The Results Act: Observations on the Office of Management and Budget's
July 1997 Draft Strategic Plan (Correspondence, 08/21/97,
GAO/AIMD/GGD-97-169R).

Pursuant to a congressional request, GAO reviewed the draft strategic
plan submitted by the Office of Management and Budget (OMB), as required
by the Government Performance and Results Act of 1993.

GAO noted that: (1) OMB's strategic plan provides a beginning framework
to articulate how OMB proposes to meet the wide range of presidential,
congressional, and federal agency expectations for its leadership on
federal budget and management issues; (2) the plan includes four of the
elements required by the Results Act--a mission statement, long-term
goals and objectives, strategies to achieve the goals and objectives,
and key external factors--but these elements could be enhanced to better
reflect the purposes of the Results Act and to permit an assessment of
OMB's contribution to the many objectives the agency serves; (3) for
instance, while defining specific results for OMB's role as presidential
advisor is challenging, a more explicit definition of expected results
and accomplishments for many of OMB's objectives could better highlight
its priorities and goals, particularly for governmentwide management
responsibilities; (4) similarly, the draft plan could be strengthened by
more explicitly describing how goals are to be achieved, in many cases
drawing on strategies OMB has articulated in other documents; (5)
achieving many of the objectives in the draft plan will require
attention to several critical crosscutting and organizational issues;
(6) strategies for addressing governmentwide management issues, such as
computer security, agencies' Year 2000 programs to change computer
systems to accommodate dates beyond 1999, and reorientation of the
regulatory process toward achievement of results, are not fully
discussed in the draft plan; (7) addressing crosscutting goals depends
heavily on collaboration between affected federal agencies, and the
draft plan could more explicitly define OMB's strategies for promoting
such interagency coordination; (8) the draft plan also does not discuss
how OMB will use evaluations to develop and assess progress toward its
own goals or how it will use and encourage agencies' program evaluations
to help make more informed budget and management choices; (9) moreover,
the draft plan does not describe how OMB will ensure that it has the
organizational capacity to provide the multidisciplinary leadership
needed to address critical budget and managerial issues; and (10) it is
important that OMB continue its ongoing efforts to refine its draft
strategic plan to provide a road map for achieving its own objectives
and a model for other agencies to follow as they develop their own
strategic plans.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD/GGD-97-169R
     TITLE:  The Results Act: Observations on the Office of Management 
             and Budget's July 1997 Draft Strategic Plan
      DATE:  08/21/97
   SUBJECT:  Strategic planning
             Presidential budgets
             Interagency relations
             Congressional/executive relations
             Agency missions
             Program evaluation
             Public administration
             Financial management systems
             Internal controls
             Information resources management
IDENTIFIER:  OMB 2000
             OMB Year 2000 Program
             
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Cover
================================================================ COVER



September 1997


GAO/AIMD/GGD-97-169R

OMB's Draft Strategic Plan

(935240/410179)


Abbreviations
=============================================================== ABBREV

  BOP - Federal Bureau of Prisons
  CFO - Chief Financial Officers
  DEA - Drug Enforcement Administration
  DOJ - Department of Justice
  FBI - Federal Bureau of Investigation
  INS - Immigration and Naturalization Service
  NPR - National Performance Review
  OMB - Office of Management and Budget

Letter
=============================================================== LETTER


B-277789

August 21, 1997

The Honorable Richard K.  Armey
Majority Leader
House of Representatives

The Honorable John R.  Kasich
Chairman
Committee on the Budget
House of Representatives

The Honorable Dan Burton
Chairman
Committee on Government Reform and Oversight
House of Representatives

The Honorable Bob Livingston
Chairman
Committee on Appropriations
House of Representatives

Subject:  The Results Act:  Observations on the Office of Management
and Budget's July 1997 Draft Strategic Plan

On June 12, 1997, you asked us to review the draft strategic plans
submitted by the cabinet departments and selected major agencies for
consultation with the Congress as required by the Government
Performance and Results Act of 1993 (the Results Act).  This letter
is our response to that request concerning the Office of Management
and Budget (OMB). 

In reviewing OMB's draft plan, it is important to recognize that the
agency has two distinct but parallel roles.  OMB supports the
President by preparing the President's budget, coordinating the
President's legislative agenda, and providing policy analysis and
advice.  This role poses certain challenges in designing measurable,
results-oriented goals and specific performance measures.  Many
statutes have also assigned to OMB a leadership role for a variety of
governmentwide responsibilities in areas such as financial,
information resources, and general management as well as regulatory
and procurement policy.  For example, OMB is responsible for
overseeing implementation of the Results Act, and its guidance forms
an essential part of the criteria against which we have evaluated its
and other agencies' draft strategic plans. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :1

Specifically, you asked us to review OMB's draft plan and assess (1)
whether it would fulfill the requirements of the Results Act and its
overall quality, (2) whether it reflects OMB's key statutory
authorities, (3) whether it reflects interagency coordination for
crosscutting programs, activities, or functions that are similar to
or complementary with those of other federal agencies, (4) whether it
addresses management problems that we have previously identified, and
(5) the adequacy of OMB's data and information systems for providing
reliable information for measuring results. 

OMB prepared a draft strategic plan based on Results Act
requirements, and we analyzed the version of the plan that OMB
provided to congressional committees on July 23, 1997.  Our overall
assessment of this plan was based on our knowledge of OMB's
operations and programs, our past reviews of OMB, and other existing
information available at the time of our assessment.  The criteria we
used to determine whether OMB's draft strategic plan would comply
with the requirements of the Results Act were the act itself,
supplemented by OMB's guidance to agencies on developing strategic
plans (Circular A-11, Part 2, Preparation and Submission of Strategic
Plans and Annual Performance Plans).  To make judgments about the
overall quality of the draft plan and its components, we used our May
1997 guidance for congressional review of the plans as a tool.\1 As
requested, in determining whether OMB's draft strategic plan reflects
its major statutory responsibilities, we coordinated our review with
the Congressional Research Service.  To determine whether the draft
plan contained information on interagency coordination and addressed
management problems that we previously identified, we relied on our
general knowledge of OMB's operations and programs and the results of
our previous work.  Our work was performed in July and August 1997. 
We obtained comments on a draft of this letter from OMB.  These
comments are discussed in the "Agency Comments" section and are
reprinted in enclosure I. 

