Embassy Construction: Proposed Cost-Sharing Program Could Speed  
Construction and Reduce Staff Levels, but Some Agencies Have	 
Concerns (15-NOV-04, GAO-05-32).				 
                                                                 
The Department of State is in the early stages of a proposed	 
multibillion dollar program to build secure new embassies and	 
consulates around the world. Under the proposed Capital Security 
Cost-Sharing Program, all agencies with staff assigned to	 
overseas diplomatic missions would share in construction costs.  
This report describes (1) the rationale for and development of	 
the program, (2) agency concerns about the program, and (3) the  
influence of the program on agencies' overseas staff levels.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-32						        
    ACCNO:   A13516						        
  TITLE:     Embassy Construction: Proposed Cost-Sharing Program Could
Speed Construction and Reduce Staff Levels, but Some Agencies	 
Have Concerns							 
     DATE:   11/15/2004 
  SUBJECT:   Construction costs 				 
	     Consulates 					 
	     Cost sharing (finance)				 
	     Embassies						 
	     Program evaluation 				 
	     Program management 				 
	     Capital Security Cost-Sharing Program		 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Product.                                                 **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
GAO-05-32

United States Government Accountability Office

                                      GAO
	Report to the Chairman, Subcommittee on National Security, Emerging Threats, and International Relations, Committee on Government Reform, House of Representatives 

November 2004

EMBASSY CONSTRUCTION 

Proposed Cost-Sharing Program Could Speed Construction and Reduce Staff Levels, but Some Agencies Have Concerns 

                                       a

GAO-05-32 

November 2004

EMBASSY CONSTRUCTION

Proposed Cost-Sharing Program Could Speed Construction and Reduce Staff Levels,
but Some Agencies Have Concerns

  What GAO Found

The administration's proposed Capital Security Cost-Sharing Program has
been developed to accelerate the building of 150 new secure embassies and
consulates around the world and to ensure that all agencies with overseas
staff assign only the number of staff needed to accomplish their overseas
missions. The Department of State's Bureau of Overseas Buildings
Operations (OBO), which would manage the program, examined several
formulas before deciding that all agencies with an overseas presence would
share costs, based on a per capita or "head-count" formula. If enacted,
nearly 30 U.S. agencies would be assessed a total of $17.5 billion for
constructing 150 new embassies by 2018, or 12 years sooner than the
projected completion date of 2030. After a gradual phase-in period
beginning in fiscal year 2005, the program would generate $1.4 billion
annually from fiscal years 2009 through 2018, with State paying $920
million and non-State agencies paying $480 million.

Accelerated Funding for Embassy Construction

Many non-State Department agencies have concerns about the proposed
program. They would prefer a formula other than one based on head counts
to assess fees, and they are concerned that cost-sharing fees could affect
their ability to accomplish their overseas missions. In addition, they
stated that it would be useful to establish new interagency mechanisms to
discuss and resolve potential implementation issues. We did not assess the
mechanisms to be used to implement the program and have taken no position
on whether they would be needed. State is concerned that, without
accelerated funding, U.S. government employees will remain at risk beyond
the 2018 completion date. State is also concerned that, without cost
sharing, OBO could overbuild office space due to agencies' imprecise
staffing projections. In our prior work, we have noted the importance of
achieving interagency consensus and striving to achieve equity while
minimizing management burden. Decision-makers need to continually focus on
these factors to give the program every opportunity to succeed. If
enacted, it is important that Congress and State monitor its
implementation and make changes as needed.

United States Government Accountability Office

Contents

Letter

Results in Brief  Background 
Rationale for and Development of the Capital Security Cost-Sharing 

Program  Several Agencies Have Concerns about the Program 
Program Has Influenced Some Agencies' Decisions to Reduce the 

Number of Overseas Staff  Conclusion  Agency Comments and Our Evaluation 

1 2  4 

7 12 

18 22 23 

     Appendixes                                                         
        Appendix I:         Objectives, Scope, and Methodology            25  
       Appendix II:     Comments from the Department of Agriculture       29  
                                       GAO Comments                       31  
      Appendix III:      Comments from the Department of Commerce         33  
                                       GAO Comments                       37  
       Appendix IV:  Comments from the Department of Health and Human   
                                         Services                         39  
                                       GAO Comment                        42  
        Appendix V:  Comments from the Department of Homeland Security    43  
                                       GAO Comments                       45  
       Appendix VI:       Comments from the Department of Justice         46  
                                       GAO Comments                       48  
      Appendix VII:        Comments from the Library of Congress          49  
                                       GAO Comments                       52  
     Appendix VIII:        Comments from the Department of State          54  
                                       GAO Comments                       58  
       Appendix IX:    Comments from the Department of the Treasury       59  
        Appendix X:   Comments from the U.S. Agency for International   
                                        Development                       60  
                                       GAO Comments                       62  

Tables Table 1: 	Non-State Agencies' Cost-Sharing Assessments, Fiscal 
Years 2005-2018 (Excluding 2008) 11 

Contents

Table 2: Four Formulas for Allocating Costs among Agencies with an Overseas Presence 13 Table 3: Selected Agencies' Annual Cost-Sharing Fees Using Different Cost-Sharing Formulas 15 

Table 4:
   	Selected Agencies' Staff Positions and Estimated Savings in Annual Cost-Sharing Fees for Fiscal Years 2005 and 2006, as of July 1, 2004 20 

Table 5:
   	Estimated Percentage Increase Needed in International Program Budgets for Cost-Sharing Fees for Selected Agencies, Fiscal Years 2005, 2007, and 2009 22 

Figures  Figure 1:  U.S. Agencies' Overseas Staff Positions Used to Determine Annual Cost-Sharing Fees under Proposed  
                                                        Program, as of March 2004                                      7  
         Figure 2:                          Accelerated Funding for Embassy Construction with                          
                                                  Cost Sharing, Fiscal Years 1999-2030                                 9  

Abbreviations

GSA General Services Administration IAP Industry Advisory Panel
ICASS International Cooperative Administrative Support Services
OBO Bureau of Overseas Buildings Operations
OMB Office of Management and Budget OPAP Overseas Presence Advisory Panel
USAID U.S. Agency for International Development 

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

A

United States Government Accountability Office

Washington, D.C. 20548

November 15, 2004 

The Honorable Christopher Shays 

Chairman 

Subcommittee on National Security, Emerging Threats, and International Relations Committee on Government Reform House of Representatives 

Dear Mr. Chairman: 

The Department of State is in the early stages of a proposed multibillion-dollar program to accelerate the building of secure embassies and consulates around the world. To help finance construction, the administration has proposed the Capital Security Cost-Sharing Program, under which agencies with staff assigned to overseas diplomatic missions would pay a portion of the construction costs. A provision authorizing the program is included in legislation currently under consideration by the Congress.1 If enacted, the program is scheduled to go into effect in fiscal year 2005 and would represent a major shift in how the U.S. government allocates funding for embassy construction, as State historically has paid for nearly the entire program.2 The cost-sharing concept, under development since 1999, gained momentum in 2001 when the President, as part of his management agenda, directed that all agencies reduce overseas staff to the minimum levels necessary to meet U.S. foreign policy objectives.3 Since then, the administration has stated that cost sharing would be an important part of the overall embassy "rightsizing" initiative as it would force each agency to consider the full costs of its overseas presence, including the costs of building safe facilities, in determining overseas staffing levels. 

1See H.R. 4754, Sec. 625, Departments of Commerce, Justice, and State, the Judiciary and Related Agencies Appropriations Act, 2005. 

2The U.S. Agency for International Development (USAID) has also funded the construction 

of some overseas facilities. For additional information, see GAO, Embassy
Construction:

Achieving Concurrent Construction Would Help Reduce Costs and Meet
Security Goals,

GAO-04-952 (Washington, D.C.: Sept. 28, 2004). 

3Office of Management and Budget, The President's Management Agenda,
Fiscal Year 2002 (Washington, D.C.: Aug. 2001). 

This report describes (1) the administration's rationale for and development of the Capital Security Cost-Sharing Program, (2) agency concerns about the program, and (3) the influence of the proposed program on agencies' decisions on overseas staff levels. To complete our work, we obtained documents and discussed the program in Washington, D.C., with State's Bureau of Overseas Buildings Operations (OBO), which is responsible for the embassy construction program; the Office of Management and Budget (OMB); eight other executive branch departments and agencies; and the Library of Congress. We selected the executive branch departments and agencies because they have staff overseas and, under the current proposal, would have the largest annual cost-sharing charges. We selected the Library of Congress because it is the only nonexecutive branch agency that would pay cost-sharing fees. We conducted our work in accordance with generally accepted government auditing standards. Appendix I provides more information on our objectives, scope, and methodology. 

