Better Evaluations Needed to Weed Out Useless Federal Advisory Committees

Published by the Government Accountability Office on 1977-04-07.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                         DOCUMENT RESUME
00437 - (A1051972]

Better Evaluations Needed to eed Out Useless Federal Advisory
Committees. GGD-76-104; B-127685. April 7, 1977. 38 pp. +
appendices (37 pp.).
Report to the Congress; by Elmer B. Staats, Comptroller General.

Contact: General Government Div.
Budget Function: General Government: Other General Government
Orga.nization Concerned: Office of Management and Budget;
    Department of Commerce: Department of Health, Education, and
    Welfare; Department o the Interior; Environmental
     Protection Agency; National Science Foundaticn.
Congressional Relevance: Congress.
Authority: Federal Advisory Committee Act (P.L. 92-463). OE
    Circular A-63.

         Legislation to control the growing number of advisory
committees, 1267 as of December 31, 1975, assigned oversight
responsibilities to Congress, the President, and the Director of
the Office of Management and Budget (OMB). The OB is required
to make an annual comprehensive review of each committee to
determine whether it has carried out its purpose, needs revised
responsibilities, o should be merged or abolished.
Findings/Conclusions: The ORB and agencies have had a difficult
time identifying useless committees because they have not
developed objective criteria. Because of lack cf leadership by
OMB, the agencies have developed their own approaches.
Uncertainties existed within agencies about the status of
subgroups and ad hoc groups, cost analyses, reporting
procedures, and committee issions. Recommendations: OMB should
(1) develop uniform guidelines on sub-groups and ad hoc groups;
(2) require that agency committee harters state purposes
clearly and include a timespan; (3) issue guidelines for
consistent cost estimates; and (4) develop a standard definition
of "report" and provide for followup. (HTW)



     Better Evaluations Needed
     To Weed Out Useless
     Federal Advisory Committees
     An important purpose of the Federal Adviso
     ry Committee Act is to provide ways to con
     trol the number of advisory committees ser-
     ving Federal departments and agencies anti
     make sure that only committees with well-
     defined, necessary functions are authorized to
     con tinue.
     The Office of Management and Budget and
     the agencies have not acted effectively to
     carry out the law. Although many committees
     are bing abolished, more can be done in this
     The act directs the Office of Management arid
     Budg,?t to prepare guidelines and controls
     suitable for managing advisory committees. It
     directs that the committees be managed under
     uniform standards and procedures. No uni
     form or conristent Government-wide standards
     exist because the Office of Managernent and
     Budget has not provided effective leadership
     and adequate guidance.

     GGD-76-104                                       '7 7
a,.!   e ,/Z1               WASHINGTON, D.C.   2054a


  To the President of the Senate and the
  Speaker of the House of Representatives

       This report describes the management problems with the
  Federal advisory committee program and suggests ways to
  correct them.  The report covers the management ractices
  of the Office of Management and Budget; the Departments of
  Commerce;  ealth, Education, a-nd Welfare; and the Interior;
  the  nvironmental Protection Aency; and the National
  Science Foundation.

      Our evaluation of the effectiveness of the Federal ad-
 visory committee program was made pursuant to the Budget
 and Accounting Act, 1921 (31 U.S.C. 53), and the Accounting
 and Auditing Act of 1950 (31 U.S.C. 6). A special interest
 in this evaluation was expressed by the former Chairman of
 the Joint Economic Committee, Senator  ubert ['. urmnhrey.

      Copies are being sent to the Director, Office of Manaoe-
 mont and Ludqet, and the heads of the deoartments and aaen-
 cies discussed in this report.

                                    Comptroller General
                                    of the  nitcd States
                                        FEDERAL ADVISORY COMMITTEES
                                        Office of Management and Budget


              Out of concern about mushrooming Federal      advi-
              sory committees and a desire to improve commit-
              tee management, the Congress enacted the Federal
              Advisory Committee Act.

              As of December 31, 1975, 1,267 advisory commit-
              tees--25 more than at the end of 1974--spent
              about $52 million of the taxpayers' money to
              support themselves.  The Office of Management
              and Budget and other Federal agencies have
              made strides in improving the advisory commit-
              tee program, Although some committees are beinq
              abolished, more can be done in this regard.


              The annual comprehensive review--which the
              Office of Management and Budget uses to
              oversee committee activities--and the process
              for establishing and renewing committees do
              not guarantee that only useful committees
              exist.  The Office and the agencies have a
              difficult time identifying useless committees
              because they have not developed objective
              criteria to evaluate the committees.

              GAO believes that the following criteria could
              play an important part in evaluating committee
              activity and productivity:

              -- Number of committee meetings.  (Those      oldina
                 no meetings should be uestioned.)

