Federal User Fees
Fee Design Characteristics and Trade-Offs Illustrated by USCIS's Immigration and Naturalization Fees
Gao ID: GAO-10-560T March 23, 2010
In light of increasing congressional interest in user fee financing, GAO developed a framework for examining user fee design characteristics that may influence the effectiveness of user fees. Specifically, we examined how the four key characteristics of user fees--how fees are set, collected, used, and reviewed--may affect the economic efficiency, equity, revenue adequacy, and administrative burden of cost-based fees. United States Citizenship and Immigration Services (USCIS) is responsible for granting or denying the millions of immigration and naturalization applications each year and charges fees to recover all processing costs. In 2007, USCIS completed a fee review to determine the level at which fees should be set to recover the full cost of its services and increased application fees by an average of 86 percent. USCIS is preparing its first fee review since the 2007 fee increase. It is critical that USCIS and the Congress have the best possible information when overseeing these fees and the operations they fund. This testimony focuses on (1) user fee design and implementation characteristics and criteria, (2) cost assignment and trade-offs identified in USCIS's 2007 fee review, and (3) additional considerations for fee-funded agencies. It is based on past GAO reports, which included recommendations to the Secretary of Homeland Security (DHS). DHS agreed to consider these recommendations in their next fee review.
There are four key design and implementation characteristics of user fees--how fees are set, collected, used, and reviewed. Each design and implementation characteristics presents its own set of decisions to consider and embodies trade-offs among the four criteria that are often used to assess user fees: equity, efficiency, revenue adequacy, and administrative burden. Equity: Equity means that everyone pays his/her fair share, but there is more than one way to think about fair share. Under the beneficiary-pays principle, the beneficiaries of a service pay for the cost of providing the service from which they benefit. Under the ability-to-pay principle, those who are more capable of bearing the burden of fees should pay more for the service than those with less ability to pay. Efficiency: By requiring identifiable beneficiaries to pay for the costs of services, user fees can simultaneously constrain demand and reveal the value that beneficiaries place on the service. If those benefiting from a service do not bear the full social cost of the service, they may seek to have the government provide more of the service than is economically efficient. Revenue adequacy: Revenue adequacy is the extent to which the fee collections cover the intended share of costs. It encompasses the extent to which collections may change over time relative to the cost of the program and the concept of revenue stability, or the degree to which short-term fluctuations in economic activity and other factors affect the level of fee collections. Administrative burden: This is the cost of administering the fee, including the cost of collection and enforcement, as well as the compliance burden. Setting the fee is perhaps is the most challenging of the fee design decisions because determining the cost of the service is often quite complex and requires considering a range of issues. One of the biggest issues in fee setting is how to define and apply the equity criterion, such as determining the overlap between beneficiaries and users, whether to employ a beneficiary pays or ability to pay equity principle, how to address fee exemptions and waivers, and finally, how to assign costs among users. Many of these design choices described in USCIS's 2007 fee review provide transparent analysis and identify deliberate trade-offs. However, USCIS did not conduct the analysis necessary to fully inform either congressional decision making or USCIS's internal deliberations on key areas such as the cost of activities funded by statutorily-set fees that led to unknown cross-subsidizations. When fees are supposed to cover all or a set portion of the costs of an agency or activity the criterion of "revenue adequacy" may be especially important to consider. For example, a reserve is important for fully fee-funded programs because it provides a cushion if program costs would not drop proportionally with a drop in fee collections. A reserve could also help support preparation for any anticipated surge in users, especially if fee collections would come after the expenditures to prepare for the surge.
GAO-10-560T, Federal User Fees: Fee Design Characteristics and Trade-Offs Illustrated by USCIS's Immigration and Naturalization Fees
This is the accessible text file for GAO report number GAO-10-560T
entitled 'Federal User Fees: Fee Design Characteristics and Trade-Offs
Illustrated by USCIS's Immigration and Naturalization Fees' which was
released on March 23, 2010.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as
part of a longer term project to improve GAO products' accessibility.
Every attempt has been made to maintain the structural and data
integrity of the original printed product. Accessibility features,
such as text descriptions of tables, consecutively numbered footnotes
placed at the end of the file, and the text of agency comment letters,
are provided but may not exactly duplicate the presentation or format
of the printed version. The portable document format (PDF) file is an
exact electronic replica of the printed version. We welcome your
feedback. Please E-mail your comments regarding the contents or
accessibility features of this document to Webmaster@gao.gov.
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. 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.
Testimony:
Before the Subcommittee on Immigration, Citizenship, Refugees, Border
Security, and International Law, Committee on the Judiciary, U.S.
House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 2:00 p.m. EDT:
Tuesday, March 23, 2010:
Federal User Fees:
Fee Design Characteristics and Trade-Offs Illustrated by USCIS's
Immigration and Naturalization Fees:
Statement of Susan J. Irving, Director:
Federal Budget Analysis:
Strategic Issues:
GAO-10-560T:
GAO Highlights:
Highlights of GAO-10-560T, a testimony before the Subcommittee on
Immigration, Citizenship, Refugees, Border Security, and International
Law, Committee on the Judiciary, U.S. House of Representatives.
Why GAO Did This Study:
In light of increasing congressional interest in user fee financing,
GAO developed a framework for examining user fee design
characteristics that may influence the effectiveness of user fees.
Specifically, we examined how the four key characteristics of user
fees”how fees are set, collected, used, and reviewed”may affect the
economic efficiency, equity, revenue adequacy, and administrative
burden of cost-based fees. United States Citizenship and Immigration
Services (USCIS) is responsible for granting or denying the millions
of immigration and naturalization applications each year and charges
fees to recover all processing costs. In 2007, USCIS completed a fee
review to determine the level at which fees should be set to recover
the full cost of its services and increased application fees by an
average of 86 percent.
USCIS is preparing its first fee review since the 2007 fee increase.
It is critical that USCIS and the Congress have the best possible
information when overseeing these fees and the operations they fund.
This testimony focuses on (1) user fee design and implementation
characteristics and criteria, (2) cost assignment and trade-offs
identified in USCIS‘s 2007 fee review, and (3) additional
considerations for fee-funded agencies. It is based on past GAO
reports, which included recommendations to the Secretary of Homeland
Security (DHS). DHS agreed to consider these recommendations in their
next fee review.