It is important to recognize that OMB's final plan is not due to the
Congress until September 30, 1997.  Furthermore, the Results Act
anticipated that it may take several planning cycles to perfect the
process and that the final plan would be continually refined as
future planning cycles occur.  Thus, our findings reflect a snapshot
status of the plan at this time.  We recognize that developing a
strategic plan is a dynamic process and that OMB is continuing to
revise this draft with input from congressional staff and other
stakeholders. 


--------------------
\1 Agencies' Strategic Plans Under GPRA:  Key Questions to Facilitate
Congressional Review (GAO/GGD-10.1.16, May 1997). 


   BACKGROUND
------------------------------------------------------------ Letter :2

As a staff office to the President, OMB develops and executes the
federal budget, oversees implementation of the President's policies
and programs, and advises and assists the President.  It also
develops and oversees implementation of various governmentwide
legislative and administrative initiatives.  OMB was established
under presidential reorganization authority in 1970, in part to
increase the attention given to management issues in the federal
government.  In fiscal year 1996, OMB obligated $56 million and
employed over 500 staff. 

OMB plays a key role in both the presidential and congressional
budget processes.  In addition to preparing and submitting the
President's budget to the Congress, it monitors the congressional
budget process to assess how congressional budget decisions address
presidential policies.  Once the Congress appropriates funds, OMB
oversees the execution of budget authority to ensure compliance with
applicable laws and presidential policies.  The Budget Enforcement
Act of 1990, moreover, gives OMB authority to enforce enacted
spending ceilings and constraints. 

OMB also is responsible for ensuring the implementation of a number
of statutory management policies and initiatives.  Most importantly,
it is the cornerstone agency for overseeing a framework of recently
enacted financial, information resources, and performance management
reforms designed to improve the effectiveness and responsiveness of
federal agencies.  The Chief Financial Officers (CFO) Act of 1990
established CFOs in 24 major agencies to provide financial leadership
and mandated significant reforms, which include increasing the
accuracy of financial information, modernizing underlying systems,
developing reliable cost and performance data, integrating budget and
accounting information, and upgrading the quality of financial
management personnel.  The CFO Act also requires OMB to provide an
annual report on progress made in achieving the act's objectives. 
Additionally, the act established a Controller in OMB to head an
Office of Federal Financial Management as well as a Deputy Director
for Management within OMB to be the government's key official for
financial management.  Later, the Government Management Reform Act of
1994 expanded the CFO requirements by charging OMB with (1) providing
guidance for the annual preparation of financial statements by the 24
major federal agencies and (2) coordinating with the Secretary of the
Treasury in the preparation of audited governmentwide financial
statements. 

The original Paperwork Reduction Act (PRA) of 1980, as well as the
recent 1995 reauthorization, requires the Director of OMB to oversee
the use of information resources to improve the efficiency and
effectiveness of government operations.  Specifically, the 1995 act
requires the Director, in consultation with agency heads, to set
annual goals for reducing information collection burdens imposed on
the public and for improving agencies' use of information resources
to increase the productivity, efficiency, and effectiveness of their
programs.  The Director is also to report to the Congress each year
on how well agencies have achieved their goals.  The Clinger-Cohen
Act of 1996 builds on the PRA by making the Director of OMB
responsible for improving the acquisition and use of information
technology by federal agencies and for developing, as part of the
budget process, a process for OMB to use in analyzing, tracking, and
evaluating the risks and results of all major capital investments for
agency information systems. 

Under the Results Act, OMB is charged with overseeing and guiding
agencies' strategic and annual performance planning and reporting and
is responsible for preparing an annual governmentwide performance
plan that presents a single cohesive picture of federal performance
goals.  The act also required OMB to designate pilot projects on
performance measurement, managerial accountability and flexibility,
and performance budgeting and prepare a summary on the results of the
pilot projects. 

OMB has responsibilities for other management policies as well.  The
Federal Acquisition Streamlining Act, for instance, requires that
executive agency heads set cost, performance, and schedule goals for
major acquisition programs and that OMB report to the Congress on
agencies' progress in meeting these goals.  Under the PRA, the
Director of OMB is assigned several responsibilities related to
federal information collection and dissemination, including reviewing
and approving proposed agency collections of information and
developing and overseeing the implementation of governmentwide
policies on statistical data. 

In addition to its statutory management responsibilities, OMB is also
responsible for implementing presidential initiatives set forth in
executive orders and directives.  For example, Executive Order 12866
directs OMB to coordinate the review of agencies' rules and
regulations to ensure that they impose the least burden, are
consistent between agencies, focus on results over process, and are
based on sound cost/benefit analysis.  Since 1967, OMB has been
responsible, through its Circular A-76, for carrying out executive
branch policy to rely on competition between the federal workforce
and the private sector for providing commercial goods and services. 

OMB faces perennial challenges in carrying out these management
responsibilities in an environment where its budgetary role
necessarily remains a vital and demanding part of its mission.  At
one time, its management functions were carried out largely by
separate staff units.  In 1994, OMB undertook a major reorganization
and process change, known as OMB 2000, intended to integrate OMB's
budget analysis, management review, and policy development roles. 
OMB 2000 created resource management offices (RMOs) that are assigned
integrated responsibilities for examining agency management, budget,
and policy issues and overseeing agency implementation.  The RMOs are
supported by three statutory offices that are responsible for
developing governmentwide management policies:  the Office of Federal
Financial Management, the Office of Federal Procurement Policy, and
the Office of Information and Regulatory Affairs. 

Under the Results Act, executive agencies are required to develop (1)
strategic plans covering a period of at least 5 years by September
30, 1997, (2) annual performance plans for fiscal year 1999 and
beyond, and (3) annual performance reports, with the first report due
by March 31, 2000.  Each strategic plan is to include six elements: 
(1) a comprehensive agency mission statement, (2) long-term goals and
objectives for the major functions and operations of the agency, (3)
approaches or strategies to achieve goals and objectives and the
various resources needed to do so, (4) the relationship between
long-term goals/objectives and annual performance goals, (5) an
identification of key external factors beyond agency control that
could significantly affect achievement of strategic goals, and (6) a
description of how program evaluations were used to establish or
revise strategic goals and a schedule for future program evaluations. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :3

OMB's strategic plan provides a beginning framework to articulate how
OMB proposes to meet the wide range of presidential, congressional,
and federal agency expectations for its leadership on federal budget
and management issues.  The plan includes four of the elements
required by the Results Act--a mission statement, long-term goals and
objectives, strategies to achieve the goals and objectives, and key
external factors--but these elements could be enhanced to better
reflect the purposes of the Results Act and to permit an assessment
of OMB's contribution to the many objectives the agency serves.  For
instance, while defining specific results for OMB's role as
presidential advisor is challenging, a more explicit definition of
expected results and accomplishments for many of OMB's objectives
could better highlight its priorities and goals, particularly for
governmentwide management responsibilities.  Similarly, the draft
plan could be strengthened by more explicitly describing how goals
are to be achieved, in many cases drawing on strategies OMB has
articulated in other documents.  For example, the Congress and the
President might be better able to determine OMB's ability to meet its
objective of ensuring clean audit opinions on financial statements if
specific actions to achieve this objective, such as those in OMB's
federal financial management status report and 5-year plan, were
identified. 