              -- Support costs incurred.  (Limited budoet and
                 staff support could indicate a lack of aqency
                 commitment to the committee's activities.)

              -- Age of a committee.   (Extremely old commit-
                 tees would be suspect.)

              -- Reports and recommendations.  (This is a meas-
                 ure of committee output.  Those producing no

TeaiS   t.   Upon re.nova., te repert
cover date should Fe noted hereon.       i                   GGD-76-104
  reports or recommendations could be suspect.
  This should also include the agencies' ac-
  tion or followup on committee reports and
  recommendations.)  (See p. 16.)


The Office of Management and Budqet has not
provided the management and leadership en-
visioned by the Federal Advisory Committee
Act. Because of this, adequate Government-
wide uniform committee standards and pro-
cedures do not exist.  The agencies, not un-
expectedly, have developed their own approaches
and procedures regarding their committees.
(See ch. 3.)

Committee management practices of the Depart-
ments of Commerce; Health, Education, and Wel-
fare; and the Interior; the Environmental Pro-
tection Agency; and the National Science
Fourndation show that the following problems
need correction:

-- Agencies are unsure of the status of sub-
   groups and ad hoc groups.  As a result,
   they classify different groups as advisory
   committees.  (See p. 19.!

-- The methods for determining committee costs
   are not consistent, making it hard to com-
   pare costs among committees or agencies.
   Most inconsistencies are due to the agencies'
   difficulties and differences in fiaurinq
   staff support costs. Also, quite a few com-
   mittee program costs are not included in the
   President's annual report to the Congress
   on advisory committees.  Thus, the annual
   report on cost and staff support figures does
   not accurately estimate committee program
   costs. (See p. 24.)

--Neither the Office's nor the agencies' guide-
  lines adequately define "report." Some
  agencies classify minutes of committee
  meetings as reiorts, others only classify
  formally issued reports, while still others
  classify the annual closed-meeting reports
  as committee reports. As a result, the in-
  formation in the President's annual report
  is misleading.  (See p. 26.)

             -- Committee charters generally do not define
                committees' missions clearly.  Charters
                fail to include the specific timespan needed
                to accomplish a committee's purpose.   (See
                p. 23.)

             Beginning in 1975, the Office of Management and
             Budget started using budget examiners to evaluate
             committee usefulness, and, after the 1975 evalua-
             tion, it began to notify the agencies about aues-
             tionable committees.  But the Office still needs

             -- develop objective criteria to be used consist-
                ently and systematically to evaluate the com-
                niittees (see pp. 9 and 31) and

             --revise and clarify its guidelines and held
               agencies formulate their own guidelines for
               rev iewing committees. (See ch. 3 and p. 31.)

             The Office and the heads of agencies should
             jointly develop a standardized monitoring and
             evaluation system to follow up on committee
             recorts and recommendations.  (See p. 28.)

             Although each of GAO's conclusions arid   recom-
             mendations was agreed to by either the    Office
             or one or another of the agencies, all    took
             exception to something in the report.     (See
             ch. 5.)

             On February 25, 1977, shortly before issuance
             of this report, the Pesident addressed a
             memorandum to heads of executive departments
             and agencies stating that "many existing
             (advisory) committees have outlived their
             usefulness, or are not providing truly bal-
             anced advice and recommendations."  He or-
             dered a Government-wide, zero-based review
             of all advisory committees and expressed the
             hope that the number of such committees
             would be sharply reduced.

Tear Sheet




  I        INTRODUCTION                                      1
                Data on advisory committees                  2
                GAO and agency internal audits of
                  advisory committees                        3

             COMMITTEES                                      5
                Committee evaluations and the associated
                  problems                                   5
                Use of systematic evaluation criteria
                  needed                                     9
                    Proposed evaluation indicators          12

                Adeciuate definition needed for sub-
                  groups and ad hoc qroups                  19
                Clear and specific committee charters
                  are needed                                23
                Costing procedures need improvement         24
                A standard "report" defiition is needed     26
                Followup procedures for committee
                  recommendations need to be established    28

  4        CONCLUSIONS AND RECOMMENDATIONS                  30
                Conclusions                                 30
                Recommendations                             31

  5        AGENCY COMMENTS AND CUR EVALUATIONS              32

  6        SCOPE OF REVIEW                                  38


      I    Digest of Comptroller General's report to the
             Congress entitled "Better Followup System
             Needed on Recommendations  y Study Commis-
             sions in the Federal Government"
             (RED-76-33, Dec. 4, 1975)                     3)

  II       Advisory corm   ttee performance in 1974,
             accordir       evaluation indicators          42

 III       Advisory c    ttee performance in 1975,
             according to evaluation indicators            43
APPEND1X                                                    Page