What GAO Found:
There are four key design and implementation characteristics of user
fees”how fees are set, collected, used, and reviewed. Each design and
implementation characteristics presents its own set of decisions to
consider and embodies trade-offs among the four criteria that are
often used to assess user fees: equity, efficiency, revenue adequacy,
and administrative burden.
Equity: Equity means that everyone pays his/her fair share, but there
is more than one way to think about fair share. Under the beneficiary-
pays principle, the beneficiaries of a service pay for the cost of
providing the service from which they benefit. Under the ability-to-
pay principle, those who are more capable of bearing the burden of
fees should pay more for the service than those with less ability to
pay.
Efficiency: By requiring identifiable beneficiaries to pay for the
costs of services, user fees can simultaneously constrain demand and
reveal the value that beneficiaries place on the service. If those
benefiting from a service do not bear the full social cost of the
service, they may seek to have the government provide more of the
service than is economically efficient.
Revenue adequacy: Revenue adequacy is the extent to which the fee
collections cover the intended share of costs. It encompasses the
extent to which collections may change over time relative to the cost
of the program and the concept of revenue stability, or the degree to
which short-term fluctuations in economic activity and other factors
affect the level of fee collections.
Administrative burden: This is the cost of administering the fee,
including the cost of collection and enforcement, as well as the
compliance burden.
Setting the fee is perhaps is the most challenging of the fee design
decisions because determining the cost of the service is often quite
complex and requires considering a range of issues. One of the biggest
issues in fee setting is how to define and apply the equity criterion,
such as determining the overlap between beneficiaries and users,
whether to employ a beneficiary pays or ability to pay equity
principle, how to address fee exemptions and waivers, and finally, how
to assign costs among users. Many of these design choices described in
USCIS‘s 2007 fee review provide transparent analysis and identify
deliberate trade-offs. However, USCIS did not conduct the analysis
necessary to fully inform either congressional decision making or
USCIS‘s internal deliberations on key areas such as the cost of
activities funded by statutorily-set fees that led to unknown cross-
subsidizations.
When fees are supposed to cover all or a set portion of the costs of
an agency or activity the criterion of ’revenue adequacy“ may be
especially important to consider. For example, a reserve is important
for fully fee-funded programs because it provides a cushion if program
costs would not drop proportionally with a drop in fee collections. A
reserve could also help support preparation for any anticipated surge
in users, especially if fee collections would come after the
expenditures to prepare for the surge.
View [hyperlink, http://www.gao.gov/products/GAO-10-560T] or key
components. For more information, contact Susan J. Irving at (202) 512-
6806 or irvings@gao.gov.
[End of section]
Chairwoman Lofgren, Mr. King, Members of the Subcommittee:
It is a pleasure to join you today as you think about issues related
to the U.S. Citizenship and Immigration Services' (USCIS) user fees.
User fees can be designed to reduce the burden on taxpayers by
financing the portions of activities that provide benefits to
identifiable users above and beyond what is normally provided to the
public. By charging the costs of programs or activities to
identifiable beneficiaries, user fees can promote economic efficiency
and equity just as prices for goods and services can do in a free and
competitive market. However, to achieve these goals, user fees must be
well designed.
In light of recent increased congressional interest in user fee
financing, we at GAO developed a normative framework for examining
user fee design characteristics that may influence the effectiveness
of user fees. Specifically, our federal user fee design guide examined
how the four key design and implementation characteristics of user
fees--how fees are set, collected, used, and reviewed--may affect the
economic efficiency, equity, revenue adequacy, and administrative
burden of cost-based fees.[Footnote 1] Since 2007, we have examined a
variety of federal user fees--including those at USCIS--in the context
of this framework. I am pleased to be here today to talk about
effective user fee design in general and USCIS fees in particular.
As this subcommittee knows, USCIS is responsible for granting or
denying the millions of immigration and naturalization applications it
receives each year and charges fees to recover all processing costs.
[Footnote 2] In February 2007, USCIS completed a fee review to
determine the level at which fees should be set to recover the full
cost of its services. USCIS's most recent fee schedule, which became
effective July 30, 2007, increased application fees by an average of
86 percent.[Footnote 3] The fee schedule was widely questioned, in
part because of the magnitude of the increases and in part because of
the agency's failure to foresee and manage the surge in applications
received immediately before the effective date of the fee increases.
USCIS is preparing its first fee review since the 2007 fee increase.
The time is ripe for analyzing and understanding the elements and
trade-offs in designing a fee structure so that both USCIS and the
Congress have the best possible information available to them when
overseeing these fees and the critical operations they fund. Further,
because USCIS's operations are mostly funded by user fees, it is
critical that fee collections and operating costs remain aligned to
ensure collections are sufficient such that applicants may enjoy
continued access to the timely, high-quality services they deserve.
As agreed with this Subcommittee, my testimony today focuses on:
1. user fee design and implementation characteristics and criteria,
2. cost assignment and trade-offs identified in USCIS's 2007 fee
review, and:
3. additional considerations for fee-funded agencies.
Before doing that, however, I would like to step back and talk a bit
about some important considerations for the practical application of
any normative framework.
Any user fee design embodies trade-offs among the four dimensions of
equity, efficiency, revenue adequacy, and administrative burden. While
there are purely analytic aspects to each of these criteria, the trade-
offs depend on policy and value decisions. No single design will
satisfy everyone on all dimensions--every fee design will have pluses
and minuses--and the weight that different policymakers place on
different criteria will vary depending on how they value different
attributes. As a general rule, the design of a fee should be viewed in
its entirety. Focusing only on the pros and cons of any single design
element can obscure how the pieces fit together and could make it
difficult to achieve consensus on a fee's design. Instead,
policymakers will ultimately need to balance the relative importance
they place on each of these criteria and focus on the overall fee
design. Moreover, there will undoubtedly be cases in which policy
considerations outweigh normative design principles.
My testimony today is based on GAO reports and testimonies issued from
May 2008 through January 2009 on the principles of effective user fee
design in general and on USCIS's user fees and fee review
specifically. In developing the design guide, we reviewed economic and
policy literature on federal and nonfederal user fees, including our
prior work on user fees. To review USCIS's fee structure, we reviewed
legislation and agency documentation, such as the proposed and final
Federal Register notices regarding the 2007 fee schedule and USCIS's
February 2007 fee review analysis. We conducted the work for both of
those reports according to generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Fee Design and Implementation Characteristics and Criteria:
Each of the four design and implementation characteristics presents
its own set of decisions to consider. In this statement I touch
briefly on the main considerations at each stage; a summary of key
questions to consider is included in appendix I.