Achieving many of the objectives in the draft plan will require
attention to several critical crosscutting and organizational issues. 
Strategies for addressing governmentwide management issues, such as
computer security, agencies' Year 2000 programs to change computer
systems to accommodate dates beyond 1999, and reorientation of the
regulatory process toward achievement of results, are not fully
discussed in the draft plan.  Addressing crosscutting goals depends
heavily on collaboration between affected federal agencies, and the
draft plan could more explicitly define OMB's strategies for
promoting such interagency coordination.  The draft plan also does
not discuss how OMB will use evaluations to develop and assess
progress toward its own goals or how it will use and encourage
agencies' program evaluations to help make more informed budget and
management choices.  Moreover, the draft plan does not describe how
OMB will ensure that it has the organizational capacity to provide
the multidisciplinary leadership needed to address critical budget
and management issues.  It is important that OMB continue its ongoing
efforts to refine its draft strategic plan to provide a road map for
achieving its own objectives and a model for other agencies to follow
as they develop their own strategic plans. 


   OMB'S DRAFT STRATEGIC PLAN
   INCLUDES FOUR OF SIX REQUIRED
   ELEMENTS, BUT ENHANCEMENTS
   COULD BE MADE
------------------------------------------------------------ Letter :4

OMB's draft plan includes elements addressing its mission, goals and
objectives, strategies, and key external factors affecting its goals,
but enhancements could help make the plan more useful in guiding OMB
and serving as a basis for assessing the agency's performance.  For
example, more explicit discussions of the expected results and
accomplishments for many of OMB's objectives could better highlight
its strategies and priorities as well as permit a more informed
analysis of the agency's contributions to public budgeting and
management.  The plan does not meet Results Act requirements for two
elements required under the Results Act:  (1) the relationship
between the long-term and annual performance goals and (2) the use of
program evaluation in developing goals. 


      MISSION STATEMENT
---------------------------------------------------------- Letter :4.1

The Results Act requires that each strategic plan contain a
comprehensive mission statement covering the major functions and
operations of the agency.  According to OMB Circular A-11, Part 2,
the statement should define the basic purpose of the agency, with a
particular focus on its core programs and activities.  The guidance
also notes that the mission statement may include a concise
discussion of enabling or authorizing legislation. 

OMB's mission statement begins with a description of its role--"to
help the President in carrying out his constitutional and statutory
duties." The statement then lists the agency's principal
functions--policy-making, overseeing execution of laws, and advising
the President--and ends with the statement, "Simply put, OMB helps to
create policy and manage execution, and provides analysis and
advice." Throughout this mission statement, there is no reference to
broader results that OMB seeks to achieve or has been directed to
achieve through legislation or presidential decision.  Specifically,
the plan would be more useful if OMB explicitly stated the linkage
between what it does and what it wants to achieve. 

Because hundreds of statutory authorities and executive orders have
assigned various responsibilities to OMB, the draft plan's mission
statement is broad and general in its discussion of OMB's purpose. 
OMB could consider providing additional specificity to its mission
statement as the plan is further revised by, for example, discussing
the major results expected from key governmentwide management
statutes.  The breadth of OMB's mission makes it especially important
that OMB develop well-defined and results-oriented goals and
objectives that address OMB's roles in both serving the President and
overseeing the implementation of statutory governmentwide management
policies. 


      LONG-TERM GOALS AND
      OBJECTIVES
---------------------------------------------------------- Letter :4.2

Under the Results Act, a strategic plan is to list general goals and
objectives, including outcome-related goals and objectives, for the
major functions and operations of the agency.  OMB's guidance states
that the plan should contain long-term programmatic, policy, and
management goals for the agency and outline planned accomplishments
and the schedule for their implementation.  The guidance further
provides that goals and objectives, even if not quantifiable, should
be stated in a manner that will allow a future assessment of whether
the goals were or are being achieved. 

Developing results-oriented goals for OMB will be challenging but
critical.  Many of OMB's responsibilities involve coordinating or
facilitating the work of others to achieve an end.  Although OMB may
not control an outcome, its actions will, and are expected to,
influence the results.  Similarly, some of OMB's activities, such as
developing the President's budget or coordinating the
administration's legislative program, present challenges for defining
quantifiable performance measures and implementation schedules. 
Following the guidance in Circular A-11, the plan's goals need not
all be quantitative, but they should be expressed in a manner
permitting subsequent assessment. 

OMB's draft plan sets four goals:  (1) assist the President in
creating policies that allocate resources within the federal
government, and establish legislative and regulatory programs to
achieve fiscal, economic, and investment goals in a cost-effective
manner, (2) ensure the faithful execution of the enacted budget,
programs, regulations, and policies, (3) assist the President by
providing analysis and advice on other significant issues, and (4)
improve OMB's development and use of its human resources and enhance
its means of accomplishing work.  Each goal is supported by three or
more objectives. 

Some of OMB's goals and objectives articulate explicit results and
can be evaluated to determine if they have been achieved.  For
example, one objective is to achieve and sustain the agreement to
balance the budget by 2002.  OMB also commits to assuring reliable
financial information capable of generating clean audit opinions on
financial statements. 