Results in Brief
   	The administration has proposed the Capital Security Cost-Sharing Program to fund the accelerated construction of 150 secure new embassies and consulates worldwide 12 years sooner than currently planned and to ensure that agencies "rightsize," or assign only the number of staff needed to accomplish their overseas missions.4 Under the proposed program, agencies would begin paying partial cost-sharing fees in fiscal year 2005. These fees would gradually increase until fiscal year 2009, when agencies would feel the full impact of the program on their budgets. In 2000, OBO began developing the cost-sharing program in consultation with a working group of interagency officials. In 2002, OBO announced that it proposed to charge each agency a portion of the overall construction costs based on a 

4For our purposes, we define rightsizing as aligning the number and location of staff assigned overseas with foreign policy priorities, security, and other constraints. State agrees with this definition. Rightsizing may result in the addition or reduction of staff, a change in the mix of staff at a given embassy or consulate, or a change in embassy construction plans. The goal of rightsizing is consistent with our framework for determining overseas staffing levels, which encourages each agency to consider security, mission, and cost trade-offs in adjusting overseas staffing levels. For further information on overseas staffing issues, see GAO, Overseas
Presence: Framework for Assessing Embassy Staff Levels Can Support
Rightsizing Initiatives,
GAO-02-780 (Washington, D.C.: July 26, 2002); Overseas Presence:
Rightsizing Framework Can Be Applied at U.S. Diplomatic Posts in
Developing Countries,
GAO-03-396 (Washington, D.C.: Apr. 7, 2003); and Embassy Construction:
Process for Determining Staffing Requirements Needs Improvement,
GAO-03-411 (Washington, D.C.: Apr. 7, 2003). 

worldwide per-capita, or "head-count," formula. OBO officials stated that they preferred the head-count formula, largely because it would best meet the primary goals of accelerating embassy construction and promoting rightsizing of U.S. agencies' overseas staff, would be simple to implement, and would avoid agencies' relocating overseas personnel to avoid or reduce cost-sharing charges. 

Several agencies have concerns about the proposed program. Some non-State agencies are particularly concerned about the cost-sharing formula selected. These agencies believe that other formulas would more closely link the fees they pay to benefits they receive, such as the amount of office space occupied. Our analysis shows that, depending on the formula used, cost-sharing amounts would vary considerably, with some agencies benefiting at the expense of others. Some non-State officials are also concerned about how potential disputes would be resolved, such as deciding which agencies' staff would be required to find office space outside the embassy compound if increased staff levels resulted in a shortage of office space within the compound. Several agencies also expressed concern that the cost-sharing fees could affect their ability to accomplish their overseas missions. In addition, State is concerned that, if the program is not implemented, OBO would be unable to accelerate construction and, if some agencies are exempted, overall support for the program would be seriously eroded. 

The cost-sharing program has already influenced some agencies' decisions to reduce their numbers of overseas staff. Some agencies, in consultation with OMB and their appropriations subcommittees, have been considering new ways of meeting their missions with fewer overseas staff. Several agency officials stated that they have closely scrutinized their staff levels to reduce their fees. We found that at least five agencies have reduced overseas positions or placed staff in less costly areas within the embassy compound, thereby reducing the amounts of their cost-sharing fees. Officials from two of these five agencies stated that the staff reductions were made specifically to reduce cost-sharing fees. The amount of pressure could increase on agencies to either further reduce their overseas staff or curtail other budgetary activities to cover the gradual increase in their cost-sharing fees. 

We received written comments on a draft of this report from eight executive branch departments and agencies (Departments of Agriculture, Commerce, Health and Human Services, Homeland Security, Justice, State, the Treasury, and the U.S. Agency for International Development) and the 

Library of Congress. State said the report is a fair and accurate representation of the issues. Non-State agencies emphasized their concerns regarding several aspects of the program, including the program's accountability and equity, as well as its impact on their ability to accomplish their overseas missions. Further, many non-State agencies said that adequate mechanisms are not in place to ensure smooth implementation. Several agencies recommended that new interagency mechanisms be established to resolve disputes, ensure accountability and equity, and consider improvements to the program. 

Our work focused on the rationale for and development of the cost-sharing program, agencies' concerns about the program, and the program's influence on agencies' overseas staffing levels. We did not assess the mechanisms to be used to implement the program if Congress enacts it. Therefore, we have taken no position on whether alternative interagency mechanisms would be needed. In our previous work, we have pointed out the importance of striving for accountability and equity and achieving an interagency consensus on capital cost sharing.5 In addition, we have noted the importance of minimizing management burden while carrying out such a program. We believe there is time to address these and other potential implementation issues during the initial phase-in period of the program and that decision-makers would need to continually focus on various implementation issues to give the program every opportunity to succeed. Further, if the proposed program is enacted, it is important that Congress and State monitor the program's implementation and make changes as needed. 

Background
   	Following the terrorist bombings of U.S. embassies in Kenya and Tanzania in 1998, the Secretary of State, with the support of the President and Congress, created an Overseas Presence Advisory Panel (OPAP) to examine the condition, organization, management, and other aspects of U.S. diplomatic representation overseas. In 1999, the panel declared that the U.S. overseas presence was near a state of crisis and that the condition of U.S. posts and missions abroad was unacceptable.6 Specifically, the 

5GAO, Overseas Presence: Framework For Assessing Embassy Staff Levels Can
Support Rightsizing
Initiatives, GAO-02-780 (Washington, D.C.: July 26, 2002). 

6U.S. Department of State, America's Overseas Presence in the 21st
Century, The Report of the Overseas Presence Advisory
Panel (Washington, D.C.: Nov. 1999). 

Panel recommended that major capital improvements be undertaken at U.S. facilities to strengthen security. The Panel reported that funds for new overseas facilities should be provided from a variety of sources, including payments by all the agencies that share space in the facilities.7 In addition, the Panel concluded that, at U.S. facilities, linking the number of staff with mission priorities could achieve significant budget savings by reducing the size of overstaffed locations. Further, Congress passed legislation in 1999 requiring all U.S. government staff working at posts slated for new construction to be located on the new embassy compounds unless they are granted a special colocation waiver.8 

In 2002, the President's Management Agenda emphasized the importance of configuring U.S. overseas staff to the minimum necessary to meet foreign policy goals. As part of the Agenda, OMB led an effort to develop a cost-sharing mechanism. OMB also emphasized the need to build embassies more quickly and recognized that, to do so, all agencies with overseas staff should be required to contribute their share to the costs. The administration also emphasized that, by requiring agencies to pay for overseas staff, agencies would be more likely to closely assess the need for each position before deciding to place a person overseas, thereby rightsizing overseas staffing levels at U.S. facilities. 

In 2003, we reported on the poor conditions of facilities at embassies and consulates. For example, we found that the primary office building at 232 posts lacked sufficient security, potentially putting thousands of U.S. government employees at risk.9 We also reported, however, that OBO had begun to institute a number of organizational and management reforms, beginning in 2001, designed to cut costs, standardize designs and review processes, and reduce the construction period for new embassies and 

7Recognizing the absence of cost sharing among agencies at overseas facilities, the OPAP recommended establishing a government corporation that would be authorized to collect rental revenue from agencies for current operating and maintenance costs. The recommendation was never implemented. 

822 U.S.C. S: 4865 requires the Secretary of State, in selecting sites for new U.S. diplomatic facilities abroad, to ensure that all U.S. personnel under chief of mission authority be located onsite. However, the Secretary of State may waive this requirement if the Secretary, together with the heads of those agencies with personnel who would be located off-site, determines that security considerations permit an off-site location and that it is in the U.S. national interest. 

9GAO, Overseas Presence: Conditions of Overseas Diplomatic
Facilities, GAO-03-557T (Washington, D.C.: Mar. 20, 2003). 

consulates. These reforms, along with other actions such as increasing staff training and expanding outreach to contractors, provided OBO with the capability to manage its overseas building program more effectively.10 

The United States currently has a network of embassies and consulates at 251 locations around the world.11 Nearly 30 agencies have more than 61,000 staff at these locations. Under the proposed program, cost-sharing fees would be charged for every overseas position. Annual charges for approximately 25,000 State support staff that provide security, transportation, and other services to all overseas agencies would be shared proportionately among over 36,000 program staff from all agencies, including State.12 Figure 1 shows the numbers of U.S. agencies' overseas staff positions that would pay annual cost-sharing fees under the proposed program. 

10GAO, Embassy Construction: State Department Has Implemented Management
Reforms, but Challenges Remain,
GAO-04-100 (Washington, D.C.: Nov. 4, 2003). 

11According to State, there are an additional 12 missions, American presence posts, and branch offices worldwide where there is no chief of mission. 

12State support staff provide services under the International Cooperative Administrative Support Services (ICASS) program. 

Figure 1: U.S. Agencies' Overseas Staff Positions Used to Determine Annual
Cost-Sharing Fees under Proposed Program, as of March 2004

2%

Homeland Security (750)

3%

Justice (1,083)

3%

Commerce (1,276)
Other departments and agencies (1,460)

The Capital Security Cost-Sharing Program was developed so that State could obtain funds to accelerate the construction of new embassies and consulates around the world and so that agencies would pay the full costs associated with their overseas presence. The agencies' share of embassy construction costs would be phased in over 5 years. When the proposed program is fully implemented, from fiscal years 2009 through 2018, it could result in funding of $1.4 billion annually from nearly 30 agencies, including State. OBO worked with OMB to develop the program based on a per-capita allocation of worldwide embassy construction costs for 150 facilities. OBO 

                                Defense (2,521)

                                 USAID (6,429)

                                 State (23,131)

Source: GAO analysis based on OBO data.

Historically, State has borne the costs for constructing nearly all diplomatic facilities abroad. During the 6-year period from fiscal year 1999 through 2004, OBO received appropriations totaling $3.1 billion for constructing these facilities. Annual funding amounts generally increased during the period from about $300 million in fiscal year 1999 to about $750 million in fiscal year 2004, an amount that is about half of the annual $1.4 billion that the proposed $17.5 billion program would provide for new embassy construction when fully implemented. 

  Rationale for and Development of the Capital Security Cost-Sharing Program 

devised a fee-assessment plan that would spread the total embassy construction costs among all agencies with an overseas presence. After considering and rejecting several ways to charge agencies, OBO approved a cost-sharing formula based on a per-capita or "head-count" fee because, according to OBO, it was simple to implement, promoted agency rightsizing, and minimized agencies' incentives to move staff to different locations to avoid cost-sharing charges. 

    Proposed Cost-Sharing Program Could Accelerate Embassy Construction 

Funding through the proposed Capital Security Cost-Sharing Program could allow significant acceleration of the construction of U.S. diplomatic missions.13 Under the proposed program, the total funding amount would be $1.4 billion annually, a substantial increase over OBO's historical funding levels. For example, during the 6-year period from fiscal years 1999 through 2004, OBO's actual appropriations for embassy construction totaled $3.1 billion, an average of roughly $522 million annually. Annual funding amounts generally increased from about $300 million in fiscal year 1999 to about $750 million in fiscal year 2004. 

According to OBO, funds from cost sharing would enable the construction of 150 new embassy and consulate compounds to be completed by 2018, 12 years sooner than OBO's initial plan, which included a planned completion date of 2030. After fees are phased in during fiscal years 2005 through 2008, non-State agencies would pay $480 million annually for a 10-year period through fiscal year 2018, while State's annual payment would be $920 million. Figure 2 shows OBO's existing embassy construction projections through fiscal year 2030 and how funding generated by the proposed cost-sharing program could accelerate embassy construction through fiscal year 2018. 

13Acceleration of construction depends on agencies' either receiving increased appropriations or reallocating funds from other activities. 

Figure 2: Accelerated Funding for Embassy Construction with Cost Sharing,
Fiscal Years 1999-2030

Dollars in billions 1.6 1.4 1.2 1.0

                                                            0.8 0.6 0.4 0.2 0

                1999 2004 2009 2018 2030 Fiscal years 1999-2030

Source: OBO.

    Proposed Cost Sharing Is Based on a Worldwide Head-Count Formula 

Amounts for Cost-Sharing Positions Would Be Adjusted Every 3 Years 

In developing the proposed cost-sharing program, OBO, with OMB's approval, selected a per-capita or head-count formula based on the number of agency staff at all overseas locations and the type of office space. To determine each agency's cost share, agency officials were encouraged to scrutinize their overseas staff numbers and determine whether each position required office space with controlled access, space with noncontrolled access, or nonoffice space for staff such as custodians, gardeners, drivers, and others who do not require a specific desk or workstation. According to OBO officials, it can easily calculate and periodically revise agencies' fees by performing a few simple calculations, without the need for a large number of staff to administer the program. 

OBO adopted a methodology in which agencies' cost-sharing fees for the first 3 years of the program, fiscal years 2005 to 2007, would be based on the total number of overseas positions that OBO identified in a 2002 worldwide survey. The positions were categorized by the four types of space. To determine agencies' fees for the four types of positions, OBO estimated the construction costs for building each type of space at a typical new embassy. For example, the annual charge for a position located in a 

controlled access area would be $59,318.14 According to OBO, it plans to
adjust these amounts every 3 years, beginning in fiscal year 2008, based on 
changes in the total number of overseas positions. In addition to the basic 
head-count fees, agencies' annual charges would include amounts for their
proportionate share of construction costs for support services' personnel
under the International Cooperative Administrative Support Services
(ICASS) program. However, agencies' fees would be reduced, or "offset,"
by the amounts they are currently paying for office space outside embassy 
compounds.

Based on input from all participating agencies, OBO plans to update the 
head-count numbers for staff annually and adjust cost-sharing fees to 
reflect updated headcounts. If the proposed program begins in fiscal year 
2005, agencies would be charged for 61,413 positions, including 251 
positions in the chief-of-mission areas; 8,432 in controlled access areas; 
30,850 in noncontrolled access areas; and 21,880 in nonoffice space. These 
positions include direct-hire Americans, locally employed staff,
contractors, continuing part-time staff, and temporary duty 
positions. Non-State agency participants and phased-in annual fees are 
shown in table 1.

14Under the proposed program, the cost-sharing fee for each type of position is as follows: (1) chief-of-mission area at $209,034 per position, (2) controlled access area at $59,318 per position, (3) noncontrolled access area at $28,144 per position, and (4) nonoffice area at $4,940 per position. 

 Table 1: Non-State Agencies' Cost-Sharing Assessments, Fiscal Years 2005-2018
                                (Excluding 2008)

Dollars in millions

                               Number of                             Annually 
                                   staff FY 2005 FY 2006 FY 2007 FY 2009-2018 
       Non-State agencies      positions  (20%)   (40%)    (60%)       (100%) 
              USAID                6,429  $20.3   $55.8    $91.3       $179.7 
             Defense               2,521    30.6    61.9    93.1        125.6 
             Justice               1,083    13.5    27.0    40.5         61.4 
            Commerce               1,276     4.5    13.6    22.8         40.2 
        Homeland Security            750     7.6    15.3    22.9         28.5 
           Agriculture               525     0.6     4.5     8.4         16.3 
       Library of Congress           202     1.2     2.4     3.6 
    Health and Human Services        219     1.0     2.6     4.3 
      Other departments and          514     4.4     9.3    14.4         16.9 
          agencies (17)                                          
    Total non-state agencies      13,519  $83.7  $192.4   $301.3       $480.0 

Source: GAO analysis based on OBO data, as of March 2004.

Note: Assessment data were not available for fiscal year 2008. Annual
funding for fiscal year 2009-2018 includes proportionate amounts for
support services. Figures may not add to total due to rounding.

OBO Considered and Rejected OBO considered two other formulas before deciding on the head-count 

Alternative Cost-Sharing method of determining agencies' shares of embassy construction costs. 

Formulas	One formula considered by OBO and an interagency working group would have assessed agencies' charges based on the amount of space (square feet or meters) occupied in overseas facilities. There was agreement that the "space occupied" formula would more directly link costs paid to benefits received. However, OBO rejected the proposed formula because, according to OBO officials, administering and managing the fee assessments would require frequent collection and updates of data, which could be burdensome and labor intensive. 

OBO proposed a second formula based on comparable rental costs apportioned on a per-capita basis. The formula included factors such as commercial cost of rent by location, the net amount of space occupied, and other variables. According to OBO officials, this option was eventually rejected because it would not result in sufficient up-front funding needed for the construction and would also be labor intensive to compile and manage the data. The space occupied and rent formulas also lacked the 

support of OBO's Industry Advisory Panel (IAP),15 whose members stated that agency officials could dispute the amount of office space for which they were charged, complain about the quality of their space, assert that other agencies' staff were using a disproportionate share of space, and raise other issues that could be difficult to manage.16 

OBO and OMB worked to develop fee assessments based on a per-capita or head-count fee for the full costs of construction in early 2002. OBO officials stated that the formula would be the simplest to manage because fees are based on a flat rate for four different types of office space, regardless of where the position is located worldwide. Charges assessed to each agency would be generated on the basis of a consistent, standardized formula. Each agency can easily compute the cost of adding or removing an employee from overseas duty. In addition, OBO officials stated that a per-capita or head-count formula would not require intensive labor to administer and could readily provide a steady flow of up-front funding to expedite embassy construction. OBO also claimed that, because all agencies' staff positions are included in the worldwide cost-sharing methodology, each agency would pay its share for occupied workspace. OBO's initial proposal included charging for office space in controlled and noncontrolled access areas only. In response to other agencies' requests, OBO established per-capita fee assessments for all four types of positions in its current proposed program. 

