Federal Real Property Data: Limitations and Implications for Oversight

Federal Real Property Data: Limitations and Implications for Oversight

Federal Real Property Profile Management
November 5, 2020
System: Data Limitations and Implications
Garrett Hatch
for Oversight
Specialist in American
National Government
The federal executive branch owns and leases more than 127,000 buildings, with annual

operating costs in excess of $15 bil ion. Oversight of this portfolio has been a priority
Carol Wilson
for recent Congresses, particularly since real property management has been identified
Research Librarian
as a “high-risk” area by the Government Accountability Office (GAO), every year since

2003. Key potential weaknesses in real property management include agencies holding
empty or only partial y occupied buildings; relying on leases for new space even when

ownership would be cheaper; and making decisions using real property data of
questionable quality. This report examines the chal enges to oversight posed by the lack of accurate and reliable
real property data, particularly as it relates to the disposal of unneeded building space and the government’s
overreliance on costly leasing.
The primary source of real property data available to Congress is the Federal Real Property Profile Management
System (FRPP-MS). The General Services Administration (GSA) established the FRPP-MS to be a “single,
comprehensive, and descriptive” database of al federal real property, as required by the Federal Asset Sale and
Transfer Act (FASTA, P.L. 114-287). FASTA required the database to include for al federal properties—at a
minimum—information about each properties’ location, size, operating and maintenance costs, and level of
utilization, among other data. The only data that FASTA excludes from the FRPP-MS are those with national
security implications.
While the FRPP-MS has expanded the amount of real property data available for oversight, many data elements
are inaccurate or incomplete. For instance, just 23% of the properties listed in the FRPP-MS had complete
addresses. The methodology used to identify and report some data vary across agencies. To cite one example, the
National Park Service (NPS), GSA, and the Department of Veterans Affairs (VA) have al used different
definitions when reporting on building utilization, which means the data cannot be used to compare agency
performance. The FRPP-MS also does not include some of the data elements required by FASTA, such as annual
operating costs, as wel as other data that GSA collects which might be useful for oversight, such as building
repair needs.
Some of the limitations of the FRPP-MS may be mitigated by congressional action. One option for improving the
data quality might be to audit select landholding agencies to identify areas where data collection might be
standardized and accuracy might be enhanced. Another option for enhancing oversight and decisionmaking might
be to require GSA to include data in the FRPP-MS which are currently withheld, such as annual operating costs,
repair needs, building condition, and the number of federal employees and contractors at each property.
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Contents
Background.................................................................................................................... 1
The Federal Real Property Profile ...................................................................................... 2
FRPP Data Quality .................................................................................................... 3
Disposal Data ................................................................................................................. 4
Limitations of Disposal Data ....................................................................................... 5
Utilization Data.................................................................................................... 5
Timing Data ........................................................................................................ 6
Location Data ...................................................................................................... 6
Cost Data ............................................................................................................ 6
Leased Space Data .......................................................................................................... 7
Limitations of Lease Data ........................................................................................... 7
High-Value Leases................................................................................................ 8
Long-Term Leases ................................................................................................ 8
Data Quality................................................................................................................... 9
Limitations of FRPP-MS Data ..................................................................................... 9
Inaccurate and Incomplete Data .............................................................................. 9
Inconsistent Data Reporting ................................................................................. 10
Concluding Observations ............................................................................................... 11

Contacts
Author Information ....................................................................................................... 11

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Federal Real Property Profile Management System

