondent time costs, including clarifying instructions for when and how to include fringe benefits. (Recommendation 1)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: In April 2019, we requested information from OMB on the agency's implementation of our recommendation but as of May 2019 have not received any status updates. We will continue to monitor OMB's efforts to address our recommendation.

Recommendation: The Director of OMB should review the policies, procedures, and related control activities to ensure that the agency's Paperwork Reduction Act review process is operating effectively. (Recommendation 2)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: In April 2019, we requested information from OMB on the agency's implementation of our recommendation but as of May 2019 have not received any status updates. We will continue to monitor OMB's efforts to address our recommendation.

Recommendation: The Secretary of Agriculture should review the policies, procedures, and related control activities to ensure that the agency's Paperwork Reduction Act review process is operating effectively. (Recommendation 3)

Agency: Department of Agriculture
Status: Open

Comments: In June 2019, USDA provided an update on efforts to review its Paperwork Reduction Act (PRA) policies and procedures. To ensure that its PRA process is operating effectively, USDA reviewed and updated its internal guidance on preparing information collection request supporting statements, including sections regarding the calculation of respondent burden hour and cost estimates. This updated guidance encourages consultation with potential respondents to help develop these burden estimates. A new PRA consultation checklist directs agency officials to seek input from individuals outside of USDA regarding the agency's burden estimates for an information collection request, including the validity of the methodology and assumptions used in the estimate calculations. The updated guidance specifies that fringe benefits, such as paid leave, insurance, and retirement contributions, should be included in the wage rates used for respondent burden cost estimates. It also clarifies when roundtrip travel time and costs should be included in burden estimates. According to USDA officials, the agency meets with PRA Coordinators to ensure compliance with the updated guidance. These are positive steps toward improving USDA's burden calculation process. However, USDA has not yet provided evidence of a review or revision of its information collection request review process. A review or revision of this process could help USDA better identify errors in burden estimate calculations prior to the final information collection request being sent to OMB and released to the public.

Recommendation: The Secretary of Health and Human Services should review the policies, procedures, and related control activities to ensure that the agency's Paperwork Reduction Act review process is operating effectively. (Recommendation 5)

Agency: Department of Health and Human Services
Status: Open

Comments: In October 2018, HHS provided a statement of actions it had taken to address this recommendation. HHS stated that it had added reporting tools to its Common Data Element Repository (CDER) Library that could help improve tracking of information related to HHS's Information Collection Requests. HHS also stated that it had launched daily emails to Paperwork Reduction Act (PRA) staff to inform them of Office of Management and Budget (OMB) Notices of Action related to Information Collection Requests. Additionally, HHS released an information collection burden calculator tool in the CDER Library to give PRA staff the ability to create burden tables for consistent use across multiple platforms for a single Information Collection Request. According to HHS officials, this tool incorporates both wages and employee benefits in the burden calculations. As of August 2019, HHS's burden calculator tool has been included as a resource on PRA.Digital.gov, a new OMB website that serves as a PRA knowledge base for federal staff. While these are important steps, we are awaiting additional details on how these changes have affected HHS's PRA review process. We will continue to monitor HHS's progress toward addressing our recommendation.

Recommendation: The Secretary of Health and Human Services should leverage existing consultation with stakeholders and the public to explicitly seek input on the estimated burden imposed by information collections. (Recommendation 6)

Agency: Department of Health and Human Services
Status: Open

Comments: In October 2018, HHS stated that it continues to leverage consultation mechanisms for input on the burdens imposed by information collections. According to the agency, it plans to increase the use of the eRulemaking program's Federal Docket Management System for all information collections, including non-rule Information Collection Requests. HHS also stated it plans to contact stakeholders to discuss potential information collections and receive burden estimates. As of August 9, 2019, we have not received an update about HHS's actions or plans. We will continue to monitor HHS's efforts to address our recommendation.

Recommendation: The Secretary of Transportation should review the policies, procedures, and related control activities to ensure that the agency's Paperwork Reduction Act review process is operating effectively. (Recommendation 7)

Agency: Department of Transportation
Status: Open

Comments: In its September 2018 recommendation implementation update, Department of Transportation (DOT) stated that the department began an internal review of the Paperwork Reduction Act program operations, policy, and guidance. Officials reported that they anticipate issuing an updated policy by September 30, 2019. We will continue to monitor DOT's efforts to address our recommendation.

Recommendation: The Secretary of Transportation should leverage existing consultation with stakeholders and the public to explicitly seek input on the estimated burden imposed by information collections. (Recommendation 8)

Agency: Department of Transportation
Status: Open

Comments: In its September 2018 recommendation implementation update, Department of Transportation (DOT) stated that the department began an internal review of the Paperwork Reduction Act program operations, policy, and guidance. Officials reported that they anticipate issuing an updated policy by September 30, 2019. We will continue to monitor DOT's efforts to address our recommendation.

Recommendation: Congress may wish to consider amending the Paperwork Reduction Act to more explicitly require federal agencies to consult with potential respondents on each information collection beyond the publication of Federal Register notices using efficient and effective consultation methods. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of July 2019, no relevant legislation has been enacted. We will continue to monitor legislation to see if it addresses our matter for congressional consideration.

Recommendation: The Secretary of Transportation should include enough information in Federal Register notices to allow the public to reasonably calculate or determine the number of respondents, the frequency of response, and the average burden time per response for each information collection activity. (Recommendation 9)

Agency: Department of Transportation
Status: Open

Comments: In its September 2018 recommendation implementation update, Department of Transportation (DOT) stated that the departmental Paperwork Reduction Act (PRA) Officer has reviewed the Notice templates and checklist with DOT component PRA Officers during monthly PRA meetings and has applied additional scrutiny in the review process. DOT officials stated that the department began an internal review of the Paperwork Reduction Act program operations, policy, and guidance that will include additional aids to support Notice development. Officials reported that they anticipate issuing an updated policy by September 30, 2019. We will continue to monitor DOT's efforts to address our recommendation.

Recommendation: The Commissioner of Internal Revenue should leverage existing consultation with stakeholders and the public to explicitly seek input on the estimated burden imposed by information collections. (Recommendation 10)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: According to IRS, agency officials met with representatives of external stakeholder organizations on the Information Reporting Program Advisory Committee (IRPAC) to seek input on the burden experience of their participants and the communities they represent. As a result of these discussions, the IRPAC has added the burden experience as defined by the PRA as a monthly agenda topic for the 2019 session. As of September 2019, IRS officials reported that the IRPAC has not yet met in 2019. Once we receive documentation confirming this action, we will update the status of the recommendation accordingly.

Recommendation: The Commissioner of Internal Revenue should include enough information in Federal Register notices to allow the public to reasonably calculate or determine the number of respondents, the frequency of response, and the average burden time per response for each information collection activity. (Recommendation 11)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: In October 2018, Internal Revenue Service (IRS) reported that it continues to standardize the review process by developing a checklist that ensures all required elements are included in the Federal Register notice. Agency officials stated that the agency will complete the development and delivery of training for employees with responsibility for PRA compliance in fiscal year 2019. We will continue to monitor IRS's progress toward completing these actions.

Recommendation: The Director of OMB should ensure that OMB's Office of Information and Regulatory Affairs staff, as part of the regulatory review process, examine the planned timeframes for implementing economically significant regulations or major rules and identify regulations that appear at potential risk of not complying with the Congressional Review Act's delay requirements and then work with the agencies to ensure compliance with these requirements (Recommendation 1).

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: In March 2020, OMB staff stated that they believe they have addressed the recommendation. They reiterated a statement made shortly before we issued our report that they already take steps to check agencies' compliance with the Congressional Review Act (CRA) during the regulatory review process. We published this statement in our report, but noted that OMB staff did not provide supporting documentation. Nor does the update we received in March 2020 provide supporting documentation and, thus, we cannot verify it. The update from OMB staff in March 2020 also refers to an April 2019 memorandum the Acting Director of OMB issued to the heads of executive agencies outlining updated guidance for complying with CRA. While the memorandum reminds agencies of the CRA requirement that they delay the effective date of a major rule to allow time for congressional review and following publication in the Federal Register, unless there is good cause to not delay the effective date, the Acting Director does not explain whether his office has made changes to the regulatory review process as we recommended. We will continue to monitor OMB's efforts to address our recommendation.

Recommendation: The Assistant Secretary for the Office of Public and Indian Housing (PIH) should complete workforce planning for the MTW demonstration to help ensure that PIH has sufficient staff with appropriate skills and competencies to manage an expanded demonstration, including reviewing reports and carrying out compliance reviews in a timely manner. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that PIH was continuing its workforce planning efforts, including assessing the knowledge, skills, and abilities needed to implement the MTW expansion.

Recommendation: The Assistant Secretary for PIH should more fully document the process for annually assessing compliance with the five demonstration requirements. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they had drafted written protocols for assessing compliance with the five demonstration requirements that would be finalized by May 2019.

Recommendation: The Assistant Secretary for PIH should develop and implement a process to track how MTW demonstration funds are being used for other allowable activities, including local, nontraditional activities. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they were still determining the most cost effective way to track MTW demonstration funds being used for local, nontraditional activities.

Recommendation: The Assistant Secretary for PIH should identify and implement changes to PIC to capture household data for households served through local, nontraditional activities. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that HUD planned to add fields for capturing data on households served through local, nontraditional activities to the next generation of PIC for expansion MTW agencies, which would be implemented in the summer of 2020. Officials said HUD is currently in the process of determining how the next generation of PIC will be rolled out for existing MTW agencies.

Recommendation: The Assistant Secretary for PIH should develop and implement a process to monitor MTW agencies' reserves. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they planned to monitor existing MTW agencies' Housing Choice Voucher reserves by revising their annual reporting requirements to require them to report their plans for and use of reserves.

Recommendation: The Assistant Secretary for PIH should clarify HUD's rent-reform definition for the MTW demonstration as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that PIH would clarify the definition of rent reform for existing MTW agencies in a document responding to frequently asked questions on the annual reporting requirements and for expansion agencies in the operations notice that it was finalizing for the expansion of the MTW program.

Recommendation: The Assistant Secretary for PIH should set parameters for HUD's definition of self-sufficiency for the demonstration, either by providing one definition or a range of options from which agencies could choose, as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 7)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they planned to provide a range of suggested options for defining self-sufficiency in a document responding to frequently asked questions about the annual reporting requirements for MTW agencies.

Recommendation: The Assistant Secretary for PIH should revise HUD's guidance to MTW agencies to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies and the information required for each element as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 8)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they planned to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies in the operations notice HUD was finalizing for the expansion of the MTW program. Further, HUD officials stated that the 2016 Appropriations Act that extended the standard agreement for the existing 39 MTW agencies limits HUD's ability to revise its guidance for these agencies to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies and the information required for each element. However, they stated that guidance related to the hardship policy and annual reevaluations has been updated to include more specific parameters for what an agency must submit to HUD. As we stated in our report, this guidance is set forth outside the standard agreement, which HUD already has revised without changes to the standard agreement. Therefore, we continue to believe that HUD could revise its guidance for the existing agencies to clarify which elements are required for these documents and the information each element should include.

Recommendation: The Assistant Secretary for PIH should develop written guidance for existing MTW agencies that requires a hardship policy for public housing time limits and encourages an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies for public housing and voucher programs as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 9)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they had updated their most recent annual reporting requirements for MTW agencies to require a hardship policy for public housing time limits and that they were working on finalizing guidance to existing MTW agencies encouraging an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies for public housing and voucher programs.

Recommendation: The Assistant Secretary for PIH should require an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies new MTW agencies adopt for their public housing and voucher programs as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 10)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that the operations notice they were finalizing for the expansion of the MTW program would require an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies new MTW agencies adopt for their public housing and voucher programs.

Recommendation: The Assistant Secretary for PIH should develop and implement a plan for analyzing the information that agencies report on the effect of rent-reform, work-requirement, and time-limit policies on tenants as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 11)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they planned to develop separate analysis plans for existing and expansion MTW agencies due to differences in the types of performance information HUD can require them to report under their MTW agreements.

Recommendation: In order to maintain progress in maximizing the efficiency of existing data sources, and to improve the broader efficiency of the federal statistical system and improve communication among agencies and others, the Director of OMB, in consultation with the Chief Statistician, should work with the ICSP, when OMB next updates guidance on agency survey and statistical information collection and dissemination methods, to include additional details on actions agencies can take to meet requirements to identify duplication, to consult with persons outside of the agency, and address other requirements as appropriate.

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: In March 2020, OMB staff reported that Federal Committee on Statistical Methodology has been developing two new products, featured in the Federal Data Strategy 2020 Action Plan, that they believe will be responsive to this recommendation when completed. They are (1) an update to Statistical Working Paper 22 on statistical disclosure limitation methodology, and (2) guidance on measuring and reporting data quality.

Recommendation: In order to maintain progress in maximizing the efficiency of existing data sources, and to improve the broader efficiency of the federal statistical system and improve communication among agencies and others, the Director of OMB, in consultation with the Chief Statistician, should work with the ICSP to create new methods or enhance existing methods to improve the dissemination of information and resources produced by interagency statistical committees. For example, such enhancements could include increasing the timeliness and availability of information on websites to better capture the full range of products and identify committee priorities.

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: In March 2020, OMB staff reported that Federal Committee on Statistical Methodology has been developing two new products, featured in the Federal Data Strategy 2020 Action Plan, that they believe will be responsive to this recommendation when completed. They are (1) an update to Statistical Working Paper 22 on statistical disclosure limitation methodology, and (2) guidance on measuring and reporting data quality.

Recommendation: In order to maintain progress in maximizing the efficiency of existing data sources, and to increase the reliability of the information presented on the Reginfo.gov website and in OMB's internal system, the Director of OMB, in consultation with the Chief Statistician, should work with the ICSP to implement quality-control procedures designed to identify and remedy any differences between cost and burden information provided on the website and in the related supporting statement documentation that underlies this information.

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: OMB staff reported that because it publishes cost and burden information in Federal Register notices, PRA statements, and on RegInfo.gov, the public is able to identify discrepancies and bring them to OMB's attention. We believe that the responsibility to identify these discrepancies should belong to OMB and not the public.