     IV    Letter dated October 11, 1976, from the Office
             of Management and Budget                        45

      V    Letter dated January 18, 1977, from the Office
             of Management and Budget                        47

 VI        Letter dated September 30, 1976, from the
             Department of the Interior                      56

 VII       Letter dated September 30, 1976, from the
             National Science Foundation                     59

VIII       Letter dated September 27, 1976,   from the
             Department of Commerce                          62

     IX    Letter dated November 30, 1976, from the
             Department of Heilth, Education, and Welfare    65

      X    Letter dated October 4, 1976, from the
             Environmental Protection Agency                 71

     XI    Principal officials responsible for adminis-
             tering activities discussed in this report      73


     1     GAO note to appendixes IV-X                       44


CMO        committee management officer

CMS        Committee Management Secretariat

EPA        Environmental Protection Agency

FACA       Federal Advisory Committee Act

FEA        Federal Energy Administration

GAO        General Accounting Office

HE         Department of Health, Education, and Welfare

NSF        National Science Foundation

OMB        Office of Management and Budget
                         CHAPTER 1


     The Congress passed the Federal Advisory Committee
Act  Public Law 92-463) to control advisory committee
management and the President signed it on October 6, 1972.
The Congress passed the act because it was concerned about
the lack of policy guidelines and reliable data on advisory
committees.  It felt that with good uniform management pro-
cedures, such committees would be established only when they
were essential and would be terminated when they no longer
fulfilled a useful purpose.  The Congress assigned oversight
responsibilities to itself; the President; and the Director,
Office of Management and Budget (OMB); it assigned manage-
ment responsibilities to heads of executive agencies.

     The act defines an advisory committee as:

    "Any committee, board, commission, council,
    conference, panel, task force, or other similar
    group, or any subcommittee or subgroup which
    has been established  y statute or reorganiza-
    tion plan, established or utilized by the
    President, or established or utilized by one
    or more agencies in the interest of obtaining
    advice and recommendations * * *."

The act excludes the Advisory Commission on Intergovern-
mental Relations, the Commission on Government Procurement,
and any committee composed wholly of full-time Federal
employees.  Also excluded are the Central Intelligence
Agency, Federal Reserve System, and certain State and local

     The act sets out the following   responsibilities:

     -- The Congress mu t continually review the committees
        under its jurisdiction.

     --The President must issue an annual report describing
       committee activity in the preceding calendar year.

     --- he Director of OMB must make a comprehensive annual
        review; issue administrative guidelines and manage-
       ment controls; and provide advice,   assistance, and
       guidance to committees to improve their performance.

     -- The agency heads must establish administrative guide-
        lines and management controls, designate a committee
        management officer (CMO) to supervise and control

       the establishment of committees,      and assemble data on

     Section 9 of the act requires that no advisory com-
mittee be established unless it is (1) specifically author-
ized by statute or by the President or (2) determined to be
in the public interest by the head of the agency involved,
after consulting OMB.  Section 14 of the act requires that
committees be terminated after 2 years unless the President
or an agency head decides to renew them.  (Statutory com-
mittees, whose durations are provided by law, are not bound
by this requirement.)

     To carry out its responsibilities under the act, OMB
established the Committee Management Secretariat (CMS).
OMB is responsible for concurring or not concurring with
the agency heads' request for establishing or renewing a
committee.  It is also required to make an annual compre-
hensive review of all committee- to identify those which
should be abolished.      To implement the act, OMB issued
Circular A-63 to provide guidan e     to the agencies.

     All   the agencies   we visited have   issued committee man-
agement guidelines to implement the act. All have appointed
CMOs to control and supervise the committees in their respec-
tive s bcmpoonents. The CMOs, th- ain contact for OMB, are
responsible for maintaining inforna:tin on their agencies'
committees and overseeing the preparation and submission
of the data for the comprehensive review and the President's
annual report.

     To evaluate individual agencies' responsiveness to
the act's requirements, we reviewed operations at OMB and
at five executive agencies:  the Department of Health,
Education, and Welfare (HEW); the Department of the Interior;
the Department of Commerce; the ational Science Foundation
(NSF); and the Environmental Protection gency (EPA). These
five agencies accounted for 573 (45 percent) of the 1,267
committees in existence on December 31, 1975.

     Because of its available personnel, the General Services
Administration was made responsible for compiling the data
for the President's annual report. The 1975 report showed a
growth in both number and cost of committees, as shown

                                             Calendar year
                                      1974              1     -
     Number of committees
       (as of Dec. 31)                  1,242                1,267
     Staff-years of Federal
       support                          1,076                1,359
     Cost                         $42,380,636       $51,769,400
Obviously, attempts to reduce the number and cost of com-
mittees are making little headway.