Background
The federal executive branch controls an extensive real property portfolio that includes more than
127,000 owned and leased buildings.1 These buildings have been acquired over a period of
decades to help federal agencies fulfil their unique missions. Agencies hold buildings with a
range of uses, including offices, warehouses, barracks, laboratories, and hospitals. The cost of
operating and maintaining these diverse properties, which total more than 1.1 bil ion square feet,
exceeded $15 bil ion in FY2018.2
Congressional oversight has focused in large part on issues identified by the Government
Accountability Office (GAO), which has included federal real property management on its annual
“high-risk list” since 2003.3 GAO has repeatedly identified three key chal enges that agencies
face when managing their real property portfolios:4
1. maintaining more real property than it needs (including unutilized and
underutilized buildings);
2. relying on leasing when ownership of new space would be more cost efficient;
and
3. making real property management decisions using unreliable data.
In an effort to accelerate the disposal of unneeded property and improve the data available for
oversight and decisionmaking, Congress passed the Federal Assets Sale and Transfer Act of 2016
(FASTA; P.L. 114-287).5 FASTA requires landholding agencies to review their real property
portfolios and recommend to the General Services Administration (GSA) and the Office of
Management and Budget (OMB) that certain properties be disposed of, and other properties
consolidated. In addition, FASTA requires GSA to establish “a single, comprehensive, and
descriptive database of al Federal real property under the custody and control of al federal
agencies, other than federal property excluded for reasons of national security.”6
FASTA requires each landholding agency to provide descriptive information on the nature, use,
and extent of its portfolio. The information must include—but is not limited to—each property’s
 relevance to the agency’s mission, presently and in the future;
 level of utilization, including whether it is excess, surplus, underutilized, or
unutilized, and the number of days it has been so designated;
 size in square feet and acreage;
 geographic location, including a physical address and description;
 annual operating costs; and
 replacement value.

1 U.S. General Services Administration, FY2018 Federal Real Property Profile (FRPP) Open Data Set Executive
Sum m ary, September 30, 2018, pp. 1-2, https://www.gsa.gov/policy-regulations/policy/real-property-policy/data-
collection-and-reports/frpp-summary-report-library.
2 Ibid.
3 U.S. Government Accountability Office, High-Risk Series: An Substantial Efforts Needed to Achieve Greater
Progress on High-Risk Areas, GAO-19-157SP, March 2019, pp. 78-85, at https://www.gao.gov/assets/700/697245.pdf.
4 Ibid.
5 See CRS Report R44999, The Federal Assets Sale and Transfer Act of 2016: Background and Key Provisions, by
Garrett Hatch.
6 130 Stat. 1477.
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Specifical y describing the database as “comprehensive,” FASTA permits agencies to withhold
data only for reasons of national security, or if the property belongs to certain categories of land,
such as public lands. FASTA also mandates that the database permit users to search and sort
properties, and download data. Once operational, the database must be available, at no cost, to
federal agencies and the public.
While GSA did establish a database pursuant to FASTA’s requirements, much of the data are
incomplete and inaccurate. This report focuses on the chal enges to effective oversight and
decisionmaking posed by the lack of useful and reliable data in the FASTA-mandated database.
The balance of this report analyzes potential weaknesses in the data related to the disposal of
unutilized and underutilized buildings, the government’s reliance on costly leases, and the
potential consequences for decisionmakers when agencies withhold information from the
database. The final section of the report provides options for policymakers to consider should
they seek to address these data issues.
The Federal Real Property Profile
For decades, GSA has collected and stored agency real property data in an internal database, the
Federal Real Property Profile (FRPP). The FRPP is the government’s most comprehensive source
of data on federal buildings, land, and structures (e.g., bridges, dams, parking lots). With the
assistance of the Federal Real Property Council (FRPC), GSA obtains a range of data from al
landholding agencies on an annual basis, including information on each asset’s
 age;
 condition;
 repair needs;
 maintenance costs;
 lease payments;
 net proceeds from disposal; and
 on-site personnel (the number of federal employees and contractors at each
property).
To assist the agencies with their data collection and reporting, the FRPC publishes an annual
“Guidance for Real Property Inventory Reporting,” also known as the FRPP data dictionary. The
guidance defines the data elements that must be reported, outlines the technical requirements for
submitting the data, and identifies types of property that agencies may exclude from their data
submission. According to the 2019 Guidance for Real Property Inventory Reporting7, agencies
were not required to provide information regarding the following:
 Land easements or rights-of-way held by the federal government.
 Public domain land (including lands withdrawn for military purposes) or land
reserved or dedicated for national forest, national park, or national wildlife refuge
purposes, except for improvements on those lands.