Setting user fees: For cost-based fees, the extent to which a program
provides benefits to the general public versus to identifiable users,
and the cost of providing those benefits should, in the abstract,
guide how much of total program costs are paid for by user fees and
the amount each user pays.
Collecting user fees: The primary challenge of determining when and
how to collect a fee is striking a balance between ensuring compliance
and minimizing administrative costs. In some cases, the collection
systems of another agency or a nonfederal entity, such as a private
sector enterprise, may be leveraged, as when the airlines collect
passenger inspection fees.
Using user fees: Determining how fees will be used is a balancing act
between Congressional oversight and agency flexibility. Congress gives
agencies various degrees of access to collected fees. For example,
fees may be dedicated to the related program or may instead be
deposited to the general fund of the U.S. Treasury and not used
specifically for the related program or agency. In addition, fee
collections may be subject to appropriation or obligation limits,
which increase opportunity for oversight but may limit agencies'
ability to quickly respond to changing conditions.
Reviewing user fees: Agencies must substantively review their fees on
a regular basis to ensure that they, the Congress, and stakeholders
have complete information. Reviews provide information on whether the
fee rates and authorized activities are aligned with actual program
costs and activities, may provide opportunities for stakeholder input,
and can help promote understanding and acceptance of the fee.
Criteria for Assessing Design:
Our May 2008 user Fee Design Guide discusses four criteria that are
often used to assess user fees and taxes: (1) equity, (2) efficiency,
(3) revenue adequacy and (4) administrative burden on the agency and
payers of the fees. As I noted, these criteria interact and are often
in conflict with each other; as such, there are trade-offs to consider
among the criteria when designing a fee. Further, the design
characteristics are interrelated: how you set the fees can influence
the activities for which they are used, and how often they are
reviewed can influence the level at which the fee is set. To
understand the implications of any fee design, it is important to
understand the options and trade-offs between these criteria.
Equity: Equity means that everyone pays his/her fair share, but there
is more than one way to think about fair share. Under the beneficiary-
pays principle, the beneficiaries of a service pay for the cost of
providing the service from which they benefit, but even this can be
complicated when beneficiaries and users differ. Under the ability-to-
pay principle, those who are more capable of bearing the burden of
fees should pay more for the service than those with less ability-to-
pay.
Efficiency: By requiring identifiable beneficiaries to pay for the
costs of services, user fees can simultaneously constrain demand and
reveal the value that beneficiaries place on the service. If those
benefiting from a service do not bear the full social cost of the
service, they may seek to have the government provide more of the
service than is economically efficient.
Revenue adequacy: Revenue adequacy is the extent to which the fee
collections cover the intended share of costs. It encompasses the
degree to which collections may change over time relative to the cost
of the program. Revenue adequacy also incorporates the concept of
revenue stability, which generally refers to the degree to which short-
term fluctuations in economic activity and other factors affect the
level of fee collections.
Administrative burden: This is the cost of administering the fee,
including the cost of collection and enforcement, as well as the
compliance burden (the administrative costs imposed on the payers of
the fee).
USCIS's 2007 Fee Design Reflects Trade-Offs among Some Key Fee Design
Principles and Provides a Foundation for Further Improvements in the
2010 Fee Design:
Today I will spend most of my time discussing the issues involved in
setting a user fee. It perhaps is the most challenging of the fee
design decisions because determining the cost of the service is often
quite complex and requires considering a range of issues. One of the
biggest issues in fee setting is how to define and apply the equity
criterion, such as determining the overlap between beneficiaries and
users, whether to employ a beneficiary-pays or ability-to-pay equity
principle, how to address fee exemptions and waivers, and finally, how
to assign costs among users. Many of these design choices described in
USCIS's 2007 fee review provide transparent analysis and identify
deliberate trade-offs. However, USCIS did not conduct the analysis
necessary to fully inform either congressional decision making or
USCIS's internal deliberations on key areas such as the cost of
activities funded by statutorily set fees. As a result, the amount
being cross-subsidized was unknown.
According to the beneficiary-pays principle, the extent to which a
program is funded by user fees should generally be guided by who
primarily benefits from the program. Under this principle, if a
program primarily benefits the general public (e.g., national
defense), it should be supported by general revenue, not user fees; if
a program primarily benefits identifiable users, such as customers of
the U.S. Postal Service, it should be funded by fees; and if a program
benefits both the general public and users, it should be funded in
part by fees and in part by general revenues[Footnote 4] (see figure
1).
Figure 1: Simplified, Hypothetical Example of Assigning Costs to
Beneficiaries:
[Refer to PDF for image: pie-chart and associated data]
Types of beneficiaries of a federal program:
Public beneficiaries (general public): 60% (Services paid with general
revenue);
Identified beneficiaries (users): 40% (Services paid with user fees):
User A – 8% (payer);
User B – 12% (payer);
User C – 20% (payer);
The amount of the fee reflects the cost of providing the service,
which differs among the three users. In this example, no users are
exempt from the fee, so all ’users“ of the service are also ’payers“
of the fee.
Source: GAO.
Note: Though not shown in this example, fees may include exemptions,
so that some "users" of the program are not "payers" of the fee. The
cost of providing the service to exempt users may be paid for with
general revenues or by the fees of other users.
[End of figure]
Although the beneficiary-pays principle is a useful guideline for
assigning costs, determining a program's beneficiaries and the extent
to which a program benefits users, the general public, or both is not
usually clear cut. For example, in prior work we found that National
Park Service staff reported that they did not want to raise federal
grazing fees assessed on ranchers, even though these fees were lower
than fees charged by other government agencies and private landowners,
in part because grazing not only benefits ranchers but also benefits
parks--for example, by controlling vegetation.[Footnote 5] In another
example, United States Department of Agriculture (USDA) food safety
inspections benefit the meat and poultry industries as well as the
general public: inspections improve consumer confidence in the safety
of those food products and the companies can advertise their products
as USDA-inspected, which may enhance the perceived quality. The
inspections also benefit the general public by preventing the spread
of communicable diseases carried by meat and poultry products, but it
is difficult to quantify that public health benefit and consequently
the extent to which the program should be covered by user fees versus
general revenues. Secondary beneficiaries of a program generally are
not considered in this examination. For example, consumers of new
prescription drugs are secondary beneficiaries of prescription drug
reviews, which provide a primary benefit to the drug sponsors.