     In 1974, 239 committees were created while 299 were
terminated--a net loss of 60 committees.  Termination was
accomplished in three ways:  20 committees were merged, 112
were abolished, and 167 were allowed to expire. At year's
end, 1,242 committees still existed.  In 1975, 272 commit-
tees were created and 233 were terminated--a net ain of 39
committees.  Termination was accomplished as follows:   5
were merged, 101 were abolished, and 127 expired.   Howaver,
the 101 abolishments included 52 similar committees
abolished by one agency. At year's end, there were 1,267
committees--25 more than in 1974.


     We have issued several reports on advisory committees.
One, "Better Followup System Needed on Recommendations by
Study Commissions in the Federal Government" (RED-76-33,
Dec. 4, 1975), addressed the immediate need for a system
which would establish and fully follow up on study commis-
sions' reports and recommendations.  It stated that OMB
should provide the leadership in evaluating such recommen-
dations.  (See app. I.)

     A January 26, 1976, report (MWD-76-79) noted that HEW's
Alcohol, Drug Abuse, and Mental Health Administration used
18 unchartered committees (see p. 23) to perform essentially
the same functions of chartered committees.

     An August 2, 1976, report (EMD-76-5) noted that the
Federal Energy Administration's (FEA's) committees were
functioning according to requirements.   However, we noted
several problemqs inhibiting committee effectiveness.
More than half the members interviewed stated their com-
mittee was ineffective or marginally effective.   Some
members said FEA had not adeauately considered committee

recommendations and had not ii formed their committee on
FEA action planned in response to committee recommenda-
tions.  In addition, some members said that their commit-
tee had not discussed all major energy issues within the
committee's scope.

     The internal audit staffs of the five agencies we
reviewed have not audited committee activities.   However,
both NSF's Office of Internal Audit and EPA's Office of
Management and Evaluation plan to review committee activi-
ties in fiscal year 1977.

                              CHAPTER 2


                       ALL USELESS COMMITTEES

     The lack of objective criteria for establishing and
evaluating committees is causing OMB and the agencies
difficulties in determining whetner many of these commit-
tees are really needed.

     Several "evaluation indicators" that could help solve
this problem by providing data on committee activity and
productivity are:  (1) number of committee meetings,
(2) support costs incurred, (3) committee age, and (4) re-
ports and recommendations issued.  Although this list is
not all-inclusive and by itself does not present a total
picture of a committee's worth, its use should lead to a
more comprehensive and  ualitative analysis of committee
activities by both OMB and the agencies.


     An aency interested in establishing a new committee
sends a letter of consultation to OMB for concurrence.
Likewise, at renewal time, agencies send a consultation
letter accompanied by an information package delineating
the committee's past activities and accomplishments.   This
renewal process is conducted biennially as required bv the

     When OMB makes its annual comprehensive review of each
committee, it tries to determine whether the committee

       --has carried out its purpose,

       -- needs revised responsibilities,

       -- should   be merged with another,   or

       -- should be abolished.

     The annual comprehensive review is implemented through
OMB Circular A-63.   The circular makes the aencies respon-
sible for mal:ing the basic evaluation of all committee
activities (the comprehensive review "justification") and
the decision of whether a committee is useful enough to
Le continued.   OMB maintains responsibility for overseeing
and reviewing the agencies' written evaluations.   On the
basis of this review, OMB is to recommend to the President

and to either the agency head or the Congress actions that
should be taken to improve committee management.  However,
our review showed  nat no such recommendations were ever

      OMB "recommends" because it cannot, under Public Law
92-463, terminate, abolish, or prohibit the establishment
of advisory committees.    However, an OMB official pointed
out that   OMB has a "perceived power" which the agencies
have elected to respect.    When OMB has disapproved estab-
lishing or renewing a committee, the agencies have always
coinplied.   According to this official, the law restricts
OMB's authority, but agencies would not defy OMB's deci-
sions because of repercussions.

     Only agency-established committees must have an
estaolishment request.  As provided by the act, statutory
and Presidential committees have only to submit a charter;
therefore, they are not evaluated and do not have to
justify their establishment.  However, OMB officials said
that, theoretically, these committees are still subject
to renewal and comprehensive reviews; but they added that
actually these committees receive little attention from

     Botn agency officials and OMB hesitate to request
abolishing Presidential and statutory committees, because
such committees can be terminated only by an executive
oraer or legislation.  All other committees, under the
2-year limitation provision of the act, can be terminated
it the agencies do not request their renewal, either with
or without OMB's recommendation to do so.