7 Federal Real Property Council, 2019 Guidance for Real Property Inventory Reporting, Version 3 , September 24,
2019, pp. 8, 40-41, https://www.gsa.gov/cdnstatic/
FY%202019%20FRPP%20DATA%20DICTIONARY%20Final%20V3.pdf . See also Section 2 of Executive Order
13327, “Federal Real Property Asset Management,” 69 Federal Register 5897; and §3(5)(B) of FAST A (P.L. 114-287).
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 Land held in trust or restricted-fee status for individual Native Americans or
Native American tribes.
 Land, and interests in land, that are withheld from the database by agency heads
for reasons of national security, foreign policy, or public safety.
 Real property data exempt from public disclosure under FASTA in cases when
the data are already exempt under section 552(b) of the Freedom of Information
Act (FOIA) (5 U.S.C. §552(b)).
To meet FASTA’s requirements, GSA created a public version of the FRPP cal ed the FRPP-MS
(Federal Real Property Profile Management System).8 The FRPP-MS does not include al of the
data contained in the FRPP, but it does include data elements that were previously unavailable to
the public. The FRPP-MS divides the public data into two sets: civilian agencies and Department
of Defense (DOD). The civilian data are published in a single spreadsheet, and the DOD data are
split into five spreadsheets: Air Force, Army, Navy, Corps of Engineers, and the Washington
Headquarters Service.
FRPP Data Quality
Prior to FASTA, the FRPP could not be accessed directly by Congress or the public, and federal
agencies had limited access (i.e., agencies could view just their own data). The only publicly
available FRPP data were found in GSA’s annual Federal Real Property Report (FRPR), which
was last published for FY2018 data.9 The information provided in the FRPR was government-
wide or aggregated by agency or property type—which provided a limited, high-level view of the
federal portfolio that did not facilitate in-depth analysis.
The FRPP database itself has been criticized repeatedly by GAO for its inability to provide
accurate, complete information. In 2012, GAO wrote that inaccurate and inconsistent data may
mean that the FRPP does not “provide an adequate tool for decision making or measuring
performance.”10 In 2016, GAO concluded that agencies’ inconsistent collection and reporting
approaches may have populated the FRPP with data that are not comparable across agencies and
do not accurately capture the intended metric (e.g., an asset’s operating costs or condition).11 In
2020, GAO assessed the FRPP again12 and found that
 key data elements are often incomplete or otherwise unusable;
 GSA and individual reporting agencies withheld information that might be
valuable for oversight and decisionmaking; and

8 U.S. General Services Administration, “ Federal Real Property Public Data Set ,” at https://www.gsa.gov/policy-
regulations/policy/real-property-policy/asset-management/federal-real-property-profile-frpp/federal-real-property-
public-data-set.
9 U.S. General Services Administration, FY2018 Federal Real Property Profile (FRPP) Open Data Set Executive
Sum m ary, September 30, 2018, pp. 1-2, https://www.gsa.gov/policy-regulations/policy/real-property-policy/data-
collection-and-reports/frpp-summary-report-library.
10 U.S. Government Accountability Office, Federal Real Property: National Strategy and Better Data Needed to
Improve Management of Excess and Underutilized Property , GAO-12-645, June 2012, p. 17, at https://www.gao.gov/
assets/600/591751.pdf.
11 U.S. Government Accountability Office, Federal Real Property: Improving Data T ransparency and Expanding the
National Strategy Could Help Address Long-standing Challenges, GAO-16-275, March 2016, pp. 13-21, at
https://www.gao.gov/assets/680/676253.pdf.
12 U.S. Government Accountability Office, Federal Real Property: GSA Should Improve Accuracy, Completeness, and
Usefulness of Public Data, GAO-20-135, February 2020, pp. 7-27, at https://www.gao.gov/assets/710/704358.pdf.
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 some stakeholders find the spreadsheets too cumbersome to be useful.
Access to some of the FRPP’s data (via the FRPP-MS) therefore represents an increase in the
quantity, but not necessarily the quality, of data available to stakeholders for real property
oversight and decisionmaking.
Disposal Data
As noted, managing federal real property is considered a high-risk issue in part due to the number
of excess and surplus properties that agencies control.13 To reduce the amount of unneeded space
in the government’s portfolio—and its associated costs—agencies are required to continuously
survey their real property assets and identify buildings they can dispose of in their entirety
(transfer, donate, or sel ), and unoccupied space within buildings that could be fil ed by new
tenants.14 Agencies are then required to report those properties as excess to the General Services
Administration (GSA),15 which is responsible for the disposition of unneeded space for al
executive branch agencies, except those with their own independent statutory disposal authority.
GSA then follows a statutory and regulatory framework for disposing of unneeded real property,
which is described briefly below.
GSA first offers to transfer excess properties to other federal agencies, which general y pay fair
market value (FMV) for them.16 If no federal agency wants an excess property, then it is declared
“surplus” and made available to state and local governments, and nonprofits.17 These entities may
have surplus property transferred to them for a discount of up to 100% of fair market value,
provided they use the property for a public benefit.18 This type of transfer is cal ed a public
benefit conveyance, and to qualify, the property must be used for one of the following purposes:
 homeless services
 corrections
 law enforcement
 public health
 drug rehabilitation
 education
 parks and recreation
 seaport facilities
 wildlife conservation
 highways
 emergency management response
 historic monuments

