GAO

2024 Lobbying Disclosure: Observations on Compliance with Requirements

What GAO Found Most lobbyists provided documentation for key elements of their disclosure reports to demonstrate compliance with the Lobbying Disclosure Act of 1995, as amended. For the third and fourth quarters of 2023 and the first and second quarters of 2024, GAO estimates that 97 percent of lobbyists who filed new registrations also filed quarterly lobbying disclosure reports as required for the quarter in which they first registered, 93 percent of lobbyists who filed quarterly lobbying disclosure reports provided documentation for lobbying income and expenses, and 95 percent of semiannual contribution reports included all reportable political contributions. These findings are generally consistent with GAO's findings since 2015. Lobbyists are required to report certain criminal convictions. GAO found that, of the 258 individual lobbyists in its sample, none failed to report a conviction. The figure below describes the typical filing and enforcement processes. Typical Lobbying Disclosure Process GAO found that most lobbyists surveyed reported some level of ease in complying with quarterly disclosure requirements and in understanding the definitions of terms used in quarterly lobbying disclosure reports. However, based on GAO's estimates, 21 percent of quarterly lobbying disclosure reports included individual lobbyists who had not properly disclosed covered positions—certain jobs in the executive and legislative branches—as required. To bring lobbyists into compliance, the U.S. Attorney's Office for the District of Columbia continues to contact lobbyists who have not filed their disclosure reports. From 2015 through 2024, the office received 3,566 referrals from the Secretary of the Senate and the Clerk of the House for failure to file quarterly lobbying disclosure reports. As of December 2024, about 36 percent of these referrals were closed as in compliance, and about 63 percent were pending further action. Why GAO Did This Study The Lobbying Disclosure Act of 1995, as amended, requires lobbyists to file quarterly lobbying disclosure reports and semiannual contribution reports, among other requirements. The law includes a provision for GAO to annually audit the extent of lobbyists' compliance with the act. This report (1) determines the extent to which lobbyists demonstrated compliance with disclosure requirements, (2) identifies challenges or potential improvements to compliance that lobbyists report, and (3) describes the efforts of the U.S. Attorney's Office for the District of Columbia in enforcing compliance. This report is GAO's 18th annual review under the provision. GAO reviewed a stratified random sample of 100 quarterly lobbying disclosure reports filed for the third and fourth quarters of calendar year 2023 and the first and second quarters of calendar year 2024. GAO also reviewed a random sample of 160 contribution reports from year-end 2023 and midyear 2024. This methodology allowed GAO to generalize to the population of 67,577 quarterly disclosure reports with $5,000 or more in lobbying activity and 35,034 contribution reports. In addition, through a survey, GAO obtained the views of 99 different lobbyists on any challenges or potential improvements to aid compliance. GAO also interviewed U.S. Attorney's Office officials. GAO provided a draft of this report to the Department of Justice for review. The Department of Justice provided technical comments, which GAO incorporated as appropriate. For more information, contact Yvonne D. Jones at JonesY@gao.gov.

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State Department: Bureau of International Narcotics and Law Enforcement Affairs Needs to Fully Address Prior GAO Recommendations