     However, terminating even these committees can be
difficult.  One OMB official said that, in a recent case,
convincing an agency to terminate a committee required
extensive negotiations and documentation and took about
10 working days.  He felt that, because of his workload,
10 days was excessive.

     If OMB approves a request for establishment or
renewal, it so informs the agency orally; if not, it
usually sends a letter of nonconcurrence.   Among the
reasons OMB gives for nonconcurrence:   (1) a proposed
committee is not consistent with the agency's role,
(2) a proposed committee will duplicate activities of
others, or (3) an established committee has accomplished
its objectives.

     During 1974, OMB sent no letters of nonconcurrence.
In 1975, it sent only four letters denying establishment
and none denying renewals.  Between January 1 and May 11,
1976, OMB sent seven letters denying the establishment of
10 committees and two letters denying renewals for 2
committees.  In addition, some agencies, because they
preferred to, received nonconcurrence decisions orally.
Officials at three of the five agencies we visited esti-
mated that, from January 1974 to May 1976, they received
27 oral nonconcurrences--25 of these were in one agency.

     Since 1975, establishment and renewal requests, and
comprehensive review justifications have been sent to OMB
budget examiners for evaluation.  These evaluations are
usually brief, since committee affairs are not a high
priority and the examiner's main responsibility is
analyzing agency programs.  Further, some examiners'
reviews are less comprehensive than others'.  For example,
for the four budget examiners we interviewed, the annual
time spent reviewing committee requests 'stablishment
and renewal) and annual review justifica  ons ranged from
3 to 10 days.

     The budget examiners told us their reviews are based
on personal knowledge of the agency's needs, its role, and
the priority of programs being implemented.  Their main
source of information on committee activities is agency
justifications, although they can ask agency program
officers for further details.  They can also examine com-
mittee reports, attend meetings, and contact committee
members (except, of course, in the ctse of a establishment

     The comprehensive review consists of answering a set
of questions provided by OMB. The program officials
collect and prepare the justifications that division
directors and other top officials later review to insure
conformance with agency policy and needs.  Two common
justifications for committees' existence are that they
are (1) a source of expertise and (2) a contact point for
outside groups.  Established committees with little or no
activity are sometimes justified on the basis of future
usefulness and need.

      OMB made its second comprehensive review in November
1974.   (The first review was made in July 1973.)  The
agency justifications for the second comprehensive review
varied widely in scope and detail, but in most cases they
were not sufficient for OMB to accurately appraise whether
a committee should be continued or abolished.   Nor did
OMB--with the data that was submitted--make an analysis,

produce a summary or report, or make recommendations
regarding overall committee activities.  In short, agen-
cies received no constructive feedback from OMB on tn*fr
committee activities.  For this reason, officials at four
of the five agencies reviewed by us questioned the purpose
and need for an annual comprehensive review.

     To improve its annual comprehensive review, OMB
changed the procedures and timing for submitting agency
data for 1975.  First, Circular A-63 was revised to provide
new instructions which emphasized that OMB's comprehensive
review was to be a qualitative analysis of each committee.
These instructions also attempted to improve the quality
of agency submissions by outlinina the information required
for the OMB comprehensive review.  Second, the timing of
the review was changed from November to April for three
basic reasons:

     1.   Agencies could prepare the annual report and com-
          prehensive review material simultaneously, since
          the annual report material is due on March 31 to
          the Congress.

     2.   OMB could have the  uantitative data from the
          annual report before performing its  ualitative
          analysis of committee operations.

     3.   OMB budget examiners could fully participate in the
          review process because the review was moved from
          the middle o the budget cycle.

     Additionally, OMB is setting up a ccn,puterized infor-
mation system to help spot duplication of activities by
similar committees at different agencies.  The CMS staff
was also increased to its present level of four positions
to permit a more detailed review and improve oer3ll
management.  (We could not evaluate the effectiveness of
all these changes because the 1975 comprehensive review
had not been completed before we finished this report.)

     Agency justifications for 1975 were improved over
those of the previous year. However, most of the five
agencies' justifications were still too general and
sketchy foL OMB to accurately appraise a committee's

     According to one agency CMO, his agency tried to
expand its 1975 annual review process by holding review
meetings involving the department CMO and program
officials.  At these meetings, the officials explained their
justifications for continuing committees. The agency

invited OMB budget examiners and CMS officials to these
reviews so they could become more familiar with the
committees' activities.  We attended three of these
reviews ourselves.  However, they seemed to be more of
a forum for explaining the committees' activities, rather
thai a critical look at the need to continue committees.
No other agency had tried this precedure.


     OMB has provided only limited guidance on the crite-
ria that should be used to determine if a committee
warrants continuation.  As a result, neither OMB nor the
agencies have systematically and consistently used objec-
tive criteria to help evaluate committees.  Using the
evaluation indicators would at least help in determining
whether committees should be established or renewed.