13 See CRS Report R43818, Overview of Federal Real Property Disposal Requirements, by Garrett Hatch (available to
congressional clients upon request).
14 40 U.S.C. §524(a).
15 Ibid.
16 41 C.F.R. §102-75.190.
17 40 U.S.C. §545.
18 41 C.F.R. §102-75.350.
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 public airports
 housing19
Pursuant to Title V of the McKinney-Vento Homeless Assistance Act, surplus properties must be
made available for serving the homeless before being made available for other public benefit
uses.20 The Department of Housing and Urban Development (HUD) is responsible for reviewing
surplus property to determine if it is suitable for homeless use. If a property is determined to be
unsuitable for homeless use, or no eligible entities have submitted a notice of interest, then it
becomes available for other public uses at that time.
Surplus properties not conveyed for public benefit are then available for purchase by state and
local governments at FMV.21 If the property is not acquired by negotiated sale, GSA typical y
sel s it at a competitive public auction for no less than FMV.22 If a property has no commercial
value, GSA may authorize its demolition.23
Limitations of Disposal Data
Access to comprehensive, reliable data on federal buildings might be considered an essential
element of congressional oversight, because that information may be used to determine if the
disposal process is operating efficiently and effectively, identify obstacles to timely disposition,
and accurately assess the costs and benefits of different real property policies, among other
things. However, as discussed above, the FRPP-MS data are incomplete and some find the
database difficult to use.24
Utilization Data
Identifying assets that are underutilized or unutilized is the first step in the disposal process, and
data on individual assets would al ow stakeholders to analyze the government’s unneeded space
in-depth. Targeted analyses may lend insight into several key questions about asset utilization,
such as the following:
 What characteristics do unutilized buildings share?
 Do they have relatively high operating costs or repair needs?
 Are they historic properties that have stringent operating and maintenance
requirements?
 Are there investments that could be made in unutilized buildings that would
facilitate their sale and generate a profit to the government?
 Are they the same types of buildings in different agencies?