  Several Agencies Have Concerns about the Program 

Officials from several agencies have concerns about the development and implementation of the proposed program. Some non-State agencies would prefer a formula other than the head-count formula to more closely link the fees paid to the services received. Non-State officials are also concerned about potential implementation issues, including concerns about the resolution of interagency differences and uncertainty about consistent congressional support for increasing budget requests that include cost shares, which could impact their international missions. State officials are concerned that, if the program is not funded, OBO will be unable to 

15According to OBO, the IAP is a chartered federal advisory committee consisting of a panel of experts who provide strategic industry insights to OBO on a variety of issues, including the latest innovations in the commercial world combining best practices, streamlined processes, and proven cost-effective methods. 

16According to OBO officials, neither method resulted in the full $1.4 billion needed to achieve annual program goals through fiscal year 2018. 

accelerate construction and that if some agencies are exempted, overall support for the program would be seriously eroded. 

    Some Non-State Agencies Prefer Formulas Other Than the Head-Count Formula 

Officials from some non-State agencies are concerned that the program's head-count formula may result in disproportionate costs to some agencies. They indicated that they would prefer a formula based on one of three options: (1) the amount of office space occupied worldwide, (2) the amount of office space occupied at a specific location, (3) a head count of staff at locations where new embassies would be built. They added that these formulas would more closely link the fees paid to the benefits received. We examined these alternative formulas and describe them, along with OBO's current proposed head-count formula, in table 2. 

  Table 2: Four Formulas for Allocating Costs among Agencies with an Overseas
                                  Presence (3)

(2) Site-specific head (1) Site-specific rent count at locations OBO's
current proposed Worldwide office space comparable to local where new
embassies worldwide head-count occupied commercial space are built formula

                   Space occupied  Comparable       Cost per      Cost per    
Basis of charge      as a       cost of        position for  position for  
                                   renting                      
                     percentage of  office space  constructing  constructing  
                      construction    locally          one           150      
                        cost                         embassy      embassies   
                    According to    According to  According to  According to  
Management and      OBO, a          OBO, a     OBO, few        OBO, few    
                   full-time staff full-time        staff are     staff are   
administrative     is needed to staff is         needed to     needed to   
                                   needed to                    
                       manage this                                manage this 
                        formula. a manage this     manage this       formula. 
    requirements             Staff formula. Staff   formula.            Staff 
                     would need to would need to   Staff would  would need    
                      periodically periodically     need data   data on the   
                    update data on update data on      on       number of     
                        the amount the costs of   construction  staff         
                                                      costs     positions     
                      of space         local      and number     overseas and 
                     occupied by     commercial   and types      the types of 
                                       space                    
                    agency staff.   overseas and  of positions   space they   
                                      security        where        occupy.    
                                     upgrades.      embassies   
                                                    would be    
                                                     built.     
                   Similar to        Similar to                 OBO and       
Cost allocation standard U.S.   standard U.S.  Link between  agencies      
                                                    building    differ        
                   government        government    costs at a   on the link   
     methodology   approach for     approach for  specific site between costs 
                       capital         rent.      and staff who and benefits. 
                    construction.                   benefit.          b       

Who pays more/less?	Agencies occupying a Agencies with large Staff in new
embassies Agencies with larger larger percentage of space numbers of staff
in pay relatively large fees; numbers of staff worldwide worldwide pay
more; high-cost locations pay staff not located in new pay more; agencies
with agencies occupying a more; small numbers of embassies pay no fees.
smaller numbers of staff smaller percentage of staff in high-cost
locations worldwide pay less. space pay less. pay less.

Source: GAO.

aAgriculture disagreed with OBO's assertion that full-time staff would be
required to administer this formula.

bOBO's head-count formula assesses agencies for positions at all 251
overseas embassies and consulates, including positions at 101 locations
where no major construction is planned through fiscal year 2018. OBO's
rationale is that staff at the 101 locations are already in secure
facilities and thus benefit from prior construction. Some non-State
agencies disagree with OBO, stating that they should not be required to
pay for secure facilities already built by OBO.

Formulas Based on Space We found that the cost-sharing fees of seven selected agencies would vary 

Occupied and Rent at Overseas under different scenarios. Specifically, we examined two formulas that 

Facilities	OBO had developed during its initial planning phase of the program: one based on the amount of office space occupied worldwide and the other based on comparable cost for renting office space locally. We compared these two formulas with OBO's current head-count formula. Using OBO data that we determined to be reliable, we computed the amount of space occupied by agencies worldwide and at each overseas location. We found that, because agencies use different amounts of office space, the Departments of Agriculture, Defense, Health and Human Services, and State would pay higher cost-sharing fees under the space-occupied formula; the Department of Commerce and USAID would pay less; and the Library of Congress' fee would be similar to its fee under the head-count formula. 

Several agency officials stated that they would be in favor of a formula similar to the standard U.S. government approach for rent as used domestically by the General Services Administration (GSA), which manages many government buildings by renting space to other U.S. government agencies. GSA's fees are based on numerous factors, including comparable costs for commercial space, number of square feet, and the location and condition of the building. We found that, under the formula based on comparable local rental costs, State, USAID, and Health and Human Services would pay less than under OBO's current head-count charge because they have staff based in numerous locations where rental costs are inexpensive. In contrast, many Defense, Commerce, and Department of Agriculture staffs are based in cities with higher rents for commercial space. Thus, their rental fee would be higher than a fee based on head counts. Finally, fees for the Library of Congress using both the amount of office space occupied and comparable rental costs would be relatively similar to fees under the head-count formula, as shown in table 3. 

Table 3: Selected Agencies' Annual Cost-Sharing Fees Using Different
Cost-Sharing Formulas

                              Dollars in millions

                              Department or agency

       Worldwide space occupied Site-specific rent comparable with commercial
                            space OBO's proposed current worldwide head count

                        Agriculture     $ 23.2         $21.6            $16.3 
                           Commerce      31.8           49.1     
                            Defense      135.3         205.3            125.6 
                   Health and Human                              
                          Servicesa      11.1           3.9      
                Library of Congress       5.2           5.5      
                              State     1,002.7        790.6            920.0 
                              USAID      79.0          100.3            179.7 

                    Source: GAO analysis based on OBO data.

aIncludes the Centers for Disease Control and Prevention (CDC).

Formula Based on Head Count of Several agency officials noted that the proposed head-count formula 

Staff Benefiting from New Embassy Construction 

assesses blanket fees worldwide, not specifically where agencies' staff are located or where new embassies would be built. As a result, some agencies would be assessed fees, although some of their staff may not benefit directly from new construction. For example, the Library of Congress (the Library) is one of several agencies opposed to the head-count formula. According to Library and OBO data, only 45 (22 percent) Library staff-located in three cities-are likely to benefit from new embassy construction scheduled from fiscal years 2004 through 2009. In addition, many of the Library's positions are currently located in rented space outside embassy compounds, where the Library's annual office-space costs are substantially less than it wouldpay underthe cost-sharing program. For example, Library officials stated that they currently pay roughly $1,200 each for several positions in Islamabad, an amount that is considerably less than the $28,144 per position that would be assessed under the cost-sharing program. According to OBO officials, the Library has numerous staff in several cities, including Islamabad and five other locations, where construction is planned during fiscal years 2010 through 2018. The officials added that the Library would receive rent credit offsets for the costs of renting office space outside embassy compounds and noted that current law requires the Secretary of State, in selecting sites for new U.S. diplomatic facilities abroad, to ensure that all U.S. personnel under chief of mission authority be located on-site. 

We examined what agencies' head-count fees could be under the formula requiring only agencies with a presence at the new location to pay. We selected a typical location where a new embassy, with 247 staff representing four agencies, is projected to be built in fiscal year 2006 at a cost of $92.2 million. Agencies with no positions at this location would not be required to pay any cost-sharing fees. Our analysis, based on comparing the costs for types of space occupied at this typical embassy, shows that one-time fees for all four agencies would be higher at this one location than the current proposed head-count fees for all positions under this formula. For example, the one-time fee for a position in the noncontrolled access area would be about $357,000 for each person, substantially higher than the $28,144 annual fee used to calculate the current head-count formula. However, the same agency's overall fees would be higher due to its paying $28,144 annually, over a 14-year period. According to OBO officials, allowing agencies to pay cost-sharing fees only where their staffs are based would not support the goal of rightsizing because it would encourage agencies to avoid cost-sharing fees. Specifically, agencies could "game the system" by moving staff, even to potentially less secure locations, where no construction was planned. OBO acknowledged, however, that some non-State agencies' would be unlikely to move staff due to country-specific missions and the costs involved with moving. 

    Agencies Have Other Concerns about the Program 

Some non-State agencies have other concerns about the proposed program, including how potential disputes would be resolved and how cost-sharing fees would affect their ability to accomplish their overseas missions. In addition, State is concerned that, if the program were not implemented, OBO would be unable to accelerate construction; and, if some agencies are exempted, overall support for the program could be seriously eroded. 

Non-State agency officials indicated that the existing interagency working group may not be an effective mechanism for resolving disputes. Some non-State agencies are concerned that, when the program is implemented, the Interagency Facilities Committee, an interagency advisory group established by OBO to facilitate communication among agency officials, would not provide a credible forum for discussing program issues and resolving disputes. For example, some non-State agency officials said that they have no assurance that OBO would provide them with space in the embassy compound if conditions become crowded. According to one agency, all agencies should have participated in the formative stage discussions of the proposed program, such as the participatory and 

transparent discussions that were held during the development of the ICASS Program. In contrast, according to OBO officials, the Interagency Facilities Committee is a credible forum for discussing office space issues. OBO officials added that, in planning embassy size, a certain amount of contingency, or "spill-over" space, in anticipation of staff increases is incorporated into the plan. 

Some non-State officials said that OBO has shown little flexibility in adopting agencies' suggestions in Interagency Facilities Committee meetings. For example, OBO currently requires that the employing agency pay cost-sharing fees for staff temporarily assigned to another agency. In contrast, some agency officials would prefer that cost-sharing fees be paid by the agency to which the staff member is detailed, not by the permanent employer. According to one non-State official, OBO should not be concerned about which agency pays the fees and should allow the agencies to resolve this issue. OBO officials stated, however, that it would be complicated and burdensome to keep track of detailees to maintain an accurate account of overseas staff positions. OBO officials added that agencies could coordinate with other agencies to reimburse funding for detailees. 

OBO officials stated that they have made adjustments to the program based on agency suggestions, including charging more for the chief-of-mission position based on larger office space, and providing rent offsets to agencies for staff working outside embassy compounds. OBO also created certain procedures that agencies can use to challenge decisions. According to OBO officials, these procedures establish OMB as the final arbiter for resolving interagency disputes. OBO officials stated that these procedures and standard OMB processes had already been used to resolve some disputes. One non-State agency stated, however, that when disputes arise, OMB is likely to favor OBO's position because OBO has overall responsibility for implementing the proposed program. 

If the proposed program is implemented, some agencies are also concerned that annual cost-sharing fees could affect their ability to accomplish their international missions. USAID officials expressed concern that, without adequate funding, they may have to downsize and with fewer staff would not be able to accomplish some of their overseas missions. Commerce and Agriculture had similar concerns. Officials from both agencies stated that, without additional funding, their agencies would have to cut their overseas staff and some ongoing activities at numerous locations. For example, Commerce has projected that it may have to close offices at as many as 51 

posts by fiscal year 2009, reducing staff levels by 498 persons, to reduce annual costs by roughly $27.4 million. A Commerce official stated that post closings and reductions in staff could affect overseas sales for some U.S. firms because Commerce would have fewer staff to represent U.S. businesses in foreign markets. Finally, the Library of Congress' $6.4 million annual cost-sharing fee, set to take effect in fiscal year 2009, would represent over 70 percent of its total fiscal year 2004 international budget. Library officials indicated that, if the Library were required to pay such a large amount without receiving additional funding, the mission of their international program would be seriously affected. 

State is concerned that, if the program is not fully funded, OBO would be unable to accelerate construction and, if some agencies are exempted, overall support for the program could be seriously eroded. Congress is currently considering the proposed program but, until it is enacted, State will not be able to implement the accelerated building schedule. In addition, State is concerned about the potential impact of granting agencies exemptions from the program. Specifically, State noted that if one or more agencies were exempted, other agencies' funding levels would have to be increased to generate the $1.4 billion needed annually for the construction program. 

  Program Has Influenced Some Agencies' Decisions to Reduce the Number of Overseas Staff 

Although it is too early to tell how the cost-sharing program, if implemented, could influence all agencies' overseas staff levels, some agencies have already begun to rightsize staff in an effort to reduce their potential cost-share bill. Faced with expenditures they have not paid in the past, agencies have had additional incentives to closely review staffing levels and, in consultation with OMB and their appropriations committees, consider new ways of meeting their missions with fewer overseas staff. We found that, as of July 2004, at least five agencies had reduced their employee rosters by as many as 473 overseas positions. Two of these five agencies stated that the staff reductions were made specifically to reduce cost-sharing fees. OBO plans to use agencies' adjusted staffing numbers to revise its embassy construction plans. However, the full effect of the cost-sharing program would not be felt until 2009, after the 5-year phase-in period ends, which would likely bring increased pressure for agencies to further reduce their overseas staff. 

    Cost Sharing Has Promoted Greater Consideration of Costs in Staffing Decisions 

In the 2001 President's Management Agenda, the administration took the position that, if agencies are required to pay a greater share of the costs associated with their overseas presence, they would weigh cost considerations more carefully before posting personnel overseas. The administration's position is that by minimizing the growth of overseas staff, the U.S. government will benefit by reducing the numbers of people exposed to security risks, terrorist attacks, kidnapping, and other risks that are inherent in the overseas presence, and by reducing the costs of constructing embassy compounds. With the added incentive to scrutinize staff numbers, agencies would be required to consider whether they could afford each staff member. This rightsizing effort is important to ensure that, governmentwide, the correct numbers of people are working at each embassy. OBO officials stated that growth in overseas positions has been generated by both State and non-State agencies and that, for the first time, the Capital Security Cost-Sharing Program would provide a mechanism for controlling growth. By reexamining staffing numbers and types of office space, some agencies have already reduced their future cost-sharing fees. 

In preparing for the program, many agencies have already scrutinized the numbers of staff positions overseas and the types of office space they require. As a result, one agency eliminated numerous unfilled overseas positions, some of which had been unfilled for several years.17 One agency official stated that, prior to the cost-sharing program, many overseas positions had not been formally removed because retaining the positions allowed the agency the ability to quickly reassign staff as their missions and priorities changed.18 For example, beginning in fiscal year 2005, State, Commerce, the Treasury, and Homeland Security had already reduced overseas positions. State cut 263 positions and Commerce reduced its overseas staff by 191 positions, eliminating 168 unfilled positions and cutting 23 other positions. Finally, Treasury removed 17 positions, and Homeland Security removed 2 positions. 

Some agencies have reassessed the types of office space required for their employees stationed overseas. These agencies decided that some positions 

17In addition to reducing staff positions, one agency has also announced plans to completely withdraw all staff at some overseas locations. 

18We previouslyreported that unfilled positions should be eliminatedtoimprove theprocess of planning and constructing new embassies. See GAO, Embassy
Construction: Process for Determining Staffing Requirements Needs
Improvement, GAO-03-411 (Washington, D.C.: Apr. 7, 2003). 

located in controlled access areas could be relocated to noncontrolled access areas, thereby reducing their cost-sharing fees. For example, the Foreign Broadcast Information Service reclassified six positions previously located in noncontrolled access areas to less costly nonoffice areas. 

By scrutinizing their numbers of overseas positions and determining the types of space they require, State, Commerce, the Treasury, and Homeland Security, and the Foreign Broadcast Information Service significantly reducedtheir cost-sharing assessments for fiscal year 2006and, at the same time, reduced the number of staff that would be exposed to terrorist attacks and other overseas security risks. For example, State reduced its projected fees by more than $15 million, and Commerce reduced its fees by nearly $6 million. Other agencies' staff numbers have either increased, did not change, or were being finalized as of September 2004. Table 4 shows selected agencies' estimated savings in annual cost-sharing fees (fiscal year 2005 to 2006) after reducing their overseas positions and/or reassessing the types of space needed. 

Table 4: Selected Agencies' Staff Positions and Estimated Savings in
Annual Cost-Sharing Fees for Fiscal Years 2005 and 2006, as of July 1,
2004

                              Dollars in millions

              FY 2005 FY 2006 Agency or department Staff positions

Cost-sharing fee Staff positions

Cost-sharing fee

Estimated savingsa

           Department of Commerce          1,276   $34.7  1,085  $28.9b  $5.8 
Foreign Broadcast Information Service      109   3.1      109  2.9   
      Department of Homeland Security         750  24.6      748  24.4  
            Department of State           23,131   663.1  22,868 647.7  
         Department of the Treasury            89   3.2       72  2.5   
                   Total                  25,355  $728.7  24,882 $706.4 $22.3 

Source: GAO analysis of OBO data.