What GAO Found The Department of State is responsible for coordinating U.S. assistance supporting international efforts to combat illicit narcotics, a role fulfilled by the Bureau of International Narcotics and Law Enforcement Affairs (INL). Fentanyl Seized in Nuevo Leon, Mexico GAO previously identified challenges State and INL face in determining the effectiveness of assistance they provide to foreign partners. Performance management can help INL identify whether the billions of dollars appropriated to help meet its mission are spent effectively and help achieve its goals. In September 2023, GAO found that INL's efforts to implement assistance to Mexico had been hampered by incomplete performance management efforts. As a result, the U.S. government could not demonstrate that the more than $3 billion of assistance it had provided to Mexico was spent effectively and helped achieve goals. GAO made three recommendations to INL to better ensure that it spends such assistance effectively. INL has taken steps to address these recommendations but has not fully implemented them. GAO also previously identified challenges State and INL face in monitoring and evaluating projects. For example, in March 2023, GAO found that State had not conducted a comprehensive evaluation of the collective efforts of U.S. agencies to combat cybercrime and ensure that programs were achieving intended goals. GAO recommended that INL conduct a comprehensive evaluation of capacity building efforts to counter cybercrime. State officials said that INL planned to conduct such an evaluation. INL has taken steps to address this recommendation but has not fully implemented it. In addition, GAO previously identified challenges INL faces in managing fraud risk in assistance to Mexico. Specifically, in March 2021, GAO found that INL had not fully assessed the potential risks of fraud in assistance to Mexico and made three recommendations to INL to help improve efforts in this area. While INL has developed a preliminary anti-fraud strategy for that assistance, it has not yet issued or implemented a final anti-fraud strategy. Why GAO Did This Study Combatting transnational crime and drug trafficking are long-standing national security priorities for the U.S., and the opioid crisis has been a public health emergency since 2017. Hundreds of thousands of Americans have died from misusing drugs, with more than 66 percent of these deaths involving synthetic opioids such as fentanyl. According to the Office of National Drug Control Policy, criminal organizations in Mexico supply most of the illicitly manufactured fentanyl smuggled into the U.S. INL's mission is to keep Americans safe by countering crime, illegal drugs, and instability abroad. This statement discusses four key areas where State and INL have faced challenges implementing programs overseas: (1) performance management, (2) program monitoring, (3) program evaluation, and (4) fraud risk management. This statement is based on GAO's prior work on a variety of State and INL programs. For that work, GAO analyzed State documents and data and interviewed agency officials. For a full list of the reports, see Related GAO Products at the conclusion of this statement.

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Passport Processing: State Department Should Identify Milestones and Resource Needs for Its Plans to Avoid Future Delays

What GAO Found Unusually long processing times in fiscal year 2023 had various negative effects on U.S. passport applicants. Processing of routine passport applications took more than 4 weeks longer than before the COVID-19 pandemic and expedited applications took more than 2 weeks longer. These delays' effects on passport applicants included delayed or cancelled travel. Several factors contributed to the processing delays. One primary factor was staff shortages stemming from a hiring freeze in fiscal year 2017. Other factors included unexpected fluctuations in application volume. For example, State received 21.6 million applications in fiscal year 2023, nearly 2 million more than it had expected. Backlog of Passport Applications at National Passport Center, Portsmouth, NH, 2023 State implemented short-term measures to mitigate the processing backlog in fiscal year 2023. For example, State required passport specialists to work up to 24 hours of overtime per month in fiscal year 2023. State data show that specialists worked more than 250,000 hours of overtime during the fiscal year. State is developing a long-term plan, known as the Transformation Roadmap, for projects to modernize processing and avoid future delays, but it has not identified milestones or resource needs for all of the projects. As of November 2024, State had developed 83 projects that included improving information technology and opening six new passport agencies. As of December 2024, State had defined milestones to measure progress for 24 projects it considered necessary for the roadmap's success, but it has not done so for the remaining 59. In addition, State has not identified the resources needed to fully implement the roadmap. State officials told GAO that the greatest risks to implementing the roadmap were insufficient staffing and funding. GAO's prior work has shown that defining milestones for agency reform efforts and determining planned projects' costs (e.g., staffing, funding, and other resources) are critical to the reforms' and projects' success. Taking such actions would better position State to complete its efforts to reduce the likelihood of future delays in passport processing and their negative effects on U.S. travelers and the travel industry. Why GAO Did This Study Issuance of U.S. passports is among the State Department's most visible and important public services. Moreover, its timeliness in adjudicating passport applications and issuing passports affects American citizens as well as the travel and leisure industry. In fiscal year 2023, State experienced a passport processing backlog, which led to substantially longer processing times than before the COVID-19 pandemic. GAO was asked to review State's passport processing backlog. In addition, a House Report included a provision for GAO to study passport processing times. This report examines (1) the time frames for State's processing of passport applications in fiscal year 2023 and the effects of processing delays on applicants; (2) factors that contributed to processing delays in fiscal year 2023; (3) State's actions to mitigate the backlog; and (4) the extent of State's long-term planning to prevent future delays. GAO reviewed State passport processing data and documents related to managing delays. GAO also interviewed State officials and visited or met with staff at four processing centers. GAO selected these centers on the basis of factors such as size, location, and volume of applications processed in 2023.