19 T he statutory authorities for each of these categories of public benefit conveyance may be found at
https://disposal.gsa.gov/s/PBC.
20 42 U.S.C. §11411.
21 40 U.S.C. §545.
22 40 U.S.C. §1303.
23 Ibid.
24 U.S. Government Accountability Office, Federal Real Property: GSA Should Improve Accuracy, Completeness, and
Usefulness of Public Data, GAO-20-135, February 2020, pp. 7-27, at https://www.gao.gov/assets/710/704358.pdf.
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Thousands of buildings—perhaps tens of thousands—listed in the FRPP-MS, however, lack
utilization indicators, thereby limiting the data’s usefulness for analysis and decisionmaking.
Timing Data
Similarly, a potential benefit of tracking excess and surplus properties in the FRPP-MS might be
the ability to measure the length of time it takes a property to move through each stage of
disposition. Agencies have long argued that delays in the disposal process make it difficult to
reduce the amount of unneeded space in their portfolios.25 In addition, the government continues
to accrue operating and maintenance costs for unneeded space until disposition is complete. Data
that show how long a property was excess and surplus might enable decisionmakers to identify
where delays occur and address the underlying causes. The FRPP-MS contains very little
information as to when properties were reported excess, declared excess, declared surplus, and
disposed.26 It is likely very difficult to use the database to monitor or analyze the movement of
most properties within the disposal process.
Location Data
One of the objectives of the FRPP-MS was to facilitate the purchase of surplus federal property
by the private sector.27 The sale of unneeded space both generates revenue to the government and
reduces operating and maintenance costs. Agencies may reinvest the net proceeds in further
disposals or other portfolio needs—such as repairs—thereby providing additional benefits to the
government. Real estate brokers have reported numerous difficulties with the FRPP-MS,
including that its format and organization are so cumbersome they wil not use it or refer their
clients to it.28 Other private-sector stakeholders have expressed a high level of concern with the
reliability of the data—a concern borne out by a study that found only 23% of the property
addresses in the FRPP-MS were complete and 30% had no address information at al .29 As a
consequence, interest in acquiring federal property may be diminished.
Cost Data
The scale of the problem of unutilized and underutilized building space may be evaluated in
terms of cost. The amount of funding spent operating and maintaining buildings that are empty or
only partial y occupied may help policymakers determine whether addressing the problem should
be a priority. Cost data may also help policymakers evaluate the cost-effectiveness of various
policy alternatives—the greater the potential for savings, the wider the range of policy options
that could provide net fiscal benefits to the government. The FRPP-MS does not include the cost
of operating and maintaining each asset, so it may not be possible to determine the potential
savings achieved by disposing of underutilized or unutilized buildings. This omission limits

25 U.S. Government Accountability Office, Federal Real Property: The Government Faces Challenges to Disposing o f
Unneeded Properties, GAO-11-370T, February 2011, p. 5, at https://www.gao.gov/assets/130/125472.pdf.
26 Statement based on CRS’s review of FRPP -MS data.
27 U.S. Congress, Senate Committee on Homeland Security and Governmental Affairs, Federal Assets Sale and
Transfer Act of 2015, report to accompany S. 2375, 114th Cong., 2nd sess., S.Rept. 114-291, p. 2, at
https://www.congress.gov/114/crpt/srpt291/CRPT-114srpt291.pdf.
28U.S. Government Accountability Office, Federal Real Property: GSA Should Improve Accuracy, Completeness, and
Usefulness of Public Data, GAO-20-135, February 2020, pp. 7-27, at https://www.gao.gov/assets/710/704358.pdf.
29 Ibid., p. 7.
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policymakers’ understanding of costs associated with retaining unneeded space and the ability to
craft policy that is revenue-positive.
Leased Space Data
Federal real property is a high-risk issue in part because of the government’s reliance on costly
leased space—which totals more than $7 bil ion in expenditures annual y.30 Leases may create
fiscal exposure, since leased space is general y less cost efficient than owned space, both
measured in terms of current market rates and over the long-term.31 One of the driving forces of
this trend is the way in which leases are scored for agency budget submissions. When an agency
seeks to enter into an operating lease—a lease that wil not result in the government owning the
building—only the amount needed to cover the first year’s lease payments plus cancel ation costs
must be recorded in the budget.32 When an agency seeks to construct or purchase a building,
however, the full cost of the project must be recorded in the budget in the year in which the
budget authority is to be made available.33 Under these rules, agencies have found it more feasible
to obtain funding for one year of rent than for the entire cost of a building, even though it is
general y less expensive over time to own rather than lease space.
Limitations of Lease Data
According to GSA’s FY2018 FRPR, civilian agencies spent $7.18 bil ion to operate and maintain
254 mil ion square feet of leased space (including rent), and $7.98 bil ion to operate and maintain
885 mil ion square feet of federal y-owned space.34 The annual cost of one square foot of leased
space ($28.25) was more than three times as expensive as the annual cost of one square foot of
owned space ($9.02). Monitoring agency leasing activity might be of interest to Congress—
particularly given the level of expenditures involved—but the FRPP-MS does not provide the
annual operating costs of owned or leased space, nor does it provide the annual rent for each
lease. Some information about the costs of GSA’s leases may be found in other databases, but
withholding cost data is contrary to the objective of making the FRPP-MS a “single,
comprehensive” source of real property information and undermines the ability of policymakers
to conduct effective oversight of bil ions of dollars expended on leases each year. Real estate
brokers say that cost data are among the most important factors used to evaluate potential
purchases, and they often exclude federal properties from consideration when the data are not
available.35

