GAO and Inspector General Recommendations to Agencies: An Introduction
April 12, 2021
GAO and Inspector General Recommendations to Agencies: An
Introduction
Congress has established a number of institutions dedicated
the subject or scope, they are intended to reflect the
to monitoring and reporting on federal agencies and making
considered judgment of these oversight bodies after careful
recommendations to improve their integrity, efficiency, and
review of available information.
effectiveness. These entities include dozens of statutory
Offices of Inspector General (OIGs) and the Government
Recommendations are typically offered as action items in
Accountability Office (GAO), each of which has a mission
written reports including audits, investigations, studies, and
focused on the economy, efficiency, and effectiveness of
evaluations. These recommendations are generally short
the federal government’s operations.
and directive and are a way for GAO and OIGs to distill
key points and identify possible responses. However, a
One way these offices fulfill their missions is by making
more thorough review of the underlying reporting may be
specific recommendations to agencies that are intended to
needed to fully understand the purpose and potential benefit
improve their operations or to address specific issues of
of each recommendation.
compliance with laws, regulations, or other criteria.
Congress has empowered both GAO and OIGs to make and
Not all observers will necessarily agree with GAO and OIG
publish such recommendations.
recommendations or their underlying premises. Agencies
may disagree with some recommendations. In such cases,
OIG and GAO recommendations can be valuable tools to
GAO and OIGs may include correspondence that addresses
support Congress’s oversight activities. The
points of disagreement. Contrasting views may assist
recommendations can help identify issues or programs in
Congress in weighing the considerations or trade-offs at
agencies that might warrant additional oversight by
play in a given situation.
Congress, provide a trackable metric for monitoring agency
compliance or progress, and provide ideas and data to
Tracking Recommendations
inform legislation. These recommendations may also
Both GAO and the interagency body of OIGs —the Council
prompt agencies to address issues without further need for
of the Inspectors General on Integrity and Efficiency
congressional intervention.
(CIGIE)—track recommendations in a manner that may be
useful to Congress and the public. GAO maintains a
This In Focus introduces the topic of GAO and OIG
searchable database of its recommendations. GAO’s list
recommendations, their underlying statutory frameworks,
includes nearly 5,000 open recommendations. GAO has
and how they might be relevant to Congress. While this In
determined that about 400 of these recommendations would
Focus covers both GAO and OIG recommendations
have a particularly significant impact and has classified
because of their practical similarities, GAO and the OIGs
them as “priority recommendations” (https://www.gao.gov/
are established by different statutes, have distinct missions
reports-testimonies/recommendations-database).
and roles, and perform their duties in their own ways.
CIGIE maintains a similar webpage that collects
What Are GAO and OIG
recommendations from OIGs across the government,
Recommendations?
provides updates on their status, and includes statistical data
A GAO and OIG recommendation is a formal suggestion—
that allow users to review open recommendations by
following careful study of agency activities—offered to
agency, age, and other metrics. OIGs are currently tracking
agencies that is intended to resolve an identified issue at the
over 14,000 open recommendations
agency.
(https://www.oversight.gov/recommendations).
Collectively, GAO and OIGs issue thousands of
Illustrative Recommendations
recommendations to agencies each year. Generally, both
Recommendations come in a variety of forms with different
GAO and OIGs appear to take an inclusive view of the
levels of contextual detail and technical discussion. While
reasons they might issue recommendations. The OIG for
all of those nuances cannot be parsed out here, the
the Environmental Protection Agency (EPA), for example,
following two examples from a GAO report dated
states that it makes recommendations to “promote
September 21, 2020, on the federal government’s COVID-
effectiveness, efficiency, economy, and integrity in all EPA
19 response illustrate certain differences between some
programs and operations, including those performed by its
recommendations:
contractors and grantees.”
The Director of the Office of Management and
While recommendations might be crafted to address a wide
Budget, in consultation with the Department of the
variety of issues, the common thread is that, regardless of
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GAO and Inspector General Recommendations to Agencies: An Introduction
Treasury, should issue the addendum to the 2020
Under Title 31, Section 720, of the U.S. Code, when GAO
Compliance Supplement as soon as possible to
issues a recommendation to an agency, the head of that
provide the necessary audit guidance.
agency is required to submit a “written statement on action
taken or planned on the recommendation” and submit that
And:
recommendation to certain congressional committees.