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Small Business Pilot Program: SBA Has Opportunities to Evaluate Outcomes and Enhance Fraud Risk Mitigation

What GAO Found The Small Business Administration's (SBA) Community Navigator Pilot Program aimed to expand access to small business assistance resources for underserved communities. The program, which operated from December 2021 to May 2024, awarded grants to “hubs”—nonprofits, local governments, and other entities that partnered with smaller organizations, called “spokes” (see figure). Overview of SBA Community Navigator Pilot Program SBA data suggest the program served a higher proportion of clients from high-minority, high-poverty, and low-income areas compared to other SBA business assistance programs. Challenges that navigators identified included collecting sensitive client data and building effective partner networks. The Navigator Program aligned with one and partially aligned with four leading practices for pilot program design. SBA established clear, measurable program objectives, such as increasing use of SBA services among underserved business owners, and developed a data gathering strategy and assessment methodology. However, GAO identified opportunities for SBA to evaluate the pilot and mitigate broader program risks: Evaluation. SBA does not plan to evaluate outcomes of the pilot. However, evaluations play a key role in strategic planning and program management. Conducting an evaluation would capture lessons learned from pilot activities. Additionally, by assessing scalability and incorporating input from a broad array of SBA staff and partner organizations, the evaluation could inform current and future programs and congressional decision-making. Fraud mitigation. SBA took steps to address fraud risk for the program, such as completing a fraud risk assessment and training hubs on financial oversight. However, during application reviews, SBA staff did not consult local SBA offices with potential knowledge about applicants' risks. For example, staff in one district office said they could have flagged a local applicant that overstated its capacity to provide assistance. SBA officials said that to avoid potential bias and inconsistency, its competitive grant programs' application reviews do not include consultation with local SBA offices. However, GAO identified federal grantmaking agencies that incorporated local staff input while implementing safeguards to mitigate bias and maintain consistency. By developing procedures to obtain relevant information from local agency staff, SBA could improve its ability to assess applicants and address fraud risks. Why GAO Did This Study Racial and ethnic minorities, women, tribal groups, and other communities have historically faced barriers to accessing credit, capital, and other resources necessary to start and grow businesses, according to SBA. The American Rescue Plan Act of 2021 directed SBA to establish the Community Navigator Pilot Program, a new, short-term business assistance program to serve these communities. GAO was asked to review the Community Navigator Pilot Program. This report examines (1) how the program reached underserved small business owners, (2) the program's alignment with leading practices for pilot program design, and (3) the program's efforts to manage fraud risk. GAO analyzed SBA documents, interviewed officials, and compared the pilot program design and fraud risk management processes against leading practices. GAO also analyzed SBA and Census data and interviewed 18 navigators (chosen to reflect a mix of grant amounts, regions, and organization types) about their activities. GAO conducted three site visits reflecting a mix of geographic regions and organization types.

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Patient-Centered Outcomes Research Institute: Review of the FY 2024 Financial Statement Audit