30 U.S. General Services Administration, FY2018 Federal Real Property Profile (FRPP) Open Data Set Executive
Sum m ary, September 30, 2018, p. 1, at https://www.gsa.gov/policy-regulations/policy/real-property-policy/data-
collection-and-reports/frpp-summary-report-library.
31 Ibid., p. 9.
32 U.S. Office of Management and Budget, Circular A-11: Preparation, Submission, and Execution of the Budget,
Appendix B, July 2020, p. 2, at https://www.whitehouse.gov/wp-content/uploads/2018/06/a11.pdf.
33 Ibid., Appendix A, pp. 3-4.
34 U.S. General Services Administration, FY2018 Federal Real Property Profile (FRPP) Open Data Set Executive
Sum m ary, September 30, 2018, p. 1, at https://www.gsa.gov/policy-regulations/policy/real-property-policy/data-
collection-and-reports/frpp-summary-report-library.
35 U.S. Government Accountability Office, Federal Real Property: GSA Should Improve Accuracy, Completeness, and
Usefulness of Public Data, GAO-20-135, February 2020, pp. 18, at https://www.gao.gov/assets/710/704358.pdf.
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High-Value Leases
Oversight of GSA, the government’s largest lease-holder, is particularly limited. GSA is required
to handle leases for any executive branch agency that does not have independent leasing
authority.36 As a consequence, GSA controls two-thirds of the leased space in the executive
branch, as measured in terms of square footage.37 When GSA seeks to enter into a lease, it must
seek congressional authorization if the projected cost of that lease exceeds a certain threshold,
known as the “prospectus threshold.”38 The threshold is established each year by GSA, and in
FY2020 it was $3.095 mil ion.39 In an effort to look for root causes of the government’s
overreliance on costly leases, GAO examined GSA’s prospectus-level leases—which it
designated as “high-value” leases—and found that while they comprised 3% of GSA’s total lease
portfolio, they represented 36%, or $1.5 bil ion, of its total operating costs.40 Oversight of these
leases is limited by the fact that the FRPP does not currently enable users to identify leases by
cost. Given that GSA reports cost data on individual leases in monthly spreadsheets, which are
available to the public online,41some may ask why the same data are not provided in the FRPP-
MS.
Long-Term Leases
Research has shown that long-term operating leases42 are especial y likely, among al high-value
leases, to expose the government to unnecessary costs.43 One audit found, for example, that a 30-
year lease for the Federal Bureau of Investigation (FBI) building in Chicago, IL, wil cost $40
mil ion more than owning the same amount of space.44 Similarly, an analysis of 89 GSA leases,
many of which had 30-year terms, found that the government could have saved almost $1 bil ion
if it had constructed rather than leased that space.45 A relatively high prevalence of long-term
leases in an agency’s real property portfolio is considered by GAO a management weakness, as it
is an indication that the agency’s capital planning strategy has not “systematical y prioritized
which high-value leases have the most cost-saving potential” as construction projects.46 The lack
of cost data means that policymakers are thus unable to take the potential savings into account
when appropriating funds for real property projects. Data showing rent and operating and