     Section 7 of the act requires OMB, after making the
comprehensive review, to submit recommendations to the
President and to either agency heads or the Congress
concerning any action that should be taken.   In 1974 OMB
issued no such recommendations; however, for 1975 it had
begun to provide feedback to the agencies on questionable

     The act further states that the head of an agency,
after consulting with the OMB Director, must determine as
a matter of formal record whether a committee is "in the
Public interest."  However, the act does not specify what
the criteria are for such a  etermination, and OMB has
not clarified the situation. despite the fact that it
issued Circular A-63 as a guide.

     The circular states that advisory committees should
be essential--if not, they should   e terminated.  It
contains nine factors (such as number of meetings and
reports) which the agencies must consider in making their
reviews.  The problem is that the agencies respond to the
factors but do not consider them integral to committee
evaluation.  An OMB official agrees that neither OMB nor
the agencies have used these factors to develop objective
criteria for evaluating committees.   He added, however,
that developing such criteria is difficult because of the
variety of committee types and activities.

     At the agencies we visited, CMOs said that they do
not have the authority or expertise to decide whether to
continue or terminate a committee.  Their only basis for
termination was the information submitted by program

officials.  In addition, as stated, no agency we visited
has used its internal audit staff to independently review
committee operations.  Therefore, division directors and
program officials have to evaluate the effectiveness of
their own committees and decide whether they should be
continued, merged, or abolished.

     One OMB oudget examiner told us he tried to develop
objective criteria--"workload projections"--to help him
make an accurate determination. His is the only attempt
we have seen to introduce some objective quantitive
analysis into the review process.

      Like OMB, four of the five agencies have not tried
to develop objective evaluation criteria. The one agency
that has tried has guidelines that recommend abolishing
or converting committees which have not been staffed for
1 year or have not met for 2 years    The other agencies
felt that these two factors are not accurate measures of
committee usefulness.

     The need for better evaluation is shown by the
following committees, which have been allowed to continue
year after year.

     Example   1--An agency-established committee was
                  set up in January 1973 and renewed
                  in January 1975.  However, in 1974
                  this committee never met, produced
                  no reports, incurred only $320 in
                  costs, and had only 0.11 agency
                  staff-years of support.  And in 1975,
                  the committee never met, produced no
                  reports, incurred no costs, and had
                  no staff support.

     Example 2--A Presidential committee was estab-
                lished in April 1972 and renewed in
                January 1975.  In the past 4 years,
                it has not met, prepared any reports
                or recommendations, incurred any
                costs, or used any Federal staff
                support.  In 1976 the agency
                recommended to OMB that the com-
                mittee be eliminated.

     Example 3--A statutory committee was estab-
                lished in 1972 and renewed in 1974.
                During the past 2 years it has not
                met, produced any reports or recom-
                mendations, incurred any costs, or

                used agency staff support.  In 1976
                the committee started to meet.

     Example 4--Two statutory committees were
                established in 1970 and renewed
                in 1975.  During the past 2
                years the committees have never
                met or prepared any reports.   In
                1974 neither incurred any costs or
                staff support.  In 1975 one did
                incur $10,000 and 0.5 staff-years
                of support.  One committee was
                terminated on December 2, 1976,
                while the other had begun to meet
                in the spring of 1976.

     OMB, in commenting on our report (zee app. V), stated
that only one of these committees could have been termi-
nated by unilateral agency action (three required congres-
sional action, one Presidential).  It stated that despite
this, in each instance, the agencies and OMB did uestion
the committees' inactivity, explain it, and take appropriate
actions. OMB added that rather than indicating a need for
a different process, the e mples appear to illustrate that
present procedures do prow.de for a meaningful evaluation of

     We believe, however, that the examples demonstrate
that, even though OMB and the aqencies in their annual
reports on committee activities disclosed the inactivity
of these committees over several years, no action was
taken to terminate them.  Therefore, the examples
demonstrate the need for agencies and OMB to not only
report inactivity but to more closely look at committee
activity and terminate the useless ones.

     Committees should not be established and retained in
anticipation of future use but should only be used when
there is a demonstrated need. When committees are
established by congressional or Presidential action
and are inactive, then appropriate steps should be
taken to terminate them.

     Presently, evaluation is based on the principle of
shared responsibility by CMB and the agencies.  The
agencies can and should make the basic determination of
whether to continue or terminate a committee.  However,
OMB can best oversee and uestion the need for a com-
mittee and provide the basic format for all agencies
to follow during the review process, because it has
responsibility over budget activities.  Because of this

shared responsibility, OMB and the agencies must work
together to develop objective criteria for evaluating

Proposed evaluation   indicators

     Evaluation indicators, used together, could provide
a basis for a consistent and systematic evaluation process
and help determine whether a committee is fulfilling its
purpose.   The indicators are not all-inclusive and, of
course, do not present a total picture of a committee's
worth.   They are oly a mechanism to "flag" those committees
which need to be scrutinizeo.   But their use should lead to
better committee evaClCinon   y both OMB and the agencies.