The Director of the Centers for Disease Control and
In addition to this general statutory framework, Congress
Prevention should ensure that, as it makes updates
sometimes passes statutes with language requiring GAO to
to its federal guidance related to reassessing
prepare a specified report or evaluation. For example, P.L.
schools’ operating status, the guidance is cogent,
116-187 directs the Comptroller General of the United
clear, and internally consistent.
States (who leads GAO) to study disability and pension
benefits provided by the Department of Veterans Affairs to
The first of these recommendations, while clearly stated,
National Guard members and Armed Forces reservists. By
likely requires the reader to either have specific technical
passing legislation mandating the study, Congress was able
knowledge or do additional research to understand what the
“2020 Compliance Supplement”
to establish its scope, specify the contents, and set a
is, what else GAO believes
reporting deadline for GAO’s work.
it should cover, and why this action is important. The
second recommendation, on the other hand, while it
Roles of Congress
requires some general knowledge about schools and the
Recommendations issued by GAO and OIGs can, and often
COVID-19 pandemic, can be broadly understood without
do, serve as raw material for the oversight and legislative
additional explanation. Each of these recommendations
work of Congress. Specifically, there are at least three ways
would be supported with additional context and evidence in
that Congress might use recommendations.
the underlying report in which they were issued.
Statutory Framework
First, reviewing recommendations is one way that Congress
can identify and learn about issues that may warrant
Both GAO and OIGs are authorized by law to make
additional oversight. GAO and OIGs have resources,
recommendations to agencies in their mandated and
access, and technical expertise that allow them to identify
discretionary reviews of agency activities. While GAO and
and analyze matters that Congress may find it difficult to
OIGs have similar purposes and authorities, they operate
uncover in hearings or through staff casework. Further,
under distinct statutes that treat agency recommendations
when recommendations and reports are the basis for
differently.
oversight hearings, GAO and OIGs might be invited to
Offices of Inspector General
testify on their findings along with related agencies.
Section 2 of the Inspector General Act of 1978 (IG Act)
Second, Congress might use its authority over agencies to
establishes that one purpose of IGs is to
encourage them to implement recommendations. While
recommend policies for activities designed (A) to
neither GAO nor OIGs can compel agencies to act, it is
often the case that reporting on an issue to Congress is
promote economy, efficiency, and effectiveness in
sufficient to encourage agency action.
the administration of, and (B) to prevent and detect
fraud and abuse in, such programs and operation.
In this context, tracking of unresolved recommendations by
Section 4 of the IG Act specifies that each OIG has a duty
GAO and CIGIE may be useful. Congress might seek to
to make recommendations to agencies and to review
monitor how quickly agencies act on recommendations and
proposed legislation and make recommendations on it as
when recommendations remain unresolved. That
well. The IG Act also requires reporting to Congress when
knowledge may drive additional oversight by identifying
an OIG makes a recommendation.
less responsive agencies or highlighting especially
challenging issues, both of which may warrant attention.
The Inspector General Empowerment Act of 2015 added
the requirement that OIGs must report to Congress every
Third, a recommendation might inspire legislation.
six months on their activities. In these semiannual reports
Congress has authority over many aspects of the
OIGs are specifically required to identify “each significant
jurisdiction, organization, and activities of executive branch
recommendation” for which “corrective action has not been
agencies and may choose to take action based on a
completed.”
particular recommendation. Factors such as the seriousness
of an issue, public awareness and concern, or the perceived
Government Accountability Office
effectiveness of an agency’s response may influence
GAO has broad authority to investigate and report on “all
Congress’s course of action. For instance, Congress might
matters related to the receipt, disbursement, and use of
not pass legislation to address a recommendation the first
public money” (31 U.S.C. §712) and “evaluate the results
time it is presented but could become more likely to act if a
of a program or activity the Government carries out under
recommendation remains unresolved over time.
existing law” (31 U.S.C. §717). Under these provisions,
GAO may initiate an investigation or evaluation on its own
Ben Wilhelm, Analyst in Government Organization and
initiative, at the direction of either House of Congress, or at
Management
the request of a committee of jurisdiction.
IF11807
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GAO and Inspector General Recommendations to Agencies: An Introduction
Disclaimer
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