Review of DOD's Report on Budgeting for Exchange Rates for Foreign Currency Fluctuations
Gao ID: GAO-05-800R June 16, 2005
The Department of Defense (DOD) expends a significant amount of funds overseas, particularly from its Operation and Maintenance (O&M) and Military Personnel (MILPERS) appropriations. As the rate of overseas currencies fluctuates on a daily basis, such fluctuations have an impact on the various expenditures that DOD makes. For budgeting purposes, DOD establishes foreign currency exchange rates to determine its O&M and MILPERS funding needs. During the fiscal year, DOD incurs expenditures at the actual exchange rate, which varies from the budgeted rate. For example, if the dollar depreciates in value, more dollars are needed to pay for goods and services than originally budgeted. Concerned about whether DOD's method for selecting foreign currency rates has produced realistic estimates in its budget submissions, Congress required DOD to consider alternative methods. Specifically, the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005 required the Secretary of Defense to submit a report on the foreign currency exchange rate projections used in annual DOD budget presentations. The act required that DOD identify alternative approaches, including the feasibility of using private economic forecasting and approaches used by other federal departments and agencies, for selecting foreign currency exchange rates that would produce more realistic estimates of the amounts required for DOD to accommodate foreign currency exchange rate fluctuations. DOD also was required to discuss the advantages and disadvantages of each approach and to identify the department's preferred approach among the alternatives and provide a rationale for preferring that approach. Finally, the act further required that we review DOD's report, including the basis for the Secretary's conclusions for the preferred approach. DOD submitted its report to Congress on April 15, 2005. In response to the act, we examined (1) the extent to which DOD evaluated alternative approaches for selecting budgeted foreign currency rates--such as private economic forecasting companies or approaches used by other federal departments' and DOD's basis for selecting its preferred rate selection approach and (2) the extent to which DOD's preferred approach for forecasting foreign currency exchange rates would produce a more realistic estimate than its historical approach.
DOD evaluated several alternative approaches for selecting budgeted foreign currency rates and selected an approach that it believed would more accurately and objectively predict exchange rates. The alternative approaches included (1) estimates from a private forecasting company; (2) methods used by other federal departments, such as selecting exchange rates on the basis of past execution data and using multiple exchange rates for individual offices; and (3) various statistical methodologies. DOD selected a statistical method referred to as the centered weighted average, which combines both a long-run average of exchange rates and the most recently observed exchange rates to predict future exchange rates. DOD chose this approach because it was based on historical and current data and could be universally replicated; therefore, it was not dependent on subjective judgment. DOD used this method in developing its fiscal year 2006 budget submission. DOD believed that using a combination of both recent and historical data would be an advantage in more accurately predicting future exchange rates because the methodology allows DOD to weight individual currencies to minimize the impact of their volatility over time. According to DOD, they did not choose the private forecasting alternative because of the lack of visibility over key assumptions used in generating the forecast nor did they choose one of the methods used by the other federal departments because the other departments either did not forecast foreign currency rates or they did not have a uniform procedure for setting departmentwide rates. DOD selected a reasonable approach for forecasting foreign currency rates that can produce a more realistic estimate than its historical approach. Unlike DOD's historical approach, the centered weighted average approach provides a straightforward statistical calculation of historical data that can be easily replicated with no hidden assumptions and is not dependent on subjective judgment. In reaching our conclusion, we compared both the new rates generated using the preferred approach and the rates DOD used to prepare the fiscal year 2004 and 2005 budget submissions based on its historical approach to current actual exchange rates. We found that the new methodology generated rates that more closely reflected actual exchange rates that occurred during the budget year.