     The information  or :     indicators could be readily
obtained from the responses co OMB's nine factors.  (See
p. 9.)  However, effective use of such indicators
requires the full commitment of both OMB and the agencies.
The proposed indicators aLe,

     1.   Committee meetings.

     2.   Budgeting and    staff support.

     3.   Committee age.

     4.   Reports and recommendations.

     These indicators can be easily quantified. They also
lend themselves to a qualitative analysis of committee
activities, especially when used with two other factors:
committee purpose and committee alternatives.  These will
all be discussed in the following pages.

     Using the four indicators, we identified committees
that would warrant further investigation.   (Apps. II and
III indicate the results for the five agencies visited
and all other Federal agencies for 1974 and 1975.)   In
Doth 1974 and 1975 the five agencies visited had a lower
percentage of questionable committees than all the other
agencies combined.  However, no significant improvement
was made from 1974 to 1975 for either the five agencies
or the others

     For both years, statutory committees had a higher
percentage of committees with no meetings and no reports
th-n Presidential or agency-authorized committees.  For
1974 statutory committees had a higher percentage of com-
mittees over 10 years old, but in 1975 agency-established
committees had a slightly higher percentage.

     The 1975 figures indicate that, of all committees, 26
percent had no meetings, 59 percent had no reports, and 36
percent were over 10 years old.  This is a slight improve-
ment over the 1974 figures; however, the figures still show
that many committees need to be scrutinized further.

     The following pages explain the use of the indicators
and give examples of how we used them in the five agencies
visited, as well as in other Federal agencies using advi-
sory committees.

       Committee meetings

     The annual report data shows the number of meetings
held during the previous year.  We believe that, if a
committee held no meetings, it may well be inactive and
perhaps should be terminated.  Also, a committee which holds
one or two meetings, when six or seven are scheduled as
necessary, could be considered fairly inactive and perhaps
not very useful.  In either case the committee should be
investigated further, to find the reason for its inactivity
and to determine if it should be abolished.

     For example, an agency we visited had statutory com-
mittees with the following records:

         Number of             No          One     More than one
         committees         meetinqs     meeting      meeting

1974          55               15           5           35

1975          61               12           8           41

     An agency we did not visit had the following record
with its statutory committees:

         Number of             No          One     More than one
         committees         meetings     meetinq     meeting

1974          60               53           3            4

1975          57               53           1            3

     At anothe. agency visited, many agency-established
committees showed little activity for the past 2 years:

         Number of             No          One     More than one
         committees         meetings     meeting      meeting
1974          57               10          11           36

1975         105               37          50           18

     Although these figures may include newly established
or abolished committees, some committees clearly deserve
more scrutiny.

        Budgeting and staff suport

      The annual report provides the annual cost and
staff-years of Federal support for each committee. Some
committees have no or very negligible staff and budgeting
support, which could indicate a lack of agency commitment
to the committee and its activities, or a shift in priori-
ties.   It may be desirable to abolish such committees and
explore alternatives when public input and advice is

     For example, an agency we visited had the following
cost and staff support figures for its aency-established

                                                  Staff support
       Number         Cost       _        No    ess
                                                 L    t-ain More than
       of com-    ~1 to           -,     staff-  one-half    one-half
       mittees $0 $2,000 and higher      years staff-year staff-year

1974     43     U    5        38           0        40         3

1975     50    10    1        39          10        37         3

     An agency we did not visit had the following cost and
staff support figures for its agency-est;Ablished committees:
                                                   Staff support
       Number         Cost     _No                Less than More ta
       of com- ---   to       ,o---       staff-  one-half one-half
       mittees $0 $2,000   and higher     years  staff-year staff-year

1974     38    18    6         14              18        7         13

1975     27     9    8         10               9    17             1

     Cost figures are usually questioned only when a com-
mittee's activities are used to justify large expenditures.
Neqligible staff support and other costs are rarely  ues-
tioned, although they could be important in indicatina com-
mittee usefulness and need.