36 40 U.S.C. §501.
37 Ibid.
38 40 U.S.C. §3307.
39 U.S. General Services Administration, GSA Annual Prospectus Thresholds, at http://www.gsa.gov/portal/content/
101522.
40 U.S. Government Accountability Office, Federal Real Property: Greater Transparency and Strategic Focus Needed
for High-Value GSA Leases, GAO-13-744, September 2013, p. 9.
41 U.S. Government Services Administration, “Lease Inventory,” at https://www.gsa.gov/real-estate/real-estate-
services/leasing-policy-procedures/lease-inventory.
42 T here is no standard definition of a long-term lease—some have suggested terms greater than 20 years, others have
suggested terms that exceed 10 or 15 years. A short -term lease is generally considered less than 10 years.
43 U.S. Government Accountability Office, General Services Administration: Comparison of Space Acquisition
Alternatives—Leasing to Lease-Purchase and Leasing to Construction, GAO-99-49R, March 1999, p. 7, at
http://www.gao.gov/assets/90/88549.pdf.
44 U.S. Government Accountability Office, Federal Real Property: Overreliance on Leasing Contributed to High -Risk
Designation, GAO-11-879, August 2011, p. 2, at http://www.gao.gov/assets/130/126817.pdf.
45 U.S. Government Accountability Office, Federal Real Property: Greater Transparency and Strategic Focus Needed
for High-Value GSA Leases, GAO-13-744, September 2013, p. 1.
46 Ibid., p. 19.
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maintenance costs would enable Congress to gain perspective on the scale of agency reliance on
long-term leases, and the opportunities for cost-savings that could result from funding
construction projects instead of operating leases, in some cases.
Data Quality
Along with holding unneeded property and relying heavily on costly leases, real property
management is a high-risk issue because data available to decisionmakers are, in part, unreliable.
The FRPP-MS represents an increase in the quantity of information available for oversight and
policymaking, but data quality weaknesses remain. Stakeholders are unable to make fully
informed decisions because basic data (e.g., costs, locations, building conditions) are incorrect,
incomplete, or inconsistently reported.
Limitations of FRPP-MS Data
The FRPP-MS is, in essence, a centralized repository of agency data. While GSA does review
agency submissions and asks them to verify “questionable responses”—such as buildings that are
very smal in size—it is ultimately the agency that ensures their data’s accuracy. Many agencies,
including some with large portfolios, provide inaccurate or incomplete data to the FRPP.47
Agencies may interpret GSA’s FRPP reporting guidance differently, leading to variations in the
type and amount of data they report. Final y, the FRPP-MS data do not include some potential y
useful data that GSA or landholding agencies have chosen to withhold.
Inaccurate and Incomplete Data
There has been no comprehensive study of agency real property reporting policies and
procedures, but audits at individual agencies suggest that many provide inaccurate data—
including some with relatively large owned or leased property portfolios.
GSA is the government’s largest leaseholder, controlling 74% of civilian agencies’ leased space.48
Given the scale of GSA’s leased space portfolio, ensuring the agency’s data are accurate might be
considered a priority for decisionmakers. This may be particularly true of data that directly relate
to the weaknesses that contribute to real property management having a high-risk designation,
such as the cost of leased space. The reported cost per square foot for office space, however, has
often been inaccurately reported. One analysis estimated that the actual cost of leased space was
higher than reported for 18 of the 23 agencies examined, with an average of $1.31 higher per
square foot.49 The auditor concluded that “stakeholders and agencies do not have accurate
information to assess agencies’ performance or help manage their space decisions.”50
DOD controls nearly half of the government’s owned real property portfolio. There is relatively
little information about these assets in the FRPP-MS.51 GAO found that while DOD has improved