GAO-05-800R, Review of DOD's Report on Budgeting for Exchange Rates for Foreign Currency Fluctuations
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June 16, 2005:
The Honorable John Warner:
Chairman:
The Honorable Carl Levin:
Ranking Minority Member:
Committee on Armed Services:
United States Senate:
The Honorable Duncan L. Hunter:
Chairman:
The Honorable Ike Skelton:
Ranking Minority Member:
Committee on Armed Services:
United States House of Representatives:
Subject: Review of DOD's Report on Budgeting for Exchange Rates for
Foreign Currency Fluctuations:
The Department of Defense (DOD) expends a significant amount of funds
overseas, particularly from its Operation and Maintenance (O&M) and
Military Personnel (MILPERS) appropriations. As the rate of overseas
currencies fluctuates on a daily basis, such fluctuations have an
impact on the various expenditures that DOD makes. For budgeting
purposes, DOD establishes foreign currency exchange rates to determine
its O&M and MILPERS funding needs. During the fiscal year, DOD incurs
expenditures at the actual exchange rate, which varies from the
budgeted rate. For example, if the dollar depreciates in value, more
dollars are needed to pay for goods and services overseas than
originally budgeted.
Concerned about whether DOD's method for selecting foreign currency
rates has produced realistic estimates in its budget submissions,
Congress required DOD to consider alternative methods. Specifically,
the Ronald W. Reagan National Defense Authorization Act for Fiscal Year
2005 required the Secretary of Defense to submit a report on the
foreign currency exchange rate projections used in annual DOD budget
presentations.[Footnote 1] The act required that DOD identify
alternative approaches, including the feasibility of using private
economic forecasting and approaches used by other federal departments
and agencies, for selecting foreign currency exchange rates that would
produce more realistic estimates of the amounts required for DOD to
accommodate foreign currency exchange rate fluctuations. DOD also was
required to discuss the advantages and disadvantages of each approach
and to identify the department's preferred approach among the
alternatives and provide a rationale for preferring that approach.
Finally, the act further required that we review DOD's report,
including the basis for the Secretary's conclusions for the preferred
approach. DOD submitted its report to Congress on April 15, 2005.
In response to the act, we examined (1) the extent to which DOD
evaluated alternative approaches for selecting budgeted foreign
currency rates--such as private economic forecasting companies or
approaches used by other federal departments--and DOD's basis for
selecting its preferred rate selection approach and (2) the extent to
which DOD's preferred approach for forecasting foreign currency
exchange rates would produce a more realistic estimate than its
historical approach.
In conducting our work, we examined the alternative approaches explored
by DOD for selecting budgeted foreign currency exchange rates and DOD's
reported advantages and disadvantages of each approach. We interviewed
responsible officials from the Office of the Under Secretary of
Defense, Comptroller to obtain DOD's rationale for deciding on its
preferred rate selection approach. We independently calculated a sample
of DOD's fiscal year 2006 budgeted foreign currency exchange rates that
were generated using DOD's preferred approach to validate that the
rates could easily be replicated. We also compared the use of DOD's
preferred approach with its historical approach to determine their
impact on developing budgetary estimates. We calculated how both the
rates generated by DOD's preferred approach and the rates used to
prepare the budget submissions for fiscal years 2004 and 2005 compared
with current actual exchange rates as of May 2005. We conducted our
work from November 2004 to June 2005 in accordance with generally
accepted government audit standards.
Summary:
DOD evaluated several alternative approaches for selecting budgeted
foreign currency rates and selected an approach that it believed would
more accurately and objectively predict exchange rates. The alternative
approaches included (1) estimates from a private forecasting company;
(2) methods used by other federal departments, such as selecting
exchange rates on the basis of past execution data and using multiple
exchange rates for individual offices; and (3) various statistical
methodologies. DOD selected a statistical method referred to as the
centered weighted average, which combines both a long-run average of
exchange rates and the most recently observed exchange rates to predict
future exchange rates. DOD chose this approach because it was based on
historical and current data and could be universally replicated;
therefore, it was not dependent on subjective judgment. DOD used this
method in developing its fiscal year 2006 budget submission. DOD
believed that using a combination of both recent and historical data
would be an advantage in more accurately predicting future exchange
rates because the methodology allows DOD to weight individual
currencies to minimize the impact of their volatility over time.
According to DOD, they did not choose the private forecasting
alternative because of the lack of visibility over key assumptions used
in generating the forecast nor did they choose one of the methods used
by the other federal departments because the other departments either
did not forecast foreign currency rates or they did not have a uniform
procedure for setting departmentwide rates.