Other objectives, such as assisting the President in developing the
budget and legislative agenda, could be stated in a more
results-oriented manner.  OMB has objectives espoused outside this
strategic plan that could guide budget preparation.  For example, a
stated goal of OMB 2000 was to integrate the review of management
issues in the budget process--a goal that is amenable to assessment,
as suggested by our 1995 report.\2 Further specification of the draft
plan's budget preparation goal could include the use of financial
statement data in budget reviews where appropriate and the use of
investment criteria when reviewing information technology
projects--both objectives OMB has articulated in other published
documents.\3 Another potential budget preparation activity that could
be included in a strategic plan involves the analyses OMB conducts
for the Analytical Perspectives volume of the President's budget
covering such areas as public investment, credit programs, tax
expenditures, and the long-term outlook for the budget and the
economy; OMB could articulate the kinds of issues that will become
the focus of future analyses.  OMB's responsibility for overseeing
the implementation of accrual-based estimates under the Federal
Credit Reform Act of 1990 could also be presented as a strategic
activity with significant implications for the budget estimation
function. 

The plan does state several other objectives with a bearing on budget
preparation and review, including providing for capital planning and
addressing programs with similar goals spanning multiple agencies. 
For capital planning, no specific accomplishments or schedules are
articulated in the plan.  In guidance to agencies, however, OMB has
developed an extensive set of criteria for the development and review
of agency capital plans and has articulated a potentially measurable
standard of up-front funding for capital items.\4 With regard to
multiple programs, the objective is not sufficiently specified to
indicate which areas OMB plans to address or what criteria it has in
mind for improving overall program effectiveness. 

Identifying results-oriented goals and objectives and needed
accomplishments is especially important to determine whether OMB's
statutory management mandates are being achieved.  For example, OMB
reflects its specific statutory responsibilities for overseeing the
use of information resources to improve the efficiency and
effectiveness of government operations in a single objective to
"obtain agency solutions to identified mission-critical problems
including the effective and efficient use of information and
information technology by agencies to support their mission." This
objective could be strengthened if it briefly described related
problems or issues and relevant statutory authorities as well as a
concise schedule and accomplishments needed to fulfill OMB's
statutory responsibilities in this area.  OMB's strategy for
overseeing sound technology investments under the Clinger-Cohen Act
could be discussed, including how OMB will evaluate the results of
and enforce accountability for agency investment decisions. 

Similarly, OMB's Office of Federal Procurement Policy (OFPP) is by
law responsible for prescribing governmentwide procurement policies
and providing leadership, coordination, and oversight in the
formulation and implementation of executive branch positions on
procurement-related issues.  It also has responsibility for (1)
overseeing the collection, development, and dissemination of
procurement data through the Federal Procurement Data System and (2)
developing innovative procurement methods and procedures to be tested
by selected executive agencies.  OMB reflects these authorities in
one objective--to "achieve savings, improve quality, and increase
customer satisfaction in agency procurement programs"--without
providing a brief discussion of accomplishments needed to fulfill its
statutory responsibilities. 


--------------------
\2 Office of Management and Budget:  Changes Resulting From the OMB
2000 Reorganization (GAO/GGD/AIMD-96-50, December 29, 1995). 

\3 See, for example, the OMB documents Evaluating Information
Technology Investments (November 1995) and Federal Financial
Management Status Report and Five-Year Plan (June 1997). 

\4 See, for example, OMB Circular A-11, Part 3 (June 1997). 


      STRATEGIES TO ACHIEVE GOALS
      AND OBJECTIVES
---------------------------------------------------------- Letter :4.3

The Results Act requires that each strategic plan describe how the
long-term goals and objectives are to be achieved, including a
description of the processes, skills and technology, and other
resources required to meet the goals and objectives.  OMB's guidance
also states that agencies are to include schedules for completing
significant actions and any underlying assumptions or projections. 
The guidance states that this section of the plan should outline the
process for communicating goals and objectives throughout the agency
and for assigning accountability to managers and staff to achieve
objectives. 

In narrative following each goal statement, OMB describes some
general strategies, such as issuing guidance and reviewing
regulations, that will be used to achieve its goals.  For certain
policy-making and advisory goals, this description may be all that is
needed to explain how goals and objectives will be achieved. 
However, for goals related to long-term management responsibilities,
the plan could be strengthened by adding a concise, organized
statement of actions and resources needed to achieve a specific goal
or objective.  For example, OMB could mention the specific
initiatives it is using to promote objectives, such as the effective
utilization of personnel across the government and achieving savings
and quality improvements in procurement.  Clarifying and linking
strategies to goals and objectives is especially important because
achieving many of OMB's goals depends on its acting in concert with
other agencies. 

OMB's draft plan briefly describes overall resource requirements and
refers the reader to separate capital and operating plans for details
on the information technology and human resource capabilities needed
to achieve its goals.  The draft plan is predicated on an assumption
of stable funding and staffing levels and emphasizes the need for a
high-quality, diverse staff and the wise use of human, financial, and
technological resources.  However, the draft plan does not discuss
whether any specific technology or training initiatives will be
necessary.  For example, OMB's effectiveness in overseeing the
implementation of recent federal IRM reforms will depend greatly on
its staff's capacity to produce sound evaluations of the agencies'
information technology investment portfolios.  The draft plan does
not indicate that any major training or outside support is needed to
build this capacity. 

OMB's strategies generally are not associated with defined time
frames.  Although such time frames may be statutorily- or
self-defined for regular activities such as budget preparation and
policy advising, they are needed for determining progress in
achieving the longer-term expectations of statutory mandates.  The
draft plan could be improved if critical actions among its many
activities were identified and ordered into steps needed to achieve a
goal or objective.  For example, in its 5-year plan on governmentwide
efforts related to financial management, OMB has identified
priorities and milestones for its CFO Act efforts, but these
priorities and milestones are not mentioned or referred to in OMB's
draft strategic plan.\5

While OMB's draft plan indicates that staff and managers were
involved in developing goals and strategies, it is not clear (1) how
the final goals and strategies will be communicated throughout OMB or
to other agencies and (2) how managers and staff will be held
accountable.  An OMB strategic plan steering group invited all staff
to meetings on identifying strategic issues, and OMB held a
"standdown day" where staff devoted a day to discussing their units'
operating plans and the draft strategic plan.  However, OMB's draft
plan does not explain how managers and staff, or other agencies, will
be made aware of and held accountable for the goals that are
ultimately developed.  As a result of OMB's reorganization (OMB 2000)
and various governmentwide management reform legislation, OMB's staff
and managers have a wide, expanded scope of responsibilities.  They
also generally have more influence than control over the ultimate
outcome of OMB's work.  Additionally, many of OMB's goals depend on
concerted actions with other agencies, but little mention is made of
strategies to leverage the actions of other agencies to achieve OMB's
goals.  In this operating environment, communicating results and
priorities, and assigning responsibility for achieving them, are
critical. 