47 U.S. Government Accountability Office, Federal Real Property: GSA Should Improve Accuracy, Completeness, and
Usefulness of Public Data, GAO-20-135, February 2020, pp. 7-27, at https://www.gao.gov/assets/710/704358.pdf.
48 U.S. General Services Administration, “FY 2018 Federal Real Property Public Data Set,” at https://www.gsa.gov/
policy-regulations/policy/real-property-policy/asset-management/federal-real-property-profile-frpp/federal-real-
property-public-data-set.
49 Government Accountability Office, Federal Real Property: Measuring Actual Office Space Costs Would Provide
More Accurate Inform ation, GAO-20-130, December 2019, p. 1, https://www.gao.gov/assets/710/703106.pdf.
50 Ibid.
51 Government Accountability Office, Defense Real Property: DOD-Wide Strategy Needed to Address Control Issues
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its data collection and reporting in some areas, it has ongoing weaknesses in others.52 Several data
elements that relate to real property disposal are incomplete. The status (excess or surplus) of
47.9% of the properties DOD reported as excess could not be verified, for example, and 14.4%
(93,000) of facilities lacked a utilization indicator (utilized, underutilized, unutilized).53 DOD’s
data gaps may reflect, in part, the difficulties DOD components have encountered in maintaining
accurate and complete real property records. For example, Air Force personnel responsible for
recording new real property assets did not create such records in a timely manner, GAO reported,
due to their inability to acquire a unique identifier for the properties as the Air Force migrated to a
new real property system.54
Inconsistent Data Reporting
While GSA’s FRPP reporting guidance is government-wide, agencies may differ in how they
define data elements and ensure complete, timely information is collected. As a consequence,
some FRPP-MS data may not be comparable across agencies, limiting its usefulness for analysis.
Agencies have applied a range of methods when capturing data, and it is unclear whether these
inconsistencies have been resolved.55 Building utilization rates, for example, may be determined
differently at different agencies. The Department of Veterans Affairs (VA) has historical y
provided utilization data on al of its buildings, while GSA has reported only on buildings that
had been declared excess.56 The latter approach meant that al of GSA’s active buildings were
reported as utilized, even if they should have been reported as underutilized or unutilized. Also,
the National Park Service (NPS), the Agricultural Research Service (ARS), and the U.S. Coast
Guard (USCG) have, at times, applied definitions for utilized, underutilized, and unutilized that
had not been in place since FY2012.57
Agencies have also used inconsistent approaches for estimating costs. The USCG has estimated
operating costs to be 3% of the replacement value of the property, while VA totaled the operating
costs of al the buildings at a facility and prorated the sum to individual properties.58 Similar
variations have been found with estimating and reporting repair needs. Some agencies have not
reported repair needs of buildings they expect to demolish, while others have. The USCG
reported that 79% of its buildings had no repair needs, but acknowledged that they hadn’t fully
surveyed their portfolio and that their estimated repair needs would likely increase considerably
when the survey was complete.59 When data are collected and reported inconsistently across
agencies, policymakers may have a limited understanding of the government’s needs.

and Im prove Reliability of Records, Report to Congressional Committees, September 2020, p. 11,
https://www.gao.gov/assets/710/709224.pdf.
52 Ibid.
53 Ibid.
54 Ibid., pp. 11-12.
55 U.S. Government Accountability Office, Federal Real Property: Improving Data T ransparency and Expanding the
National Strategy Could Help Address Long-standing Challenges, GAO-16-275, March 2016, pp. 17-18, at
https://www.gao.gov/assets/680/676253.pdf.
56 Ibid.
57 Ibid.
58 Ibid., p. 16.
59 Ibid., p. 14.
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Concluding Observations
The value of the FRPP-MS for oversight and decisionmaking is limited by inaccurate information
and inconsistent reporting across agencies. Given that dozens of agencies control varying
amounts of real property, it may not be feasible to assess the internal controls over real property
data at each of them. It might be useful to audit the largest landholding agencies with the goal of
identifying areas where standardization could be improved—such as ensuring that data are being
collected with the same methodology.
It is unclear to many why potential y valuable, unclassified information is being withheld from
the FRPP-MS. As noted, GSA requires agencies to submit annual operating and maintenance
costs for leased and owned buildings, as wel as the estimated cost of building repairs. With
access to these data elements, policymakers would gain insight into the bil ions of dollars the
government invests each year in its building portfolio and better anticipate future funding needs.
Publishing other data elements might also enhance oversight and guide decisionmaking.
Information on building conditions might give policymakers a clearer understanding of the state
of each agency’s portfolio, and knowing the number of federal employees and contractors at each
federal building might facilitate consolidation and colocation efforts.

Author Information

Garrett Hatch
Carol Wilson
Specialist in American National Government
Research Librarian

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