[Footnote 6] Similarly, fees should be charged to the direct user,
even if that payer then passes the cost of the fee on to others.
Strictly following the beneficiary-pays principle is not always
desirable or practical. The government may wish to charge some users a
lower fee or no fee to encourage certain activities. For example,
potential profits from the development of "orphan" drugs--those that
treat rare diseases--are limited by the small size of their market,
and therefore drug companies may be reluctant to invest in them; such
drugs are exempt from the Food and Drug Administration (FDA)
prescription drug application fee to encourage their development.
Beneficiary-Pays Versus Ability-to-Pay:
While the beneficiary-pays principle may promote one aspect of equity,
it may run contrary to another--the ability-to-pay principle. Fees
that are proportionally more burdensome for low-income than high-
income individuals are said to be regressive. To address this concern,
the design of a fee may consider the ability of a user to pay, by for
example, exempting low-income users or scaling fees by some measure of
ability-to-pay. When those who are more capable of bearing the burden
of fees pay more for the service than those with less ability-to-pay,
the ability-to-pay definition of equity is employed, creating conflict
with the beneficiary-pays definition of equity and causing cross-
subsidization among applicants.
USCIS demonstrated the ability-to-pay principle of equity by limiting
the 2007 increase in the fees charged for some low-volume
applications, such as the Form I-360, Petition for Amerasian Widow(er)
or Special Immigrant. This avoided what, in some cases, would have
been a 250 percent fee increase or greater, levied on a population
unlikely to be able to pay. Instead USCIS only increased the fees by
the total average increase across all applications. The unrecovered
processing costs for these form types were distributed across other
form types and thus distributed among other fee-paying applicants.
USCIS demonstrated the beneficiary-pays principle of equity by not
limiting a second set of fees, for which the population would likely
be able to pay the large fee increase. For example, by not adjusting
fees for the Form I-829, Petition by Entrepreneur to Remove
Conditions--a form for which the applicants are entrepreneurs with
$500,000 to invest--USCIS closely aligned these fees with the cost of
providing the services to these users.
Both ability-to-pay and beneficiary-pays are valid applications of the
equity principle. Choosing between them depends on the policy goal to
be achieved.
Exemptions and Waivers:
Fees can also include provisions for exemptions and waivers to promote
certain policy goals and these provisions affect how program costs are
allocated among users. The cost of providing services to fee-exempted
or fee-waived users is commonly funded by general revenues or by the
fees of other users. Fee exemptions and waivers may also increase an
agency's administrative burden--the cost of administering the fee--
since the agency must carefully track when fees are due and from whom
rather than simply charging every applicant. Fee-paying applicants
also bear an administrative burden in terms of compliance costs
associated with waiver and exemption policies.
USCIS's user fee design allows fee exemptions for certain form types
and fee waivers for some applicants, and USCIS funds these activities
through a surcharge added to fee-paying applicants. By law, USCIS's
immigration and naturalization fees "may be set at a level that will
ensure recovery of the full costs of providing all [adjudication and
immigration] such services, including the costs of similar services
provided without charge to asylum applicants or other immigrants. Such
fees may also be set at a level that will recover any additional costs
associated with the administration of the fees collected."[Footnote 7]
As a result, certain form types are fee-exempt, such as for refugees
and applicants seeking asylum, and fee waivers are granted on a case-
by-case basis for applicants who demonstrate an inability to pay by
meeting certain need-based criteria.[Footnote 8] The cost of fee
exemptions and waivers is allocated to the fee-based applications as a
flat-rate surcharge.
Reliably accounting for the costs and benefits associated with such
provisions is important in order to ensure that these provisions are
achieving the intended results. In fully fee-funded programs, if some
users are exempt from paying fees, total fee collections cannot cover
total program costs unless other users pay a higher fee to cover the
costs of the exempted users. For example, commercial and private
vessels are both subject to Agricultural Quarantine Inspections (AQI),
but private vessels are exempt from the AQI fees. In prior work we
found that the costs of these private vessel inspections are included
in the AQI fee charged to commercial vessels.[Footnote 9] Thus
commercial vessels are paying for the cost of inspecting private
vessels. An alternative to cross-subsidization would be to pay for the
costs of providing services to exempt entities through general
revenues. USCIS received an appropriation for asylum, refugee, and
humanitarian parole activities, and military naturalizations beginning
in fiscal year 2010[Footnote 10]. In this way the policy goal is
attained and the general public, rather than other users, make up the
cost of exempt users or discounted fees.
Finally, fee exemptions and caps can increase an agency's
administrative costs because it must carefully track when fees are due
and from whom rather than simply charging everyone. The U.S. Customs
and Border Protection (CBP) generally assesses a $437 customs
inspection fee on commercial vessel operators when they arrive at
port, but the fee is capped at $5,955 per calendar year. This is
approximately 13.6 payments. This means that CBP has to calculate the
point at which the vessel has reached the cap and is no longer subject
to the fee. We recently reported that the cap increases CBP's
administrative costs and the potential for errors.[Footnote 11] This
issue was particularly problematic in 2007 because a fee increase took
effect on April 1, 2007, so vessels arriving before and after that
date paid two different rates. Since the fee cap applies to payments
received within a calendar year, it was even more difficult for CBP to
calculate the total amount paid and determine if a vessel had reached
the cap.
Assigning Costs among Users:
Assigning costs among fee-payers requires determining (1) total
program costs and (2) how to assign these costs among different
payers. The beneficiary-pays principle can be useful in guiding
decisions about cost allocation among users. That is, basing fees on
the cost of providing the program or service to various groups of
users enhances equity as each user pays for the cost of services
actually used.
When the cost of providing a service varies for different types of
users, the fee may vary (i.e., a user-specific fee), or be set at an
average rate (i.e., a systemwide fee). All other things being equal,
user-specific fees promote equity and economic efficiency because the
amount of the fee is more closely aligned with the cost of the
service.[Footnote 12] In contrast, systemwide fees may be higher or
lower than the actual cost of providing a service to certain types of
users and may result in cross-subsidies across users. For example, we
previously reported that the Federal Aviation Administration's (FAA)
funding structure had raised concerns about equity and efficiency
because users paid more or less than the costs of the air traffic
control services they receive and therefore may lack incentives to use
the national airspace system as efficiently as possible.[Footnote 13]
However, because user-specific fees require agencies to track the
costs of providing service to different users, these fees are often
more costly to administer than systemwide fees. In managing the trade-
offs between the benefits and drawbacks of user-specific versus
systemwide fees, several factors may be important to consider, such as
the purpose of the program, the amount of the fee and the amount of
cost variation among users when assigning costs.