What GAO Found Based on the limited procedures GAO performed in reviewing the independent public accounting firm's (IPA) fiscal year 2024 audit of the Patient-Centered Outcomes Research Institute's (PCORI) financial statements, GAO did not identify any significant issues that it believes require attention. Had GAO performed additional procedures, other matters might have come to its attention that it would have reported. The IPA provided an unmodified audit opinion on PCORI's fiscal years 2024 and 2023 financial statements. Specifically, the IPA found that PCORI's financial statements were presented fairly, in all material respects, in accordance with U.S. generally accepted accounting principles. Further, for fiscal year 2024, the IPA did not identify any deficiencies in internal control that it considered to be material weaknesses or any reportable noncompliance with the selected provisions of laws, regulations, contracts, and grant agreements it tested. PCORI concurred with the IPA's conclusions. GAO's review of PCORI's fiscal year 2024 financial statement audit, as differentiated from an audit of the financial statements, was not intended to enable GAO to express—and it does not express—an opinion on PCORI's financial statements or conclude on the effectiveness of its internal control over financial reporting. Furthermore, GAO does not express an opinion on PCORI's compliance with provisions of applicable laws, regulations, contracts, and grant agreements. The IPA is responsible for its reports on PCORI dated February 19, 2025, and the conclusions expressed therein. GAO provided a draft of its report to PCORI and the IPA for review and comment. PCORI's Chief Financial Officer provided technical comments, which GAO incorporated in the final report. An IPA partner responded that the IPA had no comments on the draft report. Why GAO Did This Study This report presents the results of GAO's review of PCORI's fiscal year 2024 financial statement audit. PCORI is a federally funded, nonprofit corporation that is neither an agency nor establishment of the U.S. government. PCORI's purpose is to help patients, clinicians, policymakers, and others make informed decisions about health and health care options. The Patient Protection and Affordable Care Act requires PCORI to obtain an annual financial statement audit from a private entity with expertise in conducting financial audits. The act includes a provision for the Comptroller General of the United States to review the audit and report the results to the Congress annually. GAO's objective was to review the results of PCORI's fiscal year 2024 financial statement audit. To satisfy this objective, GAO (1) read and considered various documents relating to the IPA's independence, objectivity, and qualifications; (2) analyzed key IPA audit documentation; (3) read PCORI's fiscal years 2024 and 2023 financial statements, the IPA's audit report on the financial statements, and the IPA's report on internal control over financial reporting and compliance; and (4) met with IPA representatives and PCORI management officials. For more information, contact Cheryl E. Clark at clarkce@gao.gov.

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Grants Management: Recent Guidance Could Enhance Subaward Oversight

What GAO Found The Single Audit Act requires non-federal entities that expend above a certain amount in federal awards in a fiscal year to undergo a single audit—an audit of an entity's financial statements and federal awards—or in select cases a program-specific audit. GAO analyzed 3,680 single audit findings from 2022 to 2024 addressed to recipients that received a grant award from a federal agency and passed funds through to another entity, or subrecipient, in the form of a subaward. According to this analysis, 36 percent of these findings were primarily associated with one of the following topics: Incomplete subaward reporting. Some of these grant recipients did not fulfill required reporting of subawards to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) for display on USAspending.gov. This limits the transparency of federal funding and makes it challenging to track these funds for oversight purposes. Subrecipient monitoring activities. Some of these grant recipients did not monitor their subrecipients' activities or did not review audit reports for their subrecipients, which impairs their oversight of those subrecipients. Verifying or justifying eligibility decisions. Some of these grant recipients did not ensure that their subrecipients were eligible to receive federal funds, which can put those funds at risk for fraud. While grant recipients are responsible for overseeing their subawards, federal agencies are to ensure the grant recipients they make awards to carry out their oversight responsibilities. GAO selected an example grant program with subrecipients from each of the three agencies that received the largest amounts of Infrastructure Investment and Jobs Act (IIJA) funding. Officials from these programs described a variety of approaches to support subaward oversight, such as reviewing recipients' budgets, progress reports, and audit findings. In 2024, the Office of Management and Budget (OMB) took steps that could enhance federal subaward oversight. These steps include: amending the Code of Federal Regulations to direct agencies to review single audit findings to non-federal entities—including subrecipients—which could broaden agencies' awareness of challenges affecting their programs; issuing a memorandum directing agencies to update their award terms to clearly convey the requirement for grant recipients to provide complete subaward descriptions in their reports to FSRS, which should result in clearer information available to the public about federal spending; and addressing GAO's prior recommendation to clarify agencies' role in supporting subaward data quality by issuing a memorandum directing agencies to hold their grant recipients accountable for reporting subawards to FSRS, which should lead to more complete subaward data being publicly available on USAspending.gov. GAO will continue to monitor subaward oversight and transparency as agencies take steps to implement this guidance. Why GAO Did This Study In fiscal year 2024, the federal government obligated roughly $1.2 trillion in grants to support national priorities. Grant recipients can pass through these funds to subrecipients in the form of a subaward. GAO and Office of Inspectors General audits have found persistent issues with the completeness and accuracy of subaward information. This makes it challenging to track where subaward funds are ultimately spent and can increase the risk for fraud and misuse of federal funds. GAO was asked to review various issues related to subaward oversight. This report describes (1) common issues related to subaward oversight identified through single audits; (2) how selected federal agencies and grant programs implement their subaward oversight requirements; and (3) recent changes to regulations and guidance that could enhance subaward oversight. GAO analyzed single audit findings from the Federal Audit Clearinghouse to identify common compliance issues related to subaward oversight. GAO met with officials from IIJA grant programs with funds distributed as subawards to describe examples of federal subaward oversight. GAO also reviewed recent changes to relevant regulations and guidance and discussed how they could improve subaward oversight with OMB staff. We provided a draft to our three selected agencies and OMB for comment. One agency provided technical comments, which we incorporated as appropriate, and two responded with no comments. OMB did not provide comments. For more information, contact Jeff Arkin at ArkinJ@gao.gov.