DOD selected a reasonable approach for forecasting foreign currency
rates that can produce a more realistic estimate than its historical
approach. Unlike DOD's historical approach, the centered weighted
average approach provides a straightforward statistical calculation of
historical data that can be easily replicated with no hidden
assumptions and is not dependent on subjective judgment. In reaching
our conclusion, we compared both the new rates generated using the
preferred approach and the rates DOD used to prepare the fiscal year
2004 and 2005 budget submissions based on its historical approach to
current actual exchange rates. We found that the new methodology
generated rates that more closely reflected actual exchange rates that
occurred during the budget year.
DOD officials reviewed a draft of this report and agreed with its
content.
Background:
Each fiscal year, DOD establishes budgeted foreign currency exchange
rates (units of foreign currency per one U.S. dollar) to use when
determining its O&M and MILPERS funding needs. In past years, DOD
tracked foreign currency exchange rates in the Wall Street Journal on a
daily basis during the months immediately preceding the budget
submission and then selected the most favorable foreign currency
exchange rates, which provide the highest amount of foreign currency
per dollar, during this timeframe. For the fiscal year 2004 budget
submission, DOD selected the most favorable rates from August through
November 2002. For the fiscal year 2005 submission, DOD did not revise
its rates. It continued to use exactly the same rate contained in the
fiscal year 2004 budget submission. We have previously briefed your
office in the past that the use of the most favorable foreign currency
rates underestimates the impact of foreign currency fluctuations and
therefore results in a budget submission that does not realistically
reflect funding requirements for O&M and MILPERS expenses. While many
methods can be used to forecast foreign currency exchange rates, some
methods may produce rates that are better estimates of actual foreign
currency trends. For fiscal year 2006, DOD changed its methodology for
setting budgeted foreign currency exchange rates and used a centered
weighted average approach. This approach combines both a long-run
weighted average of exchange rates and a weighted average of the most
recently observed exchange rate to predict future exchange rates.
DOD Considered Alternative Approaches and Selected a Statistical Method:
In meeting its legislative requirement, DOD considered alternate
approaches for determining foreign currency exchange rates to use in
developing its budget request. These approaches included: estimates
from a private forecasting company, methods used by other federal
departments, and various statistical methodologies for selecting
budgeted foreign currency rates. DOD selected a statistical method, the
centered weighted average that it thought would more closely reflect
actual rates that occur during the budget year. DOD used this method to
set its fiscal year 2006 rates.
DOD considered using a private economic forecasting company as an
approach for establishing budgeted foreign currency exchange rates and
cited several advantages and disadvantages in its report. According to
the report, a private forecasting company would provide DOD with
forecasted foreign currency exchange rates calculated by the company
using its own assumptions and methods. It also stated that the
advantage of using a private forecasting company would be that it
provides a quick way to acquire foreign currency exchange rates because
the rates are already established by the company. The report further
noted that a disadvantage of using a private forecasting company would
be that DOD would incur additional costs since the department would
have to purchase the forecasted rates from the private company. Also,
DOD stated that another disadvantage would be that the approach would
not provide a straightforward methodology that could be explained to
decision makers because the assumptions and methods used to forecast
the exchange rates are produced and owned by the company and would not
be disclosed to DOD. Additionally, the report noted that the use of a
forecasting company would raise questions as to why a particular
company was selected instead of another one. According to DOD
officials, for these reasons, DOD did not consider using a private
forecasting company to be a viable option.
In its report, DOD also evaluated approaches used by other federal
departments to set budgeted foreign currency exchange rates. DOD
contacted five federal departments but found no foreign currency
budgeting procedures in use that would meet DOD's needs. DOD contacted
the Departments of Education, Energy, Justice, State, and Agriculture.
The Departments of Education, Energy, and Justice did not purchase
foreign currency. Therefore, they had no reason to forecast. The
Department of State used past execution rates and thus did not forecast
future market foreign currency exchange rates in its budget
submissions. The Department of Agriculture used forecasted exchange
rates in developing its budget. However, the department included 80
different budget estimates from its various offices and each office
could use a different methodology to produce the forecasted rates.