Note: Amounts shown for fiscal year 2005 and 2006 cost-sharing fees and
estimated savings are full cost shares that do not reflect the phase-in
period of the program. They do not include construction charges for ICASS
positions and rent offsets, if applicable.

aIf agencies would "save" funds by reducing cost-sharing fees, OBO would
receive less than $1.4 billion annually. As a result, OBO would have to
either construct fewer or less costly buildings annually or extend the
proposed completion date beyond 2018.

bAccording to Commerce, the fiscal year 2006 fee was still under
negotiation with OBO, as of October 12, 2004.

OBO officials stated that the fundamental building block for planning a new embassy compound is the projected numbers and types of positions that must be accommodated in the new facilities. Without these details, the U.S. government risks building new facilities that are designed for the wrong number of staff. To prepare for the initial implementation of the cost-sharing program, OBO asked agencies to submit updated information on overseas staff numbers. OBO has since revised the agencies' data so that it can begin the program with the most current staffing levels. Because the size and cost of new embassy facilities are directly related to anticipated staffing requirements, OBO stated that it would continue to obtain periodically revised staff numbers and, when appropriate, change its embassy construction plans or adjust cost-sharing fees that agencies would be required to pay. 

    Gradual Phase-in of Program Would Likely Bring Increasing Pressure to Reduce Overseas Staff 

For selected agencies, international program budgets would have to increase substantially to cover the gradual phase-in of annual cost-sharing fees. Therefore, agencies are likely to face increased pressure to scrutinize their overseas staff levels and ensure that only essential personnel are staffed at overseas posts. As agencies are required to pay more each year until the proposed program is fully implemented in fiscal year 2009, agency officials may decide to further reduce their overseas staff numbers to reduce their fees. 

We selected four agencies and estimated how much their international program budgets would need to increase to meet cost-sharing fees. We found, for example, that Commerce's Foreign and Commercial Service budget would have to increase by 11 percent from fiscal year 2005 to fiscal year 2007 and by as much as 18 percent from fiscal year 2005 to fiscal year 2009 to cover cost-sharing fees. The estimated amount and percentage of budget increases needed to pay cost-sharing fees for fiscal years 2007 and 2009 for sampled agencies-Agriculture, Commerce, USAID, and the Library of Congress-are shown in table 5. 

Table 5: Estimated Percentage Increase Needed in International Program
Budgets for Cost-Sharing Fees for Selected Agencies, Fiscal Years 2005,
2007, and 2009

Dollars in millions

                                        FY 2007                FY 2009 
                          FY 2005               Percent                 Percent 
                    International International increase International increase 
Department or                                from FY                 from FY 
      agency               budget        budget                 budget 
(component/program)   (requested)  (estimated)    2005    (estimated)      2005 
    Agriculture                                                                 
     (Foreign              $147.6        $156.0       6%        $163.9      11%
    Agriculture                                                        
     Service)                                                          
  Commerce (U.S.                                                       
    Foreign and                                                        
    Commercial                                                         
     Service)               211.9         234.7       11         252.1 
Library of Congress           8.9          12.5       40          15.3 
  (International)                                                      
 USAID (Operating           623.4         714.7       15         803.1 
     Expenses)                                                         

Source: President's Budget submission and GAO estimation.

Note: Estimates for fiscal years 2007 and 2009 assume no other budget
increases and are GAO estimations based on fiscal year 2005 data.

Conclusion	The principle of cost sharing is consistent with the Overseas Presence Advisory Panel's findings and recommendations that agencies share in the cost of constructing new secure embassies and that agencies' staffing levels be linked with their overseas missions. If the proposed cost-sharing program is enacted and funded, it could result in expedited construction of new embassies and, at the same time, increased incentives for agencies to ensure that only essential staff are based overseas. Providing secure facilities for U.S. employees overseas is a high priority for the U.S. government, and the proposed Capital Security Cost-Sharing Program is one way to accelerate the construction of these facilities. Requiring agencies to pay a share of embassy construction costs would also encourage them to consider the full cost of their overseas presence and to determine the number of people they need to meet critical overseas missions. 

Several non-State agencies have raised concerns about the proposed cost-sharing formula and implementation issues that could adversely affect their overseas missions. According to our analysis, agencies' cost-sharing fees under other formulas would vary widely, with some agencies benefiting at the expense of others. While we take no position on which formula should be used, some type of cost-sharing mechanism could 

provide a disciplined approach to the staffing projection and rightsizing processes and accelerate the capital construction program. 

Several agencies suggested that it would be useful to establish new interagency mechanisms to discuss and resolve potential disputes. We did not assess the mechanisms to be used to implement the program, if Congress enacts it. Therefore, we have taken no position on whether new interagency mechanisms would be needed. Nevertheless, in our prior work, we have noted the importance of achieving interagency consensus and striving to achieve equity, while minimizing management burden. Decision-makers need to continually focus on these factors in order to give the program every opportunity to succeed. There is time to address these and other potential implementation issues during the 5-year phase-in period of the program. If the proposed program is enacted, it is important that Congress and State monitor the program's implementation and make changes as needed. 

  Agency Comments and Our Evaluation 

We received written comments on a draft of this report from eight executive departments and agencies (Departments of Agriculture, Commerce, Health and Human Services, Homeland Security, Justice, State, the Treasury, and the U.S. Agency for International Development) and the Library of Congress. The Department of State said that the report is a fair and accurate representation of the issue. The other departments and agencies raised a number of concerns regarding accountability and equity issues if the program is implemented. Their comments, along with our responses to specific points, are reprinted in appendixes II-X. Several agencies also provided technical comments, which we have incorporated into the report where appropriate. 

Several agencies stated that using a cost-sharing formula based on the number of personnel overseas was not equitable. We have taken no position on the formula to be used. Our report points out the advantages and disadvantages of potential formulas and that some agencies may benefit at the expense of others, depending on the formula used. 

We are sending copies of this report to interested congressional committees. We are also providing copies of this report to the Secretaries of Agriculture, Commerce, Defense, Health and Human Services, Homeland Security, Justice, State, and the Treasury; the Administrator, U.S. 

Agency for International Development; the Director, Office of Management 
and Budget; and the Librarian of Congress. We will also make copies 
available to others upon request. In addition, this report will be available at 
no charge on the GAO Web site at http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 
me on (202) 512-4128. John Brummet, Lynn Cothern, Martin De Alteriis,
Mary Moutsos, Julia A. Roberts, and George Taylor made key contributions 
to this report.

Sincerely yours,

Jess T. Ford Director, International Affairs and Trade

Appendix I 

                       Objectives, Scope, and Methodology

Our objectives were to examine (1) the Department of State's rationale for and development of the proposed Capital Security Cost-Sharing Program, (2) agency concerns about the program, and (3) the influence of the proposed program on agencies' decisions on overseas staff levels. To complete our work, we analyzed data, reviewed documents, and discussed the program in Washington, D.C., with officials of State's Bureau of Overseas Buildings Operations (OBO), which is responsible for the embassy construction program; the Office of Management and Budget (OMB); and eight other executive branch departments and agencies, including the Departments of Agriculture, Commerce, Defense, Health and Human Services, Homeland Security, Justice,and the Treasury, and the U.S. Agency for International Development (USAID). We also reviewed documents and held discussions in Washington, D.C., with officials of the Library of Congress, a legislative branch agency. We selected the executive branch departments and agencies because they have staff overseas and, under the current proposal, would have the largest annual cost-sharing charges. We selected the Library of Congress because it is the only nonexecutive branch agency that would pay cost-sharing fees. 

To describe the overall rationale for and development of the proposed program, we examined numerous reports and other documents, including those issued by OBO, the Overseas Presence Advisory Panel, and other working groups and committees. We reviewed historical information dating back to 1999, including the alternative formulas OBO considered before selecting the head-count formula to assess agencies' fees for embassy construction. We reviewed documents and held discussions in Washington, D.C., with officials of nine executive branch agencies or departments with the largest cost-sharing fee assessments and with the Library of Congress. In addition, we met with OMB officials to discuss agencies' concerns about some aspects of the proposed program and General Services Administration to discuss its management of U.S. government facilities domestically. 

We conducted data analyses using data from the International Cooperative Administrative Support Services (ICASS) system Global Database, which was developed and maintained by the ICASS Service Center and contains information for each overseas post. We assessed the reliability of the ICASS data during a recent review of State's Embassy Administrative Support 

Appendix I
Objectives, Scope, and Methodology

System.1 The assessment included (1) performing electronic testing for errors in accuracy and completeness, (2) discussing data reliability issues with agency officials knowledgeable about the data, and (3) reviewing relevant reports from State's Office of the Inspector General and GAO and financial audits of the ICASS system. We found that the data were also sufficiently reliable for the purpose of determining agencies' space occupied worldwide that was compared with alternative formulas. Data showing estimates for future costs under the Capital Security Cost-Sharing Program were provided in a briefing by staff from OBO. We interviewed knowledgeable officials about the estimating methodology and reviewed some supporting documents, but we did not conduct a full review of the procedures OBO used for these estimations. 