--------------------
\5 See Federal Financial Management Status Report and Five-Year Plan
(June 1997). 


      RELATIONSHIP BETWEEN
      LONG-TERM GOALS AND
      OBJECTIVES AND ANNUAL
      PERFORMANCE GOALS
---------------------------------------------------------- Letter :4.4

The Results Act requires that each strategic plan describe how the
agency's annual performance goals will be related to its general, or
long-term, goals and objectives.  OMB guidance states that agencies
should briefly outline (1) the type, nature, and scope of the
performance goals to be included in a performance plan, (2) the
relation between the performance goals and the long-term goals and
objectives, and (3) the relevance and use of performance goals in
helping determine the achievement of long-term goals and objectives. 

Especially for OMB's statutory responsibilities, linking long-term
goals and objectives and annual performance goals can (1) help
clarify the meaning of its long-term goals and objectives and (2)
ensure that OMB's day-to-day operations produce desired long-term
results.  The section of OMB's draft plan entitled, "Relation of
Annual Performance Goals to General Goals and Objectives," states
OMB's capability to meet its goals and measure its performance, but
it does not describe any relationship between annual and long-term
goals. 

However, other sections of the draft plan discuss selected
performance measures for each of the long-term goals that might form
the basis for annual goals.  For example, OMB lists several
performance measures for its goal of ensuring "faithful execution of
the enacted budget, programs, regulations and policies," including
the number of agency strategic plans that comply with the Results Act
and the receipt of clean audit opinions on agency and governmentwide
financial statements.  Each of these measures could be associated
with specific performance indicators during the development of the
annual performance plan.  It can be expected that the relationship
between long-term and annual performance goals will be further
defined as the Results Act planning process continues. 


      KEY EXTERNAL FACTORS
---------------------------------------------------------- Letter :4.5

The Results Act stipulates that the strategic plan must identify
those key factors external to the agency and beyond its control that
could significantly affect the agency's ability to achieve its goals
and objectives.  OMB's guidance states that these factors may be
economic, demographic, social, or environmental and may result from
action by the Congress, other federal agencies, states, local
governments, or other nonfederal entities.  The guidance states that
the strategic plan is to briefly describe each key external factor,
indicate its link with a particular goal, and describe how each
factor could affect achievement of a goal. 

Throughout its draft plan, OMB acknowledges that its work is affected
by several outside factors.  For example, OMB recognizes that
national economic circumstances, as well as different views about the
appropriate roles of government, can affect such goals as assisting
the President in resource allocation and fiscal and economic
policy-making.  However, OMB's plan does not consistently or
completely discuss important external factors.  For instance, the
plan does not discuss the potential influence that the Federal
Reserve Board or international economic developments can have in
achieving fiscal and economic policies.  With regard to OMB's goal of
executing statutory management policies, the plan could discuss the
need for the Congress to actively support the use of performance
measures in budget decisions and the impact of rapidly changing
technologies on agency information resources management. 

For each goal, the plan discusses major barriers to achievement. 
Some of these barriers include agency administrative capacity and
cooperation and the diversion of OMB staff to temporal crises. 
Although these factors clearly constitute barriers to the achievement
of several goals, it is not clear that they are invariably beyond
OMB's control or influence.  The short-term pressures of the budget
process clearly absorb significant staff and management attention
within OMB, but the strategic plan can outline approaches to help
sustain policy and management priorities in this environment.  For
example, in fiscal year 1996, the OMB Director articulated clear
priorities for OMB's examiners to consistently address agencies'
streamlining plans and performance information throughout that budget
cycle, and our evaluation showed that this direction transcended
immediate budgetary concerns and resulted in greater attention to
management issues.\6 Statutory offices, such as the Office of Federal
Financial Management and the Office of Information and Regulatory
Affairs, also provide the expertise and longer-term focus to address
certain key policy and management issues throughout the year.  With
regard to agency cooperation, OMB could discuss in its draft plan how
it uses such mechanisms as councils, task forces, and the engagement
of agency Inspectors General to gain agency input and support. 


--------------------
\6 GAO/GGD/AIMD-96-50, December 29, 1995. 


      PROGRAM EVALUATION
---------------------------------------------------------- Letter :4.6

Under the Results Act, agencies' strategic plans are to describe the
program evaluations used in establishing or revising long-term goals
and objectives, with a schedule for future program evaluations. 
Program evaluation is defined by the Results Act as an assessment,
through objective measurement and systematic analysis, of the manner
and extent to which federal programs achieve their intended
objectives.  According to OMB guidance, the strategic plan should
describe the evaluations that were used in preparing the plan and
outline the general scope and methodology for future evaluations, key
issues to be addressed, and when such evaluations are to occur. 

OMB's draft plan does not provide a description of program
evaluations used to prepare the plan nor does it include a schedule
for future program evaluations.  In its draft plan, OMB states that
it does not administer programs and, therefore, "no program
evaluations, as that term is usually defined, were available for use
in preparing the plan." OMB's plan, however, could address the need
for program evaluations in at least two ways.  First, OMB could
address evaluations of its own internal operations and programs. 
Second, OMB could be considered a consumer of agencies' program
evaluations to better inform its resource allocation role and, in
this capacity, could become a catalyst to enhance agencies'
evaluation capabilities. 

Evaluations are especially critical for OMB because it is charged
with overseeing and implementing some of the most critical managerial
functions of government.  Such evaluations can provide a critical
source of information for the Congress and others to ensure the
validity and reasonableness of OMB's goals and strategies and to
identify factors likely to affect the results of programs and
initiatives overseen by OMB.  In recent years, we have conducted
assessments of OMB's functions or programs, with particular emphasis
on its management role and the factors associated with sustaining
attention to management issues in the budget process.\7

Additionally, OMB's draft plan discusses a number of activities that
would benefit from program evaluation.  The draft plan states that
issuing guidance to agencies is one strategy for its goal of ensuring
the faithful execution of the enacted budget, programs, regulations,
and policies.  However, the draft plan is silent on whether OMB will
assess the effectiveness of its guidance to agencies.  For example,
the policy of contracting out to the private sector for providing
commercial goods and services is embodied in OMB Circular A-76.  This
circular's effectiveness has been questioned both in the executive
branch and in dozens of congressional hearings.  Because OMB views
Circular A-76 as a tool for achieving needed efficiencies in agency
operations, an assessment of its effectiveness would help determine
how this guidance is working and whether other changes are needed. 

OMB is also statutorily required to undertake evaluations similar to
those intended under the Results Act.  For example, the Paperwork
Reduction Act of 1995 requires the Director of OMB to "evaluate
statistical program performance and agency compliance with
Governmentwide policies, principles, standards, and guidelines."
Further, the act requires OMB, in conjunction with four other federal
agencies, to assess the efficiency and effectiveness of agency IRM
activities.  The Federal Financial Management Improvement Act of 1996
requires the Director of OMB to submit an annual report to the
Congress regarding implementation of the act.  None of these
evaluation-related requirements are explicitly mentioned in OMB's
draft strategic plan. 

OMB's draft plan could also discuss how it will use agencies' program
evaluations to further its goals in both budgeting and management. 
Improving program evaluation across government is vital for promoting
more informed budget choices in an environment of scarce resources. 
As we have reported earlier this year,\8 the lack of results-oriented
performance information will hamper Results Act implementation. 
Furthermore, our review of other agencies' draft strategic plans
showed that many agencies had not yet addressed the need for program
evaluations in their plans. 


--------------------
\7 See, for example, GAO/GGD/AIMD-96-50, December 29, 1995, and
Managing the Government:  Revised Approach Could Improve OMB's
Effectiveness (GAO/GGD-89-65, May 4, 1989). 

\8 The Government Performance and Results Act:  1997 Governmentwide
Implementation Will Be Uneven (GAO/GGD-97-109, June 2, 1997). 


   DRAFT PLAN GENERALLY REFLECTS
   MOST OF OMB'S KEY STATUTORY
   AUTHORITIES
------------------------------------------------------------ Letter :5

OMB's draft strategic plan generally reflects and identifies many of
OMB's key statutory authorities, but it could be improved if the
goals and objectives were more clearly linked to the underlying
statutory authorities upon which they rest.  For the most part, the
draft plan focuses much more on OMB's responsibilities to advise and
assist the President and on its managerial and policy-making roles
than it does on the specific statutory requirements OMB must carry
out.  While the former responsibilities are critically important, the
draft plan could be improved if it contained an enhanced discussion
and reflected greater recognition of the specific statutory mandates
for which OMB is responsible. 


   CROSSCUTTING ISSUES COULD BE
   MORE FULLY DISCUSSED
------------------------------------------------------------ Letter :6

OMB's draft plan states that achieving its goals and objectives
depends heavily on "input from and the collaborative efforts of all
Federal agencies." Many of OMB's activities, in addition to its
annual collaboration with agencies to prepare the President's Budget,
involve coordination with other agencies or facilitating coordination
among agencies to address crosscutting issues.  Crosscutting issues
have several dimensions for OMB.  OMB must engender the cooperation
of all agencies to achieve many key goals, such as financial and
information management.  For certain policies, OMB shares leadership
responsibility with one or more agencies, requiring collaborative
approaches to promote goals.  Finally, several issues OMB must
address are interrelated and require cooperation across various
offices and functions within OMB. 

Crosscutting goals and objectives require concerted efforts and
strategies, but it is unclear whether OMB coordinated with other
agencies in preparing this draft plan.  OMB's description of its
draft plan development process does not mention that its plan was
shared with any other agencies or that any external stakeholders were
consulted.  The draft plan also does not explicitly mention
coordination with other agencies that have related functions.  For
example, OMB's draft plan could recognize that other entities--for
example, the Department of the Treasury; the National Economic
Council; and the administration's major management improvement
initiative, the National Performance Review; and two other central
management agencies, the Office of Personnel Management and the
General Services Administration--share its mission of creating
policy, managing execution, and providing analysis and advice to the
President. 

When OMB's goals or objectives point to coordinated efforts, OMB's
draft plan could be strengthened by referencing the plans of other
agencies and by discussing strategies to gain the cooperation and
support of these agencies.  For example, the Paperwork Reduction Act
of 1995 requires the Director of OMB, in consultation with agency
heads, to (1) set annual governmentwide goals for reducing
information collection burdens by at least 10 percent during each of
fiscal years 1996 and 1997 and 5 percent during each of fiscal years
1998, 1999, 2000, and 2001 and (2) set annual agency goals for
reducing information collection burdens on the public to the maximum
extent practical.  Although one of OMB's objectives is to review
current and proposed policies to ensure consistency with the
President's information collection policy priorities, the draft plan
does not describe how OMB will ensure burden reduction goals are
incorporated in agencies' plans and hold agencies accountable for
their actions to meet these agency burden reduction goals. 

OMB's draft plan could better describe how it will achieve the
coordination needed to address other crosscutting issues as well.  In
the financial management area, the draft plan articulates the
objective of improving financial management information to attain
clean audit opinions.  However, it does not discuss OMB's role and
specific goals in working with agencies to improve financial
management practices throughout the government.  A separate document,
the Federal Financial Management Status Report and Five-Year Plan,
contains objectives and strategies that OMB might draw from for its
strategic plan.  This financial management plan discusses strategies
for working with agencies, councils, and other groups and sets
specific objectives and milestones for financial management reform. 
For example, the financial management plan proposes such specific
tasks as issuing guidance on managerial cost accounting system
requirements, training agencies to implement audit guidance, and
providing guidance for the forthcoming governmentwide financial
statement audit.  OMB's strategic plan could note whether OMB intends
to review agencies' strategic and financial management plans to
ensure its financial management objectives are also reflected in
agency plans. 

In the information management area, the draft plan proposes to
promote effective and efficient use of information resources but does
not discuss how it will work with agencies to resolve critical
crosscutting issues.  OMB does not describe its strategy for carrying
out its expanded responsibilities in overseeing the effective
implementation of PRA and the Clinger-Cohen Act and for addressing
specific issues, such as agencies' Year 2000 programs to change
computer systems to accommodate dates beyond 1999 and information
security.  We have previously reported on actions OMB needs to take
to implement sound technology investment in federal agencies.\9
Additionally, given the urgent need to accelerate federal agencies'
year 2000 programs, the plan can specify how OMB intends to monitor
critical aspects of this problem.  Similarly, in light of the
increasing importance of information security and the widespread
security problems that have already emerged, we have previously
suggested that OMB, as chair of the Chief Information Officers
Council, take the lead in prompting agencies to identify weaknesses
and take corrective actions.\10

In the regulatory management area, the draft plan notes that OMB
reviews agencies' regulations and conducts certain analyses, but does
not fully discuss what those reviews and analyses are intended to
achieve.  The draft plan states that OMB seeks to maximize the public
benefits while minimizing the public burden of regulations and that
OMB reviews agency documents for consistency.  Additionally,
Executive Order 12866 gives OMB direct responsibility for ensuring
that agencies' regulations focus on results instead of process and
are based on sound economic analysis.  Delineating these kinds of
outcomes in OMB's plan would give the Congress and others clear
criteria that could be used to evaluate how well OMB is carrying out
its crosscutting regulatory management responsibilities. 