     Officials of one agency believe that the existence of
a committee that s not incurring an? staff support and
other costs is not a problem, because it does not harm or
cost the Government.  However, the Comptroller General
disagreed in 1970 hearinas, when he stated:

    "One of the more significant problems is in the
    danger of committees being permitted to remain in
    existence beyond their usefulness.  If the con-
    tinued existence of a committee serving no useful
    purpose involves staff and operating expanses,
    then an obvious waste of funds occurs.  Even if
    continuation is in name only, involving no staff
    or expenses, it is undesirable merely because o
    Ehe confusion    t creates botl in Government and
     in the    1fs oTis e   public     * * *."   (Underscoring
     A committee, when created, should be given sufficient
staff and funds to effectively carry out its activities.
However, the above examples and appendixes II and III
indicate that some committees may lack such support.
     Committee age

     The annual report also lists committees' creation
dates. Old committees could be questioned as to (1)
whether their advice is still needed and (2) if it is,
whether such expertise should be made a permanent part
of the agency, by hiring qualified personnel. According
to the overall figures for 1974 and 1975, over one-third
of the committees are over 10 years old.
     Two of the agencies visited had the following break-
down for 1974 and 1975 agency-established committees:
Aency A         Number of committees               Over 10 years old

  1974                      305                             82

  1975                      282                             83
AgencyB         Number of committees               Over 10 yearsold

  1974                       57                             26

  1975                      105                             35

     An agency we did not visit had an even higher percent-
age of agency-established committee. cv-:         10 years old.

The breakdown was as follows:

                Number of committees               Over 10 years old

  1974                      id                              86

  1975                      125                             74

     Further analysis of older committees could show that
some have become perpetuated and are continued not because
of their contributions, but because of tradition.

     Reports and recommendations

     The annual report lists written reports submitted by
the committees during the year.   This is to provide quanti-
fiable committee output.   The five agencies' 1974 and 1975
anrtal reports show that 64 percent and 59 percent, respec-
tiv: v, of tno· committees did not produce a report.

     agepcy officials, however, assert that many committees
perform valuable services without publishing a report.
Therefore, they believe that the number of reports alone
should not be used to measure committee output.  We agree;
measuring committee output could be better accomplished by
considering the number of reports and the number of formal
recommendations.  Such recommendations could include formal
committee resolutions, letters to the agency listing recom-
mendations, consensus advice given in summary form, or
otner written formats, all of which would be "hard evidence"
of committee advice.

     Besides making a quantitative analysis, agencies should
perform a qualitative analysis of such reports and recom-
mendations.  Such an analysis could include (1) who ini-
tiates the recommendations and (2) how the recommendations
are disposed of procedurally.

     Recommendations should be classified as to whether they
are initiated by the agency or by the committee.  If most
recommendations are initiated by the agency, the agency
may be doing most of the work, and the committee may be
merely approving predesignated agency decisions.  If most
recommendations are initiated by the committee, it may
indicate that the committee is productive and independent.

     Procedurally, the agency should indicate who requested
the committee's advice and to whom the ensuing recommenda-
tions are directed.  Also, it should indicate the responsi-
ble oficials involved in accepting, commenting on, and
implementing the committee's recommendations.

     The agency must show how the committee's advice and
recommendations were used in agency decisions.   The agency
should indicate whether the committee recommendations were
timely, how they were acted upon, and whether both the
agency and the committee were satisfied with the quality
of tne recommendations and the responses, respectively.   A
prior report of ours also discussed these ideas.   (See app.

     Other factors

     Besides the indicators mentioned above, there are two
other factors which, although not easily quantified, could
provide essential information for a qualitative evaluation.
First, the committee's purpose--when incorporated into the
agency's review--should be clearly stated, along   ith how
and when it will be accomplished.   (Committee charters do
contain a statement of purpose, but the language may b so
vague that it is meaningless.)  Second, an evaluation
should include information about what alternatives other
than committees are available for accomplishing the same
objectives and why those alternatives are not being used.

     By using the second factor, agencies could introduce
a kind of cost-benefit analysis to committee activities.
Committee costs can already be computed from the
staff-years and expenditures shown in the annual report;
benefits, though, are extremely difficult to obtain and
must e determined subjectively.   However, agencies could
still ascertain a committee's worth by asking such critical
questions as:

     -- Could the agency secure the same quality of
        advice from different sources more cheaply?

     -- How does the committee affect agency decisions?

     -- How else could the agency use the funds and
        staff allocated to the committee if it did
        not exist?

     --Could these funds and staff be better used
       in other ways?

     --To what extent does the agency seek the
       committee's advice?

     -- What type of activity is the committee
        performing?  Is it merely rubberstamping
        agency decisions, or is it contributing
        substantially to agency programs?

     OMB and the agencies have failed to systematically
and objectively evaluate committees.  The indicators and
factors described in this section, if used systematically,
should help "weed out" useless committees.

                         CHAPTER 3

                    BETTER LEADEPSHIP AND

                     GUIDANCE POSSIBLE

     The Federