Recommendation: The Secretary of Commerce should direct BIS to identify, analyze, and respond to factors in the process that may cause submission errors. (Recommendation 1)

Agency: Department of Commerce
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Commerce should direct BIS to identify, assess, and make program changes to address issues that have impeded timeliness and created the backlog of exclusion requests. (Recommendation 2)

Agency: Department of Commerce
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Commerce should assign responsibility for regularly reviewing the impact of the tariffs on steel and aluminum imports, including tariff exclusions, and document the results. (Recommendation 3)

Agency: Department of Commerce
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Commerce should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 1)

Agency: Department of Commerce
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that it will develop an action plan to address the recommendation to better align its contingency plan with OMB guidance. When we confirm what actions Commerce has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Homeland Security should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: The Department of Homeland Security agreed with the recommendation and and stated that it has begun to take steps to better address OMB guidance on contingency plans. When we confirm what actions DHS has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of Internal Revenue should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 3)

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

Comments: The Internal Revenue Service (IRS) partially agreed with the recommendation. IRS agreed with one element of our recommendation to include additional detail in its agency contingency plan and stated that it is in the process of adding procedures for resuming program activities following a government shutdown into its contingency plan. IRS did not agree with the other elements of the recommendation because it believes it has already addressed plans for a potential prolonged shutdown and flexibilities for supervisors if employees are unable to return to work at the end of a shutdown in its contingency plans. We agree that while IRS has included some details on these elements in its plans, we continue to believe that it should provide more detail, such as points in time when the furlough status of an employee may change, how many employees would be affected, and the legal basis for the changes, within its publically available contingency plan to fully address these elements. We will continue to monitor IRS's efforts in this area.

Recommendation: The U.S. Trade Representative, in consultation with EOP as appropriate, should align the component's contingency plan with OMB guidance. This could be accomplished through (1) revisions to the EOP contingency plan; or (2) by creating a separate USTR plan. (Recommendation 4)

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has already begun addressing our recommendations on aligning its contingency plan with OMB guidance. When we confirm what actions USTR has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for International Trade should document the component's shutdown processes, including roles and responsibilities, planning processes for potential shutdowns, and recall processes for furloughed employees during a shutdown. (Recommendation 5)

Agency: Department of Commerce: International Trade Administration
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that the International Trade Administration (ITA) has documented its shutdown planning processes and recall processes for furloughed employees during a shutdown. When we confirm what actions ITA has taken in response to this recommendation, we will provide updated information.

Recommendation: The U.S. Trade Representative should document the component's shutdown processes, including roles and responsibilities, planning processes for potential shutdowns, and recall processes for furloughed employees during a shutdown. (Recommendation 6)

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has already begun addressing our recommendations on documenting its shutdown processes. When we confirm what actions USTR has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of CBP should develop internal controls to track and document which employees worked and what work was performed daily during a government shutdown. (Recommendation 7)

Agency: Department of Homeland Security: United States Customs and Border Protection
Status: Open

Comments: The Department of Homeland Security agreed with the recommendation and stated that Customs and Border Protection plans to analyze existing systems to determine which is best suited to track and document employee work during a government shutdown and will ensure that the chosen system is available should a future shutdown occur. When we confirm what actions CBP has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of CBP should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 8)

Agency: Department of Homeland Security: United States Customs and Border Protection
Status: Open

Comments: The Department of Homeland Security (DHS) agreed with the recommendation but stated that because Customs and Border Protection (CBP) does not have systems capable of efficiently restoring physical access for furloughed employees, it would have to reinstate employee access individually and the cost would be substantial. DHS stated that CBP plans to update procedures to ensure more comprehensive workspace access guidance for furloughed employees. We continue to believe that physical access controls are important during shutdowns in order to prevent misuse of government resources. We encourage CBP to improve their systems to be able to efficiently implement such controls and will monitor CBP's efforts going forward.

Recommendation: The Commissioner of Internal Revenue should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 9)

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

Comments: The Internal Revenue Service disagreed with this recommendation. IRS stated that it believes that it has effective controls in place to manage physical workspace access during a shutdown. In addition, IRS said that it believes that implementing additional access controls do not justify the corresponding resource investments. We continue to believe that IRS should improve its access controls, which currently rely on managers and furlough letters to communicate limits on workspace access. While we recognize the costs of increased access controls, government shutdowns are unique events that require additional access controls in order to prevent potential misuse of government resources and will monitor IRS's efforts to address it.

Recommendation: The U.S. Trade Representative should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 10)

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has made the Executive Office of the President (EOP) aware of the recommendations on developing controls for physical workspace access during a shutdown. We will continue to monitor USTR's efforts to address this recommendation.

Recommendation: The Commissioner of CBP should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 11)

Agency: Department of Homeland Security: United States Customs and Border Protection
Status: Open

Comments: The Department of Homeland Security (DHS) agreed with the recommendation. DHS stated that Customs and Border Protection (CBP) believes that furloughed employees must be able to passively monitor the status of the government shutdown and access important agency communications using DHS-issued electronic devices. Additionally, disabling and reactivating thousands of employee user accounts during a shutdown posed a significant burden. DHS said that CBP plans to update shutdown procedures to clarify allowed use of DHS-issued electronic devices by furloughed employees. We agree that CBP should update procedures on workspace access as suggested, and continue to believe that virtual access controls are important during shutdowns in order to prevent misuse of government resources. We encourage CBP to improve their systems to be able to efficiently implement such controls and will monitor CBP's progress going forward.

Recommendation: The Commissioner of Internal Revenue should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 12)

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

Comments: The Internal Revenue Service disagreed with this recommendation. IRS stated that it believes that it has effective controls in place to manage virtual workspace access during a shutdown. In addition, IRS said that it believes that implementing additional access controls do not justify the corresponding resource investments. We continue to believe that IRS should improve its access controls, which currently rely on managers and furlough letters to communicate limits on workspace access. While we recognize the costs of increased access controls, government shutdowns are unique events that require additional access controls in order to prevent potential misuse of government resources and will monitor IRS's efforts to address it.

Recommendation: The Under Secretary for International Trade should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 13)

Agency: Department of Commerce: International Trade Administration
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that the International Trade Administration (ITA) has established and documented internal controls to limit virtual workspace access to excepted or exempt employees during a government shutdown. When we confirm what actions ITA has taken in response to this recommendation, we will provide updated information.

Recommendation: The U.S. Trade Representative should, in consultation with EOP, develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 14)

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has made the Executive Office of the President (EOP) aware of the recommendations on developing controls for virtual workspace access during a shutdown. We will continue to monitor USTR's efforts to address this recommendation.

Recommendation: The Secretary of Homeland Security should direct the Director of ICE to develop a strategy for the TTU program to ensure that ICE has a plan to guide its efforts to effectively partner with existing TTUs, and to expand the program, where appropriate, into additional countries. (Recommendation 1)

Agency: Department of Homeland Security: Office of the Secretary
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Homeland Security should direct the Director of ICE to develop a performance monitoring framework for the TTU program that would enable the agency to systematically track program results and how effectively it is achieving the program's goals. (Recommendation 2)

Agency: Department of Homeland Security: Office of the Secretary
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The SBA Administrator should establish a process that ensures documentation of states' compliance with the total match requirement before grant closeout. (Recommendation 1)

Agency: Small Business Administration
Status: Open
Priority recommendation

Comments: SBA generally agreed with GAO's findings and concurred with our recommendations. In response to our draft report, agency officials said SBA will establish a process that ensures documentation of state recipients' compliance with the total match requirement before grant closeout. In September 2019, officials told us this process will include assigning SBA program office responsibilities for ensuring recipient compliance related to the cost match. In March 2020, SBA officials said they were still working on implementing changes to address our recommendation. GAO will continue to monitor the agency's implementation of this process.

Recommendation: The SBA Administrator should develop a process to determine states' compliance with the cash match requirement. (Recommendation 2)

Agency: Small Business Administration
Status: Open
Priority recommendation

Comments: SBA generally agreed with our findings and concurred with our recommendations. In response to our draft report, agency officials said they would develop a process to determine state's compliance with the cash match requirement. In September 2019, officials told us the process will apply to both grants specialists and program officers, and ensure the cost match is appropriately applied. In March 2020, SBA officials said they were still working on implementing changes to address our recommendation. GAO will continue to monitor the agency's implementation of this process.

Recommendation: The Director of the Office of Management and Budget should instruct the Office of Federal Procurement Policy: (1) To facilitate additional training to improve the understanding of the contracting workforce regarding the Buy American Act requirements; and (2) To facilitate clarifying revisions to FPDS-NG, where needed, and provide training and guidance for recording Buy American Act information in FPDS-NG to improve the accuracy of the Buy American data. (Recommendation 1)

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

Comments: The Office of Federal Procurement Policy (OFPP) within OMB concurred with our recommendation, noting that it plans to coordinate with federal agencies on the extent to which they have developed training and guidance. Based on this information, OFPP will work with agencies to determine the most appropriate course of action to address gaps, if any. As of August 2020, OFPP stated that it had not taken any additional actions to implement the recommendation because it is currently focused on implementing Executive Order 13881 "Maximizing Use of American-Made Goods, Products and Materials".

Recommendation: The Secretary of Veterans Affairs should clarify existing guidance, or provide training or other instruction, to help contracting officials: (1) Address the applicability of the Buy American Act requirements and provide instruction on how to implement the requirements, including in any training developed to implement the Veterans First policy; (2) Identify the factors that should be considered in order to determine the applicability of the Trade Agreements Act and waiver of the Buy American Act; and (3) Identify sources of information available for determining products' origins and the steps they should take to verify information that is inconsistent. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs (VA) concurred and has since taken action to address some of our three-part recommendation. For example, VA revised its "Procurement Policy Memorandum 2017-12", on April 9, 2019, to better clarify its existing Buy American Act guidance and highlight key factors contracting staff should consider when determining the applicability of Buy American Act exceptions and waivers. Additionally, in October 2019, VA provided GAO briefing slides for a new training to be offered at the agency's acquisition academy that includes specific instruction pertaining to the use of Buy American Act exceptions and waivers. However, VA has yet to address our recommendation that the agency clarify guidance or provide training to help contracting officers identify sources of information regarding product origin and the steps to be taken to verify inconsistent product origin information. We plan to keep this recommendation open until VA implements guidance or training of this nature and we are able to assess the extent to which it fully addresses our recommendation.

Recommendation: The Secretary of Health and Human Services should provide guidance, training, or other instruction to help contracting officials: (1) Identify the factors that should be considered in order to determine the applicability of the Trade Agreements Act and waiver of the Buy American Act; (2) Document determinations of the use of Buy American exceptions for domestic non-availability and ensure the required approvals are obtained; and (3) Identify sources of information available for determining products' origins and the steps they should take to verify information that is inconsistent. (Recommendation 4)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with this recommendation and has taken steps to implement it. HHS issued a memorandum in February 2019 requiring all contracting officers as part of their continuous learning program to complete the Buy American Statute course, FAC063, offered by the Federal Acquisition Institute. As of February 2020, about 90 percent of contracting officials had taken the required training. However, due to its COVID-19 Pandemic response activities, HHS stated that all of its contracting officials had not completed the training as intended. HHS also developed checklists and guidance related to the Buy American Act and Trade Agreements Act. We plan to keep this recommendation open until HHS completes its training initiative.

Recommendation: To strengthen CBP's trade enforcement efforts, the Commissioner of CBP should direct the Office of Trade to include performance targets, when applicable, in addition to performance measures in its Priority Trade Issue strategic and annual plans.

Agency: Department of Homeland Security: United States Customs and Border Protection
Status: Open

Comments: As of August 2019, the seven FY 2019 Priority Trade Issue (PTI) annual plans prepared by CBP's Office of Trade all included performance measures with performance targets, but some plans did not include baselines to measure it's trade enforcement efforts against. The Office of Trade reported that it was in the process of finalizing its FY2020 annual plans, which should be available in December 2019. In addition, the Office of Trade reported that it no longer develops a single strategic plan covering all of its PTIs and only prepares the PTI annual plans.

Recommendation: To strengthen CBP's trade enforcement efforts, the Commissioner of CBP should direct the Office of Trade and the Office of Field Operations to develop a long-term hiring plan that articulates how CBP will reach its staffing targets for trade positions set in the Homeland Security Act and the agency's resource optimization model.

Agency: Department of Homeland Security: United States Customs and Border Protection
Status: Open

Comments: As of June 2019, CBP stated that both the Office of Trade (OT) and Office of Field Operations (OFO) continue to take steps to address hiring gaps which include evaluating approaches to hiring and evaluating and selecting candidates for its various trade positions. For example, OT had developed a recruitment strategy for hiring regulatory auditors. OT reported that it has brought regulatory auditors onboard as a result of its strategy but experienced attrition and challenges in attaining its staffing target for this position. OT and OFO did not provide recruitment strategies for the other trade positions. OFO's Human Capital Division, along with assistance from OT and other CBP components, reported finalizing a long-term hiring plan to meet and maintain the congressional floor for certain trade and revenue positions, including those for import specialists, by the end of fiscal year 2020.

Recommendation: The U.S. Trade Representative should, with appropriate experts in Commerce, OMB, and GSA, improve the U.S. methodology for providing federal government procurement statistics to the WTO to ensure both accurate and more timely reporting, consistent with GPA requirements--for example, by providing preliminary estimates and updated values of covered federal procurement or by using an alternative methodology that bases measures of covered government procurement on actual annual obligations, if USTR determines that such an approach is consistent with WTO obligations.

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: In February 2017 we reported that the United States had revised its approach to statistical reporting to the World Trade Organization (WTO) about covered federal government procurement from an "award values" methodology to an actual "cumulative obligations" approach in October 2015. The "cumulative obligations" methodology resulted in a more accurate measure of covered federal procurement, but it introduced a 6-year delay in reporting. We found this reporting delay inconsistent with the 2014 WTO Agreement on Government Procurement (GPA) requirement of reporting within 2 years of the end of the reporting period. We recommended that the U.S. Trade Representative (USTR) should, with appropriate experts in Commerce, Office of Management and Budget, and General Services Administration, improve the U.S. methodology for providing covered federal government procurement statistics to the WTO to ensure both accurate and more timely reporting, consistent with GPA requirements--for example, by providing preliminary estimates and updated values of covered federal procurement or by using an alternative methodology that bases measures of covered government procurement on actual annual obligations, if USTR determines that such an approach is consistent with WTO obligations. Following the issuance of our report, in December 2017 USTR reported that they had worked with other agencies to improve their methods. While they decided to continue to report statistics using the "cumulative obligations" methodology they decided to also report "partially reported" (preliminary) statistics to improve the timeliness of U.S. reporting. This preliminary data was to be based on the same data used in the "cumulative obligations" methodology but can be submitted within two years of the end of the reporting period and therefore comply with GPA statistical reporting obligations. USTR submitted preliminary statistics for FY 2015 on November 15, 2017; for FY 2016 on October 31, 2018; and for FY 2017 on October 29, 2019. USTR will later update these statistics to reflect the "final" total value in 2021. GAO will continue to monitor this recommendation until that time.

Recommendation: To inform DOT's development of its national freight strategy and associated freight efforts, such as states' development of freight plans, newly established freight funding programs, and advancing DOT's efforts to implement national freight policies, in the development of the freight data strategy, the Secretary of Transportation should include a specific plan to identify: (1) appropriate freight data sources, information, and analytic tools for transportation modes involved in the freight network and supply chains; (2) data gaps that could help both the agency and states and local governments in the development of their freight plans, and an approach for addressing obstacles to developing high-quality, reliable supply chain information; (3) current and planned efforts that can provide insights into supply chains and their impacts on freight networks; and (4) how DOT plans to use the supply chain information and analytical tools to inform freight planning and programming.

Agency: Department of Transportation
Status: Open

Comments: DOT concurred with this recommendation. As of March 2020, DOT had not issued the National Freight Strategic Plan, but DOT officials stated that they are planning to issue it in 2020. To fully implement this recommendation, in the national strategy, DOT should include plans to identify data sources, gaps, information on supply chains and freight networks, and on how DOT will use this information.

Recommendation: To improve risk management in the collection of AD/CV duties and to identify new or changing risks, CBP should regularly conduct a comprehensive risk analysis that assesses both the likelihood and the significance of risk factors related to AD/CV duty collection. For example, CBP could construct statistical models that explore the associations between potential risk factors and both the probability of nonpayment and the size of nonpayment when it occurs.

Agency: Department of Homeland Security: United States Customs and Border Protection
Status: Open
Priority recommendation

Comments: As of December 2019, CBP was taking steps to conduct the type of risk analysis GAO recommended in July 2016. In November 2019 we reported that according to CBP , the agency had developed and successfully tested two models using risk factors including, but not limited to, the type of good, country of origin of the good, and whether the importer is from a foreign country. One test demonstrated that, using data from fiscal years 2007-2015, CBP could have predicted over 95 percent of the importers with delinquent antidumping and countervailing (AD/CV) duty bills in fiscal years 2016 and 2017. CBP requested $17 million in fiscal year 2020 funds to make updates to its information systems necessary to facilitate the implementation of statistical models. CBP is also working on long-term enhancements to the models that it says will leverage additional modeling techniques, such as social network and spatial analysis. Regularly conducting a comprehensive risk analysis of factors related to AD/CV duty non-collection could enhance CBP's capacity to collect additional revenue by enabling CBP to increase bonding amounts for continuous entry and single-transaction bonds for importers with a greater risk of nonpayment. In a December 2019 Commercial Customs Operations Advisory Committee report, CBP said that it planned to begin rolling out a risk-based bonding framework in March 2020. The new framework relies on a bond formula that is in part based on risk factors identified by the statistical models .

Recommendation: To improve risk management in the collection of AD/CV duties, CBP should, consistent with U.S. law and international obligations, take steps to use its data and risk assessment strategically to mitigate AD/CV duty nonpayment, such as by using predictive risk analysis to identify entries that pose heightened risk and taking appropriate action to mitigate the risk.

Agency: Department of Homeland Security: United States Customs and Border Protection
Status: Open
Priority recommendation

Comments: As of December 2019, CBP was taking steps to develop a risk-based AD/CV bonding framework to use in conjunction with the development of an AD/CV risk assessment model. CBP is developing a supplemental AD/CV duty continuous entry bond that incorporates nonpayment risk factors identified in its statistical models and has worked with Commercial Customs Operations Advisory Committee (COAC) to test the proposed risk based bonding formula by applying it to historical data. CBP has estimated that the collection rate under the risk-based bonding framework using the proposed formula would have been significantly higher than the collection rate under its existing bond policies during fiscal years 2007-2017, both in number and value of the bills collected; however, COAC members said the proposed bond formula would have resulted in overinsurance, which could increase cost to importers. The use of supplemental continuous entry bonds may require regulatory changes and modifications to CBP's database. CBP has also conducted an analysis of the use of single-transaction bonds using historical data, and found that this procedure would have allowed CBP to collect significantly more revenue in fiscal years 2007-2018. CBP is working with COAC members to test a risk-based application of single-transaction bonds to historical AD/CV duty entries to assess whether the bond would have reduced the amount of uncollected duties. In a December 2019 Commercial Customs Operations Advisory Committee report, CBP said that it plans to rolls out its risk-based bonding framework in March 2020.

Recommendation: To improve the consistency, comprehensiveness, and transparency of information provided to Congress and policymakers on the federal investment in export promotion programs, the Secretary of Commerce, as chair of the TPCC, should report in its National Export Strategies on how resources are allocated by agency and aligned with priorities.

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: The Export Enhancement Act [15 U.S.C. Section 4727(c)] states that the Trade Promotion Coordinating Committee's (TPCC) strategies should establish a set of priorities for federal export promotion activities and propose a unified federal trade promotion budget that supports the plan. In written comments on GAO's report, the Director of the TPCC Secretariat generally concurred with the recommendation on behalf of the Secretary. Nevertheless, the Director noted the TPCC's limited authority over budget reporting and resource allocations and gave examples of some challenges they faced, including shifts in the political and budgetary landscape and how different Administrations and Congresses have emphasized different priorities over time. In the years following GAO's 2013 report, the TPCC has not issued any National Export Strategies (NES), except in 2016; however this 2016 NES did not include any budget information on how resources were allocated by agency and aligned with the strategy's priorities. In August 2020 Commerce officials told GAO they had collected budget information from TPCC agencies related to trade promotion activities (FY19 actual and FY20 requested). They noted that the budget categories and agencies from which it was collected reflected changes in Administration priorities and new Congressional mandates. However, they said this information has not been transmitted to Congress.

Recommendation: To ensure that the performance measures used to evaluate the TAA for Firms program demonstrate program results and to help ensure that EDA can comprehensively evaluate the effectiveness of the program, the Secretary of Commerce should broaden the program's evaluation approach, for instance, by developing additional quantifiable outcome-oriented performance goals and measures for key program areas and conducting further analysis of the data to isolate the impact of the TAA for Firms program from other influences, such as economic trends.

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: Commerce concurred with our findings and recommendations. As of August 2020, EDA is taking actions to implement our recommendation. In 2012, EDA commissioned a study to inform the development of performance metrics and evaluation methods for the TAA for Firms program. Issued in October 2014, the study provided recommendations to EDA on potential performance metrics, tested the metrics by conducting a statistical analysis of TAA for Firms clients against a control group as well as a survey, and suggested data sources for conducting future evaluations of the TAA for Firms program. According to EDA officials, the study would help provide a foundation for more robust longitudinal performance measurement and enhanced policy analysis, thereby enabling EDA to more comprehensively evaluate the program. These officials noted that, in April 2017, the authors of the study finalized an operational toolkit containing recommended metrics and protocols for data collection and impact evaluation methods. In June 2017, EDA began to pilot test these recommended metrics and evaluation methods to improve program evaluation. EDA formed a working group in December 2017 to further refine the new evaluation system and metrics based on the results of the pilot tests. In May 2018, EDA's working group concluded the refinement of the metrics. In August 2018, EDA continued to collect data on these metrics from its grantees using a pilot survey and refined the metrics as EDA received additional responses and feedback about the pilot survey from grantees. As of August 2020, EDA had developed new data collection instruments that will gather data and information on the TAA for Firms program's outputs and outcomes. EDA intends to use the information collected from the new instruments to conduct program evaluations to better understand how program performance compares with performance goals and the impact of the TAA for Firms program, according to EDA officials. EDA is in the process of developing software to administer the instruments and an internal working group is guiding the implementation of the new data collection system. EDA expects to implement the new system in fiscal year 2020, according to EDA officials. We will continue to monitor Commerce's efforts to implement our recommendation.

Recommendation: To improve the data available to manage and evaluate the TAA for Firms program, the Secretary of Commerce should develop a data system to consistently collect, maintain, and analyze sufficiently reliable and up-to-date data on program operations and participant firms.

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: Commerce concurred with our findings and recommendations. As of August 2020, EDA is taking actions to implement our recommendation. According to EDA officials, in fiscal year 2017, EDA had developed an improvement plan for its agency-wide data system for collecting data on program operations. As of August 2020, EDA is working with a contractor to implement a new data system to assist in administering and managing the TAA for Firms program. For example, EDA officials expect the new data system to allow TAA Centers to submit participant firms' petitions for certification and adjustment proposals to EDA electronically for review and approval. In addition, these officials noted that the new data system will facilitate EDA's analysis of program performance. EDA anticipates that the new data system for the TAA for Firms program will be operational in fiscal year 2021. We will continue to monitor Commerce's efforts to implement our recommendation.

Recommendation: To help ensure that FDA's overseas offices are able to fully meet their mission of helping to ensure the safety of imported products, the Commissioner of FDA should ensure, as it completes its strategic planning process for the overseas offices, that it develops a set of performance goals and measures that can be used to demonstrate overseas office contributions to long-term outcomes related to the regulation of imported products and that overseas office activities are coordinated with the centers and Office of Regulatory Affairs (ORA).

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

Comments: In June and July 2018 FDA reported on its recent efforts to assess the effectiveness of the foreign offices' contributions to drug-safety related outcomes. Among other things, the agency developed new performance measures for these offices along with a monitoring and evaluation plan and conducted an assessment of the foreign offices to help set their objectives and ensure the right balance of personnel, skillsets, and resources. However, FDA still had to develop intermediate outcomes to link with final outcomes. In August 2020, the agency indicated that because of a reorganization and strategic planning effort for its Office of Global Policy and Strategy, it was still revising and updating its measures and its approach to evaluating impact in 2020 to align with a five-year strategic plan completed in March 2020. The agency indicated that the recommendation should remain open, and GAO will continue to monitor the implementation of this recommendation.