The draft plan does not discuss most of the 25 issues we have
identified as high risk because of vulnerabilities to waste, fraud,
abuse, and mismanagement.  OMB recently discontinued its high-risk
list because it determined that more progress could be made on these
issues by helping agencies focus on system changes and management
challenges.  The draft plan could specify how OMB will provide the
leadership needed to help resolve high-risk problems.  Although the
plan discusses some of OMB's responsibilities related to recent
management reform legislation, which, if implemented successfully,
will help resolve some of these problems, the high-risk areas involve
long-standing problems that can be corrected only with sustained
management attention and congressional oversight. 

Tackling crosscutting issues will also require extensive
collaboration between offices and functions within OMB, which the
plan could discuss in more detail.  The draft strategic plan contains
an objective to use internal interdisciplinary and interagency work
groups to address issues in more depth but does not provide any
specific strategies for or areas where these groups will be used. 
OMB recognized the importance of integrating management into the
budget process through its 1994 reorganization where RMOs were
assigned responsibilities for examining agency management issues
during the budget review process. 

Recent statutory management initiatives will challenge OMB to mount
an effective organizationwide effort.  For example, collaboration
across units within OMB will be necessary to bring financial
information systems into compliance with both the Federal Financial
Management Improvement Act and the Clinger-Cohen Act.  We have
testified that the performance information produced by the Results
Act will be most useful to congressional and executive branch
decisionmakers if it is integrated with accurate cost data drawn from
agency financial accounting systems; OMB has efforts underway to
develop accountability reports that consolidate and integrate the
separate reporting requirements of the Results Act, CFO Act, and
other specified acts that could be discussed in its plan.  Similarly,
preparation of the governmentwide performance plan under the Results
Act, due in early 1998, will call for OMB to draw on expertise across
many units within the agency. 


--------------------
\9 In Information Technology Investment:  Agencies Can Improve
Performance, Reduce Costs, and Minimize Risks (GAO/AIMD-96-64,
September 30, 1996) and Information Management and Technology
(GAO/HR-97-9, February 1997), we reported that OMB needs to take
action on several fronts to help implement sound technology
investment decision-making processes at federal agencies, including
(1) requiring agencies to use explicitly defined criteria in deciding
what technology projects to fund, (2) ensuring that agencies'
technology investment control processes comply with the new
information resources management legislation and OMB guidance, (3)
improving OMB staff's capacity to analyze the soundness of the
agencies' technology portfolios, and (4) establishing an internal
evaluation process to determine whether its reviews of the agencies'
investment processes and results are having an effect on reducing the
risks and improving the returns on federal information technology
investments.  OMB's strategy for overseeing the implementation of the
IRM reforms should also include continuing to monitor the appointment
of chief information officers and their efforts to develop and
implement integrated agencywide information architectures; build
their agencies' capacity to acquire needed systems and deal with
emerging technology issues; and devise effective performance measures
for OMB to assess the progress their agencies are making in using
information technology to achieve stated goals. 

\10 See Information Security:  Opportunities for Improved OMB
Oversight of Agency Practices (GAO/AIMD-96-110, September 24, 1996). 


   MAJOR MANAGEMENT CHALLENGES ARE
   NOT FULLY ADDRESSED
------------------------------------------------------------ Letter :7

We and other organizations have evaluated OMB's ability to provide
leadership on critical budget and management issues.  Although some
of the major challenges we have raised are mentioned in the draft
plan, OMB could more specifically describe how these challenges will
be addressed. 

Our 1989 report on OMB\11 examined the agency's repeated
reorganizations and management improvement efforts and concluded that
OMB had been unable to coordinate its management and budget functions
effectively and had not established a stable management capacity.  We
found that OMB's short-term, budget-driven focus often made it
difficult for the agency to address long-term management problems. 
OMB's internal 1994 review of its operations reached similar
conclusions. 

We made recommendations to improve the agency's effectiveness in
addressing management and budget issues, and OMB has implemented some
of them.  For example, we recommended that a second Deputy Director
position be established to enhance OMB's leadership role on
management issues, and OMB has filled this position, which was
created by the CFO Act.  We also recommended that OMB budget
divisions be explicitly charged with overseeing agency implementation
of selected management improvement efforts, evaluating the
effectiveness of the management of individual agencies and programs,
and ensuring that corrective action is taken to solve identified
problems.  OMB's 1994 reorganization (OMB 2000) was intended to
integrate its budget analysis, management review, and policy
development roles. 

In our 1995 review of OMB 2000,\12 we observed that this approach has
the potential to improve the agency's capacity to address management
issues, but it will require a sustained focus to institutionalize an
integrated approach over the longer term.  We recommended that OMB
review the impact of its reorganization as part of its planned
broader assessment of its role in formulating and implementing
management policies for the government.  We suggested that the review
focus on specific concerns that need to be addressed to promote more
effective integration, including (1) the way OMB currently trains its
program examiners and whether this is adequate given the additional
management responsibilities assigned to these examiners and (2) the
effectiveness of the different approaches taken by OMB in the
statutory offices to coordinate with its resource management offices
and provide program examiners with access to expertise.  In
commenting on our recommendation, OMB agreed that its strategic
planning process offered opportunities to evaluate this initiative
and would address issues raised by the reorganization.  However, such
a review is not described in OMB's draft plan and neither of the two
concerns we raised is explicitly discussed.\13

Furthermore, OMB's draft plan does not discuss initiatives to improve
its working relationship with other federal agencies and the
Congress--a key factor in its ability to effectively carry out its
mission and responsibilities.  In our 1989 review of OMB's management
leadership, agency officials told us that OMB is most effective when
it serves as a catalyst and provides leverage for officials to get
attention within their agencies.  These officials also stressed the
importance of consistent communication and involvement of agency
officials in formulating policies.  A National Academy of Public
Administration study also supported a consultative relationship for
agencies and OMB.  As previously mentioned in this correspondence,
OMB is working in such a manner with various interagency councils,
and its draft plan could discuss more of these groups' initiatives
and responsibilities. 

Similarly, we found that obtaining congressional cooperation has been
an important factor in OMB's success.  Our discussions with
congressional staff in conducting the 1989 study indicated that OMB
could gain more support for its initiatives through earlier and more
frequent contact with the Congress and a clearer communication of its
priorities.  OMB's draft plan recognizes the need to work
cooperatively with the Congress but could specify what changes, if
any, it will seek in its relationship with the Congress. 


--------------------
\11 GAO/GGD-89-65, May 4, 1989. 

\12 GAO/GGD/AIMD-96-50, December 29, 1995. 

\13 For a discussion of other management challenges, see
GAO/GGD/AIMD-96-50, December 29, 1995. 


   CAPACITY TO PROVIDE RELIABLE
   INFORMATION ON ACHIEVEMENT OF
   GOALS
------------------------------------------------------------ Letter :8

OMB's draft plan indicates that it will need a variety of measures to
determine whether its goals are being achieved.  The draft plan
suggests that many of its goals will be measured qualitatively.  For
example, OMB suggests performance in identifying less effective
programs, improved personnel utilization, and timeliness of analysis
as potential performance indicators.  OMB will need reliable tracking
systems to support the performance indicators it chooses. 
Additionally, determining whether some of OMB's objectives, such as
savings in agency procurement programs, have been achieved will
depend on the quality of information generated by agencies'
information systems.  We have not reviewed OMB's financial and
information systems in recent years; therefore, we cannot comment on
the capacity of OMB's current systems or any plans to develop such
systems. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :9

We requested comments on a draft of this letter from the Director of
OMB.  On August 15, the OMB Acting Deputy Director for Management
provided written comments.  (A copy of those comments is included in
enclosure I.) OMB's comments characterized our letter as a
comprehensive assessment of OMB's draft strategic plan and said that
it contained constructive and helpful suggestions for improving the
plan.  OMB also commented on our observations regarding two elements
missing from its strategic plan:  (1) a description of the
relationship between general goals and objectives and annual
performance goals and (2) a discussion of the use of and future
schedule for program evaluations.  Our response to OMB's comments is
included in enclosure I. 


---------------------------------------------------------- Letter :9.1

As arranged with your offices, unless you publicly announce its
contents earlier, we plan no further distribution of this
correspondence until 30 days from its issue date.  At that time, we
will send copies to the Minority Leader of the House of
Representatives, the Ranking Minority Members of your Committees, and
the Director of the Office of Management and Budget.  We will also
send copies to the Chairmen and Ranking Minority Members of the
Senate Appropriations, Budget, and Governmental Affairs Committees. 
Copies will be made available to others upon request. 

Please contact Nye Stevens at (202) 512-8676 or Paul Posner at (202)
512-9573 if you or your staffs have any questions concerning this
letter.  Major contributors to this report are listed in enclosure
II. 

L.  Nye Stevens
Director, Federal Management and Workforce Issues

Paul L.  Posner
Director, Budget Issues

Enclosures




(See figure in printed edition.)Enclosure I
COMMENTS FROM THE OFFICE OF
MANAGEMENT AND BUDGET
============================================================== Letter 

end of this enclosure. 



(See figure in printed edition.)


The following are GAO's comments on the Office of Management and
Budget's letter dated August 15, 1997. 


   GAO'S COMMENTS
----------------------------------------------------------- Letter :10

1.  OMB commented on our observation that its draft plan did not
describe the relationship between general goals and objectives and
performance goals.  OMB said that its plan contains such a
description.  OMB also said that an additional description of this
relationship will be included in its annual performance plan.  OMB
noted that the strategic plan should outline the type, nature, and
scope of the annual performance goals, but it was not intended that
the plan present a comprehensive list of specific measures. 

We agree that strategic plans are not intended to provide
comprehensive listings of specific performance measures.  However,
our letter notes that the section of OMB's draft plan entitled
"Relation of Annual Performance Goals to General Goals and
Objectives" does not describe any relationship between annual and
long-term goals.  Thus, we continue to believe that OMB's plan could
be more useful if it discussed the relationship between the
performance goals and the long-term goals and objectives and the
relevance and use of performance goals in helping determine the
achievement of long-term goals and objectives. 

2.  OMB commented on our observation that its draft plan did not
include a discussion of the use of and schedule for program
evaluations.  OMB reiterated that it does not run programs and
therefore it "did not use Program Evaluations" to develop its plan. 
OMB said that "many evaluations.  .  .while not technically Program
Evaluations," were used in developing its strategic plan and that it
"continues to be a strong supporter of Program Evaluation."

We note that the Senate report that accompanied the Results Act
described program evaluation in broad terms, specifically "including
evaluations of .  .  .  operating policies and practices when the
primary concern is about these issues rather than program outcome."
In this context, we believe that evaluations are especially critical
for OMB because it is charged with overseeing and implementing some
of the most critical managerial functions of government.  Thus, we
continue to believe that OMB's strategic plan could be more useful if
OMB provided more information on its use of program evaluations in
developing its plan. 


MAJOR CONTRIBUTORS TO THIS LETTER
========================================================== Appendix II


   ACCOUNTING AND INFORMATION
   MANAGEMENT DIVISION, WASHINGTON
   D.C. 
-------------------------------------------------------- Appendix II:1

Gloria L.  Jarmon, Director
Michael J.  Curro, Assistant Director
John P.  Finedore, Assistant Director
Danny R.  Latta, Assistant Director
Denise M.  Fantone, Senior Evaluator
Laura E.  Hamilton, Senior Evaluator


   GENERAL GOVERNMENT DIVISION,
   WASHINGTON D.C. 
-------------------------------------------------------- Appendix II:2

J.  Christopher Mihm, Acting Associate Director
Joseph S.  Wholey, Senior Advisor for Evaluation Methodology
Curtis W.  Copeland, Assistant Director
John K.  Needham, Assistant Director


   OFFICE OF GENERAL COUNSEL
-------------------------------------------------------- Appendix II:3

Alan N.  Belkin, Assistant General Counsel
Carlos E.  Diz, Attorney


*** End of document. ***