To examine and compare alternative cost-sharing formulas, we selected seven agencies, four that have a larger number of staff worldwide (State, Defense, Commerce, and USAID) and three agencies with a smaller number of staff working overseas (Agriculture, Health and Human Services, and the Library of Congress). To determine alternative cost
sharing percentages for agencies with overseas staff, we allocated costs for ICASS personnel proportionately. We used OBO staffing data that excluded Peace Corps staff, Marine Security Guards, and various other positions permanently stationed in host government facilities or specialized research or technical facilities. We determined that the data were sufficiently reliable for determining cost-sharing percentages. 

To determine the amount each agency would have to pay under two rent formulas, we used OBO data that we had determined to be sufficiently reliable for the purpose of this report and computed the percentage of space each agency occupies. OBO's data were included in a database that listed the total worldwide space at each post and the total space occupied per agency at each post. To find out how much each agency would pay annually to raise $1.4 billion under this formula, we multiplied each agency's percentage of space occupied worldwide by $1.4 billion. To determine how OBO would generate $1.4 billion annually using a rental formula, we used OBO's 2002 data for fees that would have generated $575 million annually, which took into consideration the cost of commercial space per location, security and classified space for each post, 

1GAO, Embassy Management: Actions Are Needed to Increase Efficiency and
Improve Delivery of Administrative Support Services,
GAO-04-511 (Washington, D.C.: Sept. 7, 2004). 

Appendix I
Objectives, Scope, and Methodology

and multiplied the fees by 2.4 to compare them with formulas that raise $1.4 billion annually. To determine the proportionate percentages and cost
sharing fees for each type of office space at one embassy, we selected a post scheduled for construction in 2006 and used the data that OBO provided, listing the number of agencies, staff and types of space occupied for each staff member. OBO's estimated cost to build the facility would be $92.2 million as listed in OBO's long-range overseas building plan. We used OBO's estimate of the total square footage for the post and determined the amount and percentage of space needed for the chief of mission, controlled access, noncontrolled access, and nonoffice areas. We then divided the amounts for each area by the total area to determine the total costs to build the embassy for each type of space. We determined the data were sufficiently reliable to illustrate the effects of the number of staff on agencies' costs. 

To describe the actions agencies have taken to reassess their overseas staffing levels, we collected documentation on each agency's staffing numbers and types of space for chief of mission, controlled access area, noncontrolled access area, and nonoffice space that were used to calculate cost-sharing fees for fiscal year 2005 budget requests. To assess the reliability of these data, we verified the amount each agency requested by reviewing budget submission documents provided by several agencies and through discussions with knowledgeable agency officials. We determined that the data were sufficiently reliable for the purpose of this report. We then compared the fees to each agency's revised staffing numbers and the space requirements used to calculate cost-sharing fees for fiscal year 2006 budget requests. Revisions to the numbers of staff or the types of space resulted in savings for five agencies. We also discussed with OBO officials how agencies' revised staff numbers and space requirements would affect future embassy construction plans. To determine the amount in international program budgets that selected agencies would need to cover cost-sharing fees in fiscal years 2005, 2007, and 2009, we obtained the figures on budget requests for fiscal year 2005. We then used OBO data showing projected cost-sharing fees for each agency in fiscal years 2007 and 2009. To determine the amount and percentage that the international budget for each agency would have to grow to cover their cost-sharing fees, we added the amount they would need in fiscal years 2007 and 2009 to their international budget request for fiscal year 2005 and determined the difference. We determined that these data were sufficiently reliable for the purpose of providing a broad indication of the amounts the agencies would 

Appendix I
Objectives, Scope, and Methodology

need to increase their budgets for the chosen years. We assumed that each agency's program budget would not increase for any other reason than Capital Security Cost-Sharing Program fees. 

Appendix II 

Comments from the Department of Agriculture 

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

See comment 1.

See comment 2.

Appendix II
Comments from the Department of
Agriculture

                                 See comment 3.

                                 See comment 4.

                                  Appendix II
                        Comments from the Department of
                                  Agriculture

The following are GAO's comments on the Department of Agriculture's
letter dated October 12, 2004.

GAO Comments 1.	We agree that mission goals are a critical factor
in determining resource levels. However,
we believe that security and cost factors also need to
be fully considered along with mission goals in determining overseas staffing levels. In our prior reports, we presented a rightsizing framework
to help decision-makers focus on security, mission, and cost
trade-offs associated with staffing levels and rightsizing options. 1 We
believe that the proposed Capital Security Cost-Sharing Program will
encourage agencies to more closely scrutinize overseas staffing levels
by requiring agencies to pay a share of the embassy construction costs
associated with their overseas presence.

2.	OBO officials stated that it solicited and received substantive input
from other agencies during the design of the proposed program. We
acknowledge that Agriculture and some other agencies have concerns about issues concerning accountability, transparency, and other
implementation mechanisms.

3.	We agree that the proposed program would be large and could have a major impact on agencies, but we believe the program is consistent
with the criteria for rightsizing we previously reported. These criteria
include (1) security of facilities and employees, (2) mission priorities
and requirements, and (3) cost of operations, all of which should be systematically evaluated. Agencies must provide a strong rationale to Congress for overseas programs, including all associated costs. 

4.	We acknowledge that agencies have concerns about potential risks they may encounter if the program is enacted. However, we concluded that
some type of cost-sharing program
would achieve important goals, such as accelerating the construction of new secure facilities. In addition, requiring agencies to pay a share of embassy construction costs would also encourage them to consider the full cost of their

1GAO, Overseas Presence: Framework for Assessing Embassy Staff Levels Can
Support Rightsizing Initiatives, GAO-02-780 (Washington, D.C.: July 26,
2002) and Overseas Presence: Rightsizing Framework Can Be Applied at U.S.
Diplomatic Posts in Developing Countries, GAO-03-396
(Washington, D.C.: Apr. 7, 2003).

Appendix II
Comments from the Department of
Agriculture

overseas presence and to determine
the number of people they need to meet critical overseas missions.

Appendix III

Comments from the Department of Commerce

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

Appendix III
Comments from the Department of
Commerce

                                 See comment 1.

Appendix III
Comments from the Department of
Commerce

                                 See comment 2.

                                 See comment 3.

                                 See comment 4.

Appendix III
Comments from the Department of
Commerce

                                 See comment 5.

                         See comment 6. See comment 7.

                                 See comment 8.

                                 See comment 9.

                                 See comment 9.

                                 See comment 8.

                                  Appendix III
                        Comments from the Department of
                                    Commerce

The following are GAO's comments on the Department of Commerce's
letter dated October 14, 2004.

GAO Comments 1.

2.

3.

4.

5.

6.

7.

8.

We did not assess the need for improvements in business processes and management controls. If the program were to be enacted, there would be time during the phase-in period to monitor these issues and address other concerns that may arise.

We believe that agencies should request the appropriate funding in their budget submissions and be prepared to make adjustments if funds are not forthcoming. If funding is not provided, agencies may have to reconsider the size of their overseas presence and/or adjust their missions.

Our report discusses several cost-sharing formulas and some of their
advantages and disadvantages. We discuss agency views on the
formulas, and OBO stated that under some formulas agencies could "game the system" to reduce their cost share.

We did not assess the mechanisms, including the interagency advisory group, that could
be used to implement the program, if Congress enacts it. Therefore, we have taken no position on whether alternative interagency mechanisms would be needed.

We did not include agencies' annual charges for embassy construction attributable to ICASS support services in
the table. However, under the program,
agencies will be expected to pay a share of the embassy construction costs attributable to administrative support service received under ICASS.

As noted, fiscal year 2008 data were not available.

The OBO data included offsets.

We agree that, if some agencies pull out of the proposed program, the
remaining agencies' cost-sharing charges may increase. However,
depending on the extent to which agencies consider the size of their
overseas presence, OBO's costs for constructing fewer and/or smaller facilities may decrease and result
in decreased costs to agencies.

Appendix III
Comments from the Department of
Commerce

9.	We modified the text on page 15 and footnoted table 4 to reflect these comments and attributed the information to the Department of Commerce.

Appendix IV

Comments from the Department of Health and Human Services

Note: GAO comment supplementing those in the report text appear at the end
of this appendix.

Appendix IV
Comments from the Department of Health
and Human Services

                                 See comment 1.

                                 See comment 1.