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Bank Capital Reforms: U.S. Agencies' Participation in the Development of the International Basel Committee Standards

What GAO Found Capital plays a critical role in ensuring bank safety and soundness. The Basel Committee on Banking Supervision, an international body of bank supervisors, sets nonbinding minimum regulatory capital standards for large banks. The committee relies on its members to implement the standards in their jurisdictions. The U.S. members of the Basel Committee are the Board of Governors of the Federal Reserve System, Federal Reserve Bank of New York, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency. Standard-development process. The Basel Committee process for developing the standards involved multiple rounds of analyses, discussion, and review. Each final standard underwent at least one round of public comments and quantitative studies assessed potential impacts on banks' regulatory capital. Decisions were made by consensus, with groups negotiating and agreeing on the scope of work, alternatives to analyze, actions to take or not take, and standards to propose and finalize. Staff from all U.S. members participated in these groups. GAO found collaboration among U.S. members throughout this process generally reflected best practices for interagency collaboration (such as leveraging information and including relevant participants). External comments and impact analyses. U.S. members informed their positions by reviewing public comments on proposals, meeting with industry representatives, contributing to and using quantitative impact studies, and conducting their own analyses. These activities helped provide insight into the potential impacts of proposed reforms and identify alternative approaches. GAO found that the information U.S. members collected and analyses they conducted generally reflected key elements for regulatory analysis (such as consideration of alternatives and evaluation of benefits and costs). U.S. members' negotiating priorities. U.S. members had two overarching reform priorities for the final Basel III standards. One was to better align certain regulatory standards for non-U.S. banks with their parallel U.S. requirements to promote a more level playing field. U.S. members also shared the Committee's priority to address weaknesses in the Basel framework—they sought to improve and balance the simplicity, comparability, and risk sensitivity of bank capital standards. For example, previous standards allowed banks more leeway in the way they modeled the risks of their assets (to help determine how much regulatory capital to hold to offset the risks). The Committee, including U.S. members, prioritized reforms that constrained banks' use of internal models to help increase the comparability of risk-weighted assets across banks. GAO's analysis of U.S. documents showed that U.S. members participated actively in the working groups that developed the standards to further their reform priorities. Why GAO Did This Study The Basel Committee released initial Basel III standards in 2010, followed by additional reforms that resulted in final Basel III standards in 2017 and 2019. These updated standards, which have not yet been implemented in the U.S., revised methods for estimating a bank's risks, which affect its regulatory capital requirements. GAO was asked to review U.S members' actions during the final Basel III negotiations. This report examines (1) how the Basel Committee organized the work to develop the standards, (2) information and analyses U.S. members considered to inform their positions, and (3) U.S. members' priorities for reform and actions taken to further those priorities. This is the public version of a sensitive report GAO issued in December 2024. Information on U.S. members' actions during the development of the standards and their positions on reforms has been omitted. GAO analyzed U.S. members' internal sensitive documents related to the development of the standards. These included internal briefing notes, talking points, analyses, and other documents prepared for the negotiations during 2011–2019. GAO also analyzed Basel Committee consultative documents, quantitative impact studies, other publicly released documents, and the final Basel III standards. GAO interviewed officials from the four U.S. members responsible for the final Basel III negotiations and Basel Committee Secretariat staff (who support the work of the Committee and its component groups). For more information, contact Michael Clements at clementsm@gao.gov.

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