Thus, Agriculture had no uniform procedure for setting departmentwide
budgeted foreign currency exchange rates. Consequently, DOD did not
choose one of the methods used by another federal department because
they either did not forecast foreign currency rates or they did not
have a uniform procedure for setting departmentwide rates.
DOD also reviewed several statistical methodologies to forecast foreign
currency exchange rates, such as linear forecasting, moving averages,
exponential smoothing, simple average, and a centered weighted average.
All of these statistical methodologies are traditional techniques that
use data to predict future trends. DOD found that the advantages of
statistical approaches are that the methodologies are clear and can be
replicated. In addition, these statistical methods do not have hidden
assumptions and the subjectivity associated with DOD's selection of
past foreign currency exchange rates would be eliminated. We have
previously briefed your office that the use of the most favorable
foreign currency rates underestimates the impact of foreign currency
fluctuations and therefore results in a budget submission that does not
realistically reflect funding requirements for O&M and MILPERS
expenses.
DOD selected the centered weighted average approach as its preferred
approach for establishing budgeted foreign currency exchange rates for
fiscal year 2006. DOD believed that this method would result in rates
that more closely reflect actual foreign currency rates because it
combined both a long-run average of exchange rates and the most recent
observed rates. This approach allowed DOD to weight individual
currencies thus minimizing volatility over time. The centered weighted
average was the only statistical methodology that used individual
weighting factors for each currency to combine recent data with the
historical average to predict exchange rates. DOD also reported that a
possible disadvantage of using this approach would be that it could
produce a rate that might not appear reasonable if the current market
exchange rates significantly increased or decreased at the time of the
budget submission.
DOD Selected a Reasonable Approach That More:
Realistically Estimates Foreign Currency Exchange Rates:
DOD selected a reasonable approach for forecasting foreign currency
rates that can produce a more realistic estimate than its historical
approach. Unlike DOD's historical approach, the centered weighted
average approach provides a straightforward statistical calculation of
historical data that can be easily replicated with no hidden
assumptions. This type of calculation eliminates the subjectivity in
the rate selection process that was present in the method DOD used to
set budget estimates in prior years, when DOD selected only the most
favorable rates for each foreign currency. We independently verified
DOD's claim that the rates can easily be replicated using this
approach. We calculated a sample of DOD's exchange rates using its
centered weighted average methodology. Our calculations matched the
same rates that DOD generated for its fiscal year 2006 budget
submission.
Our analysis shows that DOD's preferred method for developing foreign
currency exchange rates for budgetary purposes more closely
approximates actual exchange rates that occurred during the budget
year. We compared both (1) the foreign currency rates DOD included in
its fiscal year 2006 budget submission using the centered weighted
average approach and (2) the rates that DOD included in its fiscal year
2004 and 2005 budget submissions using the most favorable rates with
current foreign currency exchange rates as of May 2005. Our analysis
showed a projected loss of almost $775 million (potential difference
between using the budgeted versus actual rates) for fiscal year 2006
using the centered weighted average rates. However, DOD would have
incurred additional losses of about $908 million, totaling about $1.7
billion, had it used the rates it used to build its budget submissions
for fiscal years 2004 and 2005 to predict its fiscal year 2006 budget
estimates.
Agency Comments:
DOD officials reviewed a draft of this report and agreed with its
content.
We are sending copies of this letter to the Senate and House Armed
Services:
Committees. We also will make copies available to others upon request.
In addition, this letter will be available at no charge on GAO's Web
site at http://www.gao.gov.
If you have any questions concerning this letter, please contact me at
(202) 512-9619 or pickups@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this letter. Key contributors to this assignment were Bonita P.
Anderson, Renee S. Brown, Laura L. Durland, Charles W. Perdue, Gina O.
Ruidera, and Michael C. Zola.
Signed by:
Sharon Pickup:
Director,
Defense Capabilities and Management:
(350614):
FOOTNOTES
[1] Pub. L. No. 108-375, §1006 (2004).