Program purpose. In general, national systems are often best supported
by a systemwide fee whereas a user-specific fee may be the better
choice to support individual entities or locations or when maximizing
economic efficiency outweighs the desire for a national system.
Amount of the fee. If the fee is small relative to other costs that a
user faces, it may be less important to have a user-specific fee with
different rates.
Cost variation among users. Lastly, if there are numerous different
groups of users and a small cost variation among them, the efficiency
gains of a user-specific fee may be overwhelmed by the added
administrative costs. Conversely, if a program has a relatively small
number of user groups and the cost of providing the service to those
groups differs significantly, then user-specific fees might be both
beneficial and feasible.
Whether fee rates will be set using average cost or marginal cost is
also an important consideration when setting fees. Setting a fee at a
rate equal to the marginal cost of providing the service or product to
the specific user maximizes economic efficiency, but is often not easy
to do. In part because it is often difficult to measure marginal cost,
fee rates are sometimes set based on average cost.[Footnote 14] For
example, while international arriving airline passengers all pay a fee
for AQIs at the airport, it is difficult to know at the time the fee
is assessed which passenger will require which level of inspection.
The AQI fees are intended to cover total program costs; to set these
fees, the Animal and Plant Health Inspection Service (APHIS) projects
program costs for different inspection types (e.g., air passenger,
commercial aircraft, and commercial vessels) and divides each by the
total projected number of each type of payer. That is, each airline
pays the same fee per arrival to cover the costs related to inspecting
aircraft.
Even when marginal costs are measurable, setting the fee equal to
marginal cost could be problematic. When marginal costs are measurable
but are low relative to the fixed costs of the program, setting the
fee at marginal cost will lead to collections less than total costs.
In such a situation either a program may be funded in part through
general revenues or--if an agency, program or activity is completely
fee-funded--users would have to be charged more than marginal costs.
[Footnote 15] A third approach might be to create a two-part fee
consisting of (1) a flat fee to cover fixed costs and (2) a usage-
based fee to cover marginal costs. For example, the marginal cost of
providing electricity (i.e., operating power plants and maintaining
transmission lines) is small compared with the costs of building power
plants and transmission lines; thus, electricity consumers could be
charged a flat monthly charge to cover fixed costs plus a charge that
would vary based on their consumption.
In its last fee review USCIS determined its fee rates by assigning
different costs to various fee-paying users in different ways. First,
USCIS identified the costs for adjudicating each form type, referred
to as the "make determination" costs. As I noted before, user-specific
fees promote equity and economic efficiency because the amount of the
fee is closely aligned with the cost of the service.[Footnote 16]
USCIS's make-determination costs, which comprise 49 percent of its
total costs, vary by form type and are assigned accordingly; as such,
this portion of the costs are aligned with the associated fees. Next,
USCIS allocated $732 million in overhead costs, including payroll,
accounting, and legal services, in proportion to full-time
equivalents. Such systemwide fees minimize administrative burden
because they do not require identifying and charging specific costs to
each user.[Footnote 17] Lastly, all fee-paying applicants pay a flat-
rate $72 surcharge to recover the costs associated with asylum and
refugee services and fee-waived and fee-exempt applications. However,
in fiscal year 2010, USCIS received an appropriation for asylum,
refugee, and humanitarian parole activities, and military
naturalizations.[Footnote 18] Both methods achieve the policy goal but
these decisions illustrate two approaches to covering the cost of
exempt users--distribute the costs among other users or have the cost
made up by the general public.
Unknown Costs Create Unknown Cross-Subsidizations:
As this Subcommittee knows, some of USCIS' fees are set in statute. In
our work, we reported that at the time of the 2007 fee review USCIS
did not know the relationship between those statutorily set fees and
the costs of the activities associated with them. Because USCIS cannot
change these fee rates through the regulatory process, USCIS officials
told us that they had not identified the costs associated with
statutorily set fees and that doing so was not a priority for them.
This means that decision makers lack this key information; in
addition, it raises the possibility that processing costs for these
services are being partially borne by other fee-paying applicants.
Absent information on the cost of these services, however, the amount
of cross-subsidization is unknown.
The most notable of the statutorily set fees is the $1,000 fee for the
premium-processing service, which was USCIS's fifth largest single
generator of funds in fiscal year 2007.[Footnote 19] In December 2000,
the Congress authorized the collection of a premium processing fee for
employment-based applications, to be paid in addition to the regular
application fees.[Footnote 20] The Congress set the amount of the
premium processing fee at $1,000; pursuant to this authority and as
established in regulations, USCIS guarantees that certain employment
based applications will be processed within 15 calendar days of
receipt.[Footnote 21]
Although the premium processing fees are not--unlike most of USCIS's
application fees--cost-based, information on the cost of the services
for which the fee is charged should be determined. We have previously
reported that reliable information on the costs of federal programs
and activities is crucial for agencies and the Congress to ensure
effective management of government operations, which includes setting
user fees.[Footnote 22]
The cross-subsidization issue for premium processing fees is
complicated by the statutory provision that premium processing fees be
available for two activities: (1) certain premium processing services
for business customers and (2) infrastructure improvements associated
with adjudications and customer-service.[Footnote 23] In its 2007 fee
review, USCIS stated that the agency's intent was to use all premium-
processing collections to fund planned infrastructure improvements,
which are a significant component of USCIS's Transformation Program.
[Footnote 24] As a result, the cost of premium processing is borne by
other fee payers (see figure 2 below). Funding the Transformation
Program with premium-processing activities is consistent with report
language accompanying the fiscal years 2008-2010 Department of
Homeland Security appropriations bills, which direct USCIS[Footnote
25] to allocate all premium-processing fee collections to information
technology and business-system transformation. It is worth noting that
if the agency (a) is directed to use all its premium processing fee
revenue for infrastructure improvements, (b) provides premium
processing services, and (c) is an entirely fee funded agency, it can
only cover the costs of premium processing activities by imposing them
on other fee payers.
While the Congress continues to support this use of premium processing
collections, we note that it does raise several issues. First, as
noted above and shown in figure 2, the cost of premium processing is
being borne by other fee payers. Second, premium processing applicants
are bearing an uneven amount of the costs of the Transformation
Program--an initiative that will ultimately benefit all types of
future applicants. Spreading the transformation costs among all
application fees would distribute the burden across all fee-paying
applicants, but it could be seen as creating inequities across time
because today's applicants would be paying for improvements likely to
benefit future applicants.