Appendix IV
Comments from the Department of Health
and Human Services

                                  Appendix IV
                     Comments from the Department of Health
                               and Human Services

The following is GAO's comment on the Department of Health and Human Services' letter dated October 12, 2004. 

GAO Comment 1.	We did not assess the mechanisms to be used to implement the program, if Congress enacts it. Therefore, we have taken no position on whether alternative interagency mechanisms would be needed. 

Appendix V 

Comments from the Department of Homeland Security 

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

See comment 1.

Appendix V Comments from the Department of Homeland Security

                                 See comment 2.

          Appendix V Comments from the Department of Homeland Security

The following are GAO's comments on the Department of Homeland Security's letter dated October 13, 2004.

GAO Comments 1.	We agree that the proposed program could impact
agencies' missions if
funding decisions result in reductions of overseas staff positions. However, as we discuss in the report, the concept of cost sharing encourages all agencies to seriously consider their overall program mission and the costs of having staff overseas. We
believe that agencies should request the appropriate funding in their
budget submissions and be prepared to make adjustments if funds are
not forthcoming. If
funding is not provided, agencies may have to reconsider the size of
their overseas presence and/or adjust their missions.

2.	Security issues associated with foreign housing and schools were not in
the scope of our work. 

                                  Appendix VI

                    Comments from the Department of Justice

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

See comment 1.

See comment 2.

Appendix VI
Comments from the Department of Justice

                                 See comment 1.

                                  Appendix VI
                    Comments from the Department of Justice

The following are GAO's comments on the Department of Justice's letter
dated October 12, 2004.

GAO Comments 1.

2.

We did not assess the need for improvements in business processes and management controls, such as transparency
and accountability of costs
and spending controls. If the program were to be enacted, there would be time during the phase-in period to monitor these issues and address other concerns that may arise.

We agree that the proposed program could impact agencies' missions if
funding decisions result in reductions of overseas staff positions. However, as we discuss in the report, the concept of cost sharing encourages all agencies to seriously consider their overall program mission and the costs of having staff overseas. We
believe that agencies should request the appropriate funding in their
budget submissions and be prepared to make adjustments if funds are
not forthcoming. If
funding is not provided, agencies may have to reconsider the size of
their overseas presence and/or adjust their missions. 

                                  Appendix VII

                     Comments from the Library of Congress

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

Appendix VII
Comments from the Library of Congress

                                 See comment 1.

                                 See comment 2.

                                 See comment 3.

                                 See comment 4.

Appendix VII
Comments from the Library of Congress

                                 See comment 5.

                                 See comment 6.

                                 See comment 7.

                                  Appendix VII
                     Comments from the Library of Congress

The following are GAO's comments on the Library of Congress letter
dated October 12, 2004.

GAO Comments 1.

2.

3.

4.

5.

We were not asked to express an opinion on whether the cost
accounting standards of the federal government apply to the capital
cost-sharing program. However, we did note that State and non-State agencies disagree on whether there is a link between the amounts to be paid and the benefits received.

The administration proposed the Capital Security Cost-Sharing Program to fund
the accelerated construction of secure new embassies
and consulates worldwide and to ensure that agencies rightsize the
number of staff needed to accomplish their overseas missions. Our
analysis shows that, depending on the formula used, cost-sharing
amounts would vary considerably, with some agencies benefiting at the expense of others. While we take no position on which formula should be used, some type of cost-sharing mechanism could provide a disciplined approach to the staffing projection and rightsizing processes and accelerate the capital construction program

We have taken no position on which cost-sharing formula, including the "head-tax" approach (which we refer to as the head-count approach), should be used. We also did not assess the need for improvements in
business processes and management controls, such as determining the number of staff required. We acknowledge that some agencies have concerns about potential risks if the program is enacted. However, we concluded that some type of cost-sharing program would achieve important goals, such as accelerating the construction of new secure facilities. In addition, requiring agencies to pay a share of embassy construction costs
would also encourage them to consider the full cost of
their overseas presence and to determine the number of people they
need to meet critical overseas missions.

The administration proposed the Capital Security Cost-Sharing Program to fund
the accelerated construction of secure new embassies
and consulates worldwide and to ensure that agencies rightsize the
number of staff needed to accomplish their overseas missions. 

We agree that, if some agencies pull out of the proposed program, the
remaining agencies' cost-sharing charges may increase. However,
depending on the extent to which agencies consider the size of their

Appendix VII
Comments from the Library of Congress

overseas presence, OBO's costs for constructing fewer and/or smaller facilities may decrease and result
in decreased costs to agencies. Congress will decide whether or not the Department of Defense will
participate in the cost-sharing program.

6.	The proposed program is intended to capture the full costs, not only support costs, to agencies for staff in overseas locations, including construction of new embassy compounds. While we recognize that the Library currently has staff located outside embassy compounds, with the 1999 enactment of the Secure Embassy and Counterterrorism Act, all staff are required to be colocated onsite at locations where new embassies are built.

7.	We recognize that the Library has only seven Americans in six offices. Our report does not suggest that the Library is not rightsized. However, the Library and other agencies should request the appropriate funding in their budget submissions and be prepared to make adjustments if
funds are not forthcoming.

                                 Appendix VIII

                     Comments from the Department of State

Note: GAO commentssupplementing those inthe report text appear at the end
of thisappendix.

Appendix VIII
Comments from the Department of State

                                 See comment1.

                                 See comment 2.

Appendix VIII
Comments from the Department of State

                                 See comment 3.

                                 See comment 4.

                                 See comment 5.

Appendix VIII
Comments from the Department of State

                                 See comment 6.

                                 See comment 7.

                                 Appendix VIII
                     Comments from the Department of State

The following are GAO's comments on the Department of State's letter dated October 7, 2004.

GAO Comments 1.

2.

3.

4.

5.

6.

7.

We modified the text in the Highlights and cover letter to reflect these comments.

We organized the report as we did because the influence of the
proposed program on agencies' overseas staffing-level decisions is
uncertain.

We modified the text in the Highlights to reflect this comment and
attributed the additional comment to OBO. 

We modified the text in the Highlights and on pages 5 and 13 to reflect State's phase-in period.

We modified the text on pages 10 and 11 to reflect these comments.

We added a footnote on page 4 to clarify the number of overseas locations.

We added a footnote on page 8 to explain the role of the OPAP.

Appendix IX

Comments from the Department of the Treasury

Appendix X

Comments from the U.S. Agency for International Development

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

See comment 1.

Appendix X
Comments from the U.S. Agency for
International Development

                                 See comment 2.

                                 See comment 3.

                                   Appendix X
                       Comments from the U.S. Agency for
                           International Development

The following are GAO's comments on the U.S. Agency for International
Development's letter dated October 8, 2004.

GAO Comments
1.	Issues involving State's planning for the size of new embassies were not in the scope of our review. Our recent reports on this issue include
Embassy Construction: Process for Determining Staffing Requirements Needs
Improvement, GAO-03-411 (Washington, D.C.: Apr. 7, 2003) and Embassy
Construction: State Department Has Implemented Management Reforms, but
Challenges Remain, GAO-04100 (Washington, D.C.: Nov. 4, 2003).

2.	We did not include agencies' annual charges for embassy construction attributable to ICASS support services in
the table. However, under the program,
agencies would be expected to pay a share of the embassy
construction costs attributable to administrative support service received under ICASS.

3.	State's prioritization for building new
embassy compounds was not included in the scope of our review. See Embassy
Construction: State Department Has Implemented Management Reforms, but
Challenges Remain, GAO-04-100 (Washington, D.C.: Nov.
4, 2003), for a discussion of these issues. 

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

Obtaining Copies of
The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO's Web site (www.gao.gov). Each weekday, GAO postsGAO Reports and newly released reports, testimony, and correspondence on its Web site. To
Testimony have GAO e-mail you a list of newly posted
products every afternoon, go to

www.gao.gov and select "Subscribe to Updates."

Order by Mail or Phone	The first copy of each printed report is free. Additional copies are $2 each. A check or money order should be made out to the Superintendent of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or more copies mailed to a single address are discounted 25 percent. Orders
should be sent to:

U.S. Government Accountability Office 441 G Street NW, Room LM
Washington, D.C. 20548

To order by Phone:	Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202)
512-6061

To Report Fraud, Contact:
Waste, and Abuse in Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: [email protected] Programs
Automated answering system: (800) 424-5454 or (202) 512-7470

Congressional	Gloria Jarmon, Managing Director, [email protected] (202) 512-4400
U.S. Government Accountability Office, 441 G Street NW, Room 7125

Relations Washington, D.C. 20548

Public Affairs	Susan Becker, Acting Manager,
[email protected] (202) 512-4800
U.S. Government Accountability Office, 441 G Street NW, Room 7149 Washington, D.C. 20548
*** End of document. ***