Figure 2: The Flow of Premium Processing Collections and Usage:
[Refer to PDF for image: illustration]
Non-premium processing:
Fees go toward:
- Premium processing activities;
- Non-premium processing activities.
Premium processing:
Fees go toward:
- Infrastructure improvements.
Source: GAO analysis of USCIS data.
[End of figure]
Additional Considerations for Fee-Funded Agencies:
The criterion of "revenue adequacy" may be especially important when
fees are supposed to cover all or a set portion of the costs of an
agency, program or activity. As noted, revenue adequacy is the extent
to which the fee collections cover the intended share of costs. Let me
touch on two aspects of revenue adequacy: (1) the extent to which
collections may change over time relative to the cost of the program
and (2) the degree to which short-term fluctuations in economic
activity and other factors affect the level of fee collections.
Program costs change over time. This means that fees intended to cover
all or a set share of the costs of an agency, program, or activity
must be not only set but also adjusted---even between formal reviews--
to cover those costs. This in turn requires agencies to project and
consider future program costs--even if they conduct periodic fee
reviews. For example, USDA's Food Safety and Inspection Service did
this in 2006 when it set fee rates through fiscal year 2008 for
overtime inspection services for meat, poultry, and egg products. The
fee rates for each year included adjustments for inflation and
employee pay raises, so that future fee collections were projected to
grow with program costs.[Footnote 26]
If an agency or program is fully fee-funded, a reserve is important
because it provides a cushion if program costs would not drop
proportionally with a drop in fee collections. A reserve could also
help support preparation for any anticipated surge in users,
especially if fee collections would come after the expenditures to
prepare for the surge. For example, the AQI fee statute gives APHIS
permanent authority to use the collected fees. APHIS maintains a
reserve in case of emergency. For example, following the September 11,
2001 attacks, there was a significant drop in international passenger
travel, which led to a significant drop in certain AQI user fee
collections. In order for APHIS to continue the AQI programs through
that uncertain time, APHIS relied heavily on its 25-percent reserve.
Without a sufficient reserve balance in place, experienced full-time
personnel would have been furloughed and services reduced. We have
previously reported, however, that while a reserve is necessary, it is
also possible that the provision of permanent spending authority may
mean agencies have less incentive to limit total collections to total
costs.
We found that in its 2007 fee review, USCIS did not conduct the
analysis needed to establish a target level of carryover balance, or
"reserve," that would allow for the continuity of operations funded by
the Immigration Examinations Fee Account (IFEA) in the event of a
decrease in application volume. As a result we determined that USCIS
did not fully consider issues related to revenue adequacy. Without
analyzing its contractual and operating costs to determine an
appropriate target carryover balance, USCIS is at risk of reducing or
disrupting services if collections decrease. Further, absent analysis,
it is unclear for how long and at what service level USCIS could
operate with its current carryover balance. USCIS officials did say,
however, that an appropriate level of carryover should reflect: (1)
USCIS's first-quarter obligations, which includes the full contract
value for the whole fiscal year;[Footnote 27] (2) deferred revenue
equal to the amount of its outstanding workload,[Footnote 28] and (3)
the operating "tempo" of the organization.
While regular fee reviews should be done for all fees, they may be
especially important where fees represent a significant source of
support for an agency or program.[Footnote 29] Absent timely review,
the agency lacks up-to-date knowledge about the cost of fee-funded
activities and the relationship of those costs to the fees charged.
Where either the level of the fee or the activities covered by it are
set in statute, lack of timely analysis means the agency cannot
provide the Congress with the information it needs to make informed
decisions about any changes.[Footnote 30] Most of USCIS's user fees
are cost-based fees set through the regulatory process and deposited
into the Immigration Examinations Fee Account. Prior to 2007, USCIS's
last comprehensive fee review was in Fiscal Year 1997. As I noted, the
lack of timely, comprehensive fee reviews in the years between 1997
and 2007 contributed to the size of the fee increase.
Abrupt imposition of new or substantially increased user fees could
have unintended consequences on workload. For example, prior to the
2007 fee increases large numbers of applicants filed for benefits
before the increase took effect, which contributed to a surge that
exacerbated USCIS's backlog of applications. In cases like this,
transitional measures such as grandfather clauses or phasing in
increases might help address concerns about the adverse effects of the
abrupt imposition of a fee, while implementing the beneficiary-pays
principle gradually. However, as is the case with exemptions, the
benefits of transitional measures must be balanced with the likelihood
of reduced efficiency and equity gains and increased administrative
costs. Furthermore, delaying a fee increase may also have adverse
effects on an agency's operations.
Concluding Observations:
The transparency and quality of USCIS's user fee design depends on
complete, reliable information on which to base informed trade-offs
that support the goals of USCIS. Analyzing and understanding the costs
of providing these services are important so that both USCIS and the
Congress have the best possible information available to them when
designing, reviewing, and overseeing these fees. To this end, USCIS
took an important step forward with its 2007 fee review. In the next
review it should build on this by including the full costs of its
services regardless of whether the fee is set through the regulatory
or statutory process. Fee reviews are critical for any agency, but
especially for agencies--like USCIS--that are mostly or solely fee
funded.
We at GAO do not take a position on whether an agency should be
partially or fully fee-funded, or whether the costs of exemptions and
waivers should be distributed across other fee payers or funded
through general revenues. These are policy questions appropriately
decided by policymakers. With the design guide we have tried to
provide a kind of "road map" for policymakers that lays out the
questions and issues to consider--the decisions that must be made--in
the design of any fee. In our analyses of various fees we have sought
to illustrate the application of this design guide and assist the
Congress in its review of existing fees and consideration of possible
new fees.
Any user fee design embodies trade-offs among equity, efficiency,
revenue adequacy, and administrative burden. Focusing only on the pros
and cons of any single design element could make it difficult to
achieve consensus on a fee's design. Instead, policymakers will
ultimately need to balance the relative importance they place on each
of these criteria and focus on the overall fee design.
Chairwoman, this completes my prepared statement. I would be happy to
respond to any questions you or other Members of the Subcommittee may
have at this time.
Contacts and Acknowledgments:
For further information on this testimony, please contact Susan J.
Irving at (202) 512-6806 or by e-mail at irvings@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this statement.
In addition to the contact named above, Jacqueline M. Nowicki,
Assistant Director; Chelsa Gurkin; Lauren Gilbertson; Barbara
Lancaster; and Michael Dino, Assistant Director made key contributions
to this statement.
[End of section]
Appendix I: Key User Fee Design Questions:
We note that some of these questions may overlap.
Section I: Setting User Fees:
1. To what extent does the program benefit the general public and
identifiable users?
a. Does use of the program by certain users, or for certain types of
uses, provide a public benefit, for example, by advancing a public
policy goal?
b. What is the users' ability to pay?
c. To the extent that the fees are used to replace funding by general
revenues, what is the impact on the distribution of the burden of
financing the program?
d. What would be the impact of a fee on users' competitiveness with
others that would not be subject to the fee?
e. Is a similar service provided by the private sector? If so:
- Will private producers be subject to unfair competition if the fee
is not set to recover the full costs of the service?
- Should their charges be a reference point in setting fees?
f. For programs that have not been paid for by fees in the past, has
the value of the program been capitalized into private assets? If so:
- Could transitional measures be used to address these concerns?
2. How will the fee be linked to the cost?
a. Does the agency have timely and reliable cost data to link the fee
to program costs?
b. Will the fee recover full or partial costs?
c. Will the fee structure include exemptions or reduced fees?
d. Will the fee be set as a percentage rate or as a fixed dollar
amount?
e. If the fee varies, will fee minimum amount, maximum amount, or both
be set?
f. Will the fee structure be user-specific or systemwide?
- Is the amount of the fee small or large relative to other costs that
the user faces?
- Are there numerous different groups of users?
- Is the cost variation among the different groups of users large or
small?
g. Does the program have high fixed costs?
- Is a two-part fee structure, with a flat rate plus a fee based on
usage, appropriate?
3. How will the fee be structured to cover the intended share of
program costs over time?
a. Are fee collections projected to change over time in relation to
the cost of the program due, for example, to inflation?
b. To what degree will short-term fluctuations in economic activity
and other factors affect the level of fee collections?
c. Will the fee design include a maintenance-of-effort requirement?
Section II: Collecting User Fees:
1. What mechanisms are available to ensure payment and compliance with
requirements while minimizing administrative costs?
a. To what extent do payment and compliance mechanisms impose
administrative costs on the agency, the payers, or both?
b. Do rewards and penalties for compliance correspond to performance?
2. Is there an agency or other entity that already collects or audits
fees from the users?
a. How will compatible policies and procedures and regular
communication be established?
b. How does coordination affect the administrative costs of fee
collection for the agency and payers?
c. Will collection by another entity affect compliance with fees?
Section III: Using User Fees:
1. What degree of access will the agency have to collected fees?
a. Will the fees directly support the related program or agency or be
deposited to the general fund of the U.S. Treasury?
b. Will agency access to fees be subject to congressional
appropriation?
c. Will the budget execution of fee collections be through
reimbursement, or will the agency receive fee collections directly?
d. Will the amount of spending be tied to the amount of collections?
e. Will the fee be categorized as mandatory or discretionary?
2. How broadly or narrowly will the activities for which fee
collections can be used be defined?
Section IV: Reviewing User Fees:
1. Will the fee be updated through legislation or by agency regulation?
2. How frequently will fees be reviewed and updated?
a. Will legislation include a sunset provision to trigger fee updates?
b. Will legislation direct the agency to submit regular fee reviews to
the Congress, different from the biennial fee review required by the
Chief Financial Officers Act of 1990?
3. What mechanisms will be used to gather stakeholder input?
a. Will the agency establish an advisory committee?
b. Will proposed changes to the fees be published for comment in the
Federal Register?
c. What safeguards will be used to prevent the agency from becoming
beholden to fee payers/stakeholders?
[End of section]
Appendix II: GAO Homeland Security User Fee Related Products:
Federal User Fees: A Design Guide. [hyperlink,
http://www.gao.gov/products/GAO-08-386SP]. Washington, D.C.: May 29,
2008.
Federal User Fees: Additional Analyses and Timely Reviews Could
Improve Immigration and Naturalization User Fee Design and USCIS
Operations. [hyperlink, http://www.gao.gov/products/GAO-09-180].
Washington, D.C.: January 23, 2009.
Immigration Application Fees: Costing Methodology Improvements Would
Provide More Reliable Basis for Setting Fees. [hyperlink,
http://www.gao.gov/products/GAO-09-70]. Washington, D.C.: January 23,
2009.
Federal User Fees: Improvements Could Be Made to Performance Standards
and Penalties in USCIS's Service Center Contracts. [hyperlink,
http://www.gao.gov/products/GAO-08-1170R]. Washington, D.C.: September
25, 2008.
Federal User Fees: Substantive Reviews Needed to Align Port-Related
Fees and the Programs They Support. [hyperlink,
http://www.gao.gov/products/GAO-08-321]. Washington, D.C.: February
22, 2008.
Federal User Fees: Key Aspects of International Air Passengers Should
Be Addressed Regardless of Whether Fees Are Consolidated. [hyperlink,
http://www.gao.gov/products/GAO-07-1131]. Washington, D.C.: September
24, 2007.
[End of section]
Footnotes:
[1] See GAO, Federal User Fees: A Design Guide, [hyperlink,
http://www.gao.gov/products/GAO-08-386SP] (Washington, D.C.: May 29,
2008).
[2] For the purposes of this testimony, the term "application" refers
to both applications and petitions.
[3] USCIS's 2007 user fee review was issued prior to the issuance of
GAO-08-386SP, however the comparison of USCIS's review to the user fee
design principles is important to identifying opportunities for future
improvements.
[4] Programs that primarily benefit the general public are generally
nonexcludable, that is, there is no practical way of preventing
someone from benefiting from the program, and nonrival, that is, once
the program is in operation, there is no additional cost of providing
it to more people.
[5] See GAO, Livestock Grazing: Federal Expenditures and Receipts
Vary, Depending on the Agency and the Purpose of the Fee Charged,
[hyperlink, http://www.gao.gov/products/GAO-05-869] (Washington, D.C.:
Sept. 30, 2005), and National Park Service: Opportunities Exist to
Clarify and Strengthen Special Uses Permit Guidance on Setting Grazing
Fees and Cost-Recovery, [hyperlink,
http://www.gao.gov/products/GAO-06-355R] (Washington, D.C.: Feb. 9,
2006).
[6] A drug sponsor is the person or entity who assumes responsibility
for the marketing of a new drug, including responsibility for
complying with applicable provisions of laws, such as the Federal
Food, Drug, and Cosmetic Act and related regulations. The sponsor is
usually an individual, partnership, corporation, government agency,
manufacturer, or scientific institution.
[7] 8 U.S.C. § 1356 (m).
[8] In determining inability-to-pay, USCIS considers the totality of
all factors, circumstances, and evidence the applicant supplies
including age, disability, household income, and qualification within
the past 180 days for a federal means tested benefit, as well as other
factors associated with each specific case. More information about fee
waiver guidance can be found at [hyperlink,
http://www.uscis.gov/feewaiver].
[9] [hyperlink, http://www.gao.gov/products/GAO-08-386SP].
[10] For fiscal year 2010, Congress appropriated $50 million to USCIS
for the processing of applications for asylum or refugee states; of
which $5 million was for the processing of military naturalization
applications. Department of Homeland Security Appropriations Act of
2010, Pub. L. No. 111-83, 123 Stat. 2142, 2164 (Oct. 28, 2009).
However, the act restricted USCIS from obligating any of these funds
for processing applications for asylum or refugee status until the
agency "has published a final rule updating part 103 of title 8, Code
of Federal Regulations, to discontinue the asylum/refugee surcharge."
[11] See [hyperlink, http://www.gao.gov/products/GAO-08-321].
[12] Unless fees are perfectly user specific, some users will pay a
higher proportion of the costs they impose and some users will pay a
lower proportion of their costs. In the case of a fee that is not user
specific and recovers full program costs (i.e., does not use general
revenue funding), some users will pay more than the costs they impose,
essentially cross-subsidizing other users, who will pay less. For more
information about funding options for the FAA see National Airspace
System Modernization: Observations on Potential Funding Options for
FAA and the Next General Airspace System, [hyperlink,
http://www.gao.gov/products/GAO-06-1114T] (Washington, D.C.: September
27, 2006).
[13] See Aviation Finance: Observations on the Current FAA Funding
Structure's Support for Aviation Activities, Issues Affecting Future
Costs, and Proposed Funding Changes, [hyperlink,
http://www.gao.gov/products/GAO-07-1163T] (Washington, D.C.: August 1,
2007).
[14] Marginal cost is equal to the cost of providing an additional
unit of the good or service.
[15] There will be some loss of economic efficiency in either case:
user fees set above marginal cost and taxes--that is, general
revenues--both result in some loss of economic efficiency. See
[hyperlink, http://www.gao.gov/products/GAO-05-1009SP].
[16] In USCIS's case, this would be a form-specific fee as all fee-
paying applicants for a certain form type would pay the same amount
regardless of how much their individual application cost to process.
[17] However, we raise concerns about the lack of justification and
support for USCIS's allocation of remaining costs in our related
report, including how USCIS allocated certain overhead costs and
whether alternate assignment methods may offer greater precision. See
[hyperlink, http://www.gao.gov/products/GAO-09-70].
[18] For fiscal year 2010, Congress appropriated $50 million to USCIS
for the processing of applications for asylum or refugee states; of
which $5 million was for the processing of military naturalization
applications. Department of Homeland Security Appropriations Act of
2010, Pub. L. No. 111-83, 123 Stat. 2142, 2164 (Oct. 28, 2009).
However, the act restricted USCIS from obligating any of these funds
for processing applications for asylum or refugee status until the
agency "has published a final rule updating part 103 of title 8, Code
of Federal Regulations, to discontinue the asylum/refugee surcharge."
[19] In addition to the premium processing fee, USCIS did not know the
relationship between the cost of processing the H-1B applications and
its statutorily-set fee imposed on employers and therefore did not
know the amount being subsidized by other fee-paying applicants.
[20] Pub.L.No. 106-553, App. B, Title I, § 112, 114 Stat. 2762, 2762A-
68 (Dec. 21, 2000), codified at 8 U.S.C. § 1356 (u).
[21] 8 C.F.R. § 103.2(f). USCIS may designate the employment-based
applications that are eligible for premium services pursuant to public
notice in the Federal Register.
[22] [hyperlink, http://www.gao.gov/products/GAO-07-1131].
[23] 8 U.S.C. §1356(u).
[24] USCIS is embarking on an agencywide Transformation Program that
is intended to transform USCIS's current paper-based data systems into
a modern, digital processing resource that will enhance customer
service and better prevent future backlogs. The transformation program
was not included in the agency's definition of overhead costs for
purposes of the 2007 review.
[25] H.Rep. No. 110-181, at 114 (2007); H. Rep. No. 110-862, at 131
(2008); H. Rep. No. 111-298, at 115 (2009).
[26] Agencies must use realistic inflationary indicators if they want
to reasonably estimate future program costs and better align future
collections with those costs. OMB Circular No. A-94, which provides
guidance to agencies on benefit-cost analysis for federal programs,
notes that future inflation is highly uncertain and recommends that
when a general inflation assumption is needed, agencies use the rate
of increase in the gross domestic product deflator from the
administration's economic assumptions for the period of the analysis.
[27] USCIS enters into yearlong contracts at the start of the year and
therefore must have collections equal to the full contract value
available for obligation at the start of the year.
[28] USCIS's deferred revenue are fee collections received by the
agency for applications for which the adjudications have not been
completed.
[29] OMB Circular A-25 recommends, and the Chief Financial Officers
(CFO) Act of 1990 requires agency CFOs to review their user fees
biennially.
[30] [hyperlink, http://www.gao.gov/products/GAO-07-1131], [hyperlink,
http://www.gao.gov/products/GAO-08-321].
[End of section]
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 GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each
weekday, GAO posts newly released reports, testimony, and
correspondence on its Web site. To have GAO e-mail you a list of newly
posted products every afternoon, go to [hyperlink, http://www.gao.gov]
and select "E-mail Updates."
Order by Phone:
The price of each GAO publication reflects GAO‘s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO‘s Web site,
[hyperlink, http://www.gao.gov/ordering.htm].
Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.
Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional
information.
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]:
E-mail: fraudnet@gao.gov:
Automated answering system: (800) 424-5454 or (202) 512-7470:
Congressional Relations:
Ralph Dawn, Managing Director, dawnr@gao.gov:
(202) 512-4400:
U.S. Government Accountability Office:
441 G Street NW, Room 7125:
Washington, D.C. 20548:
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, D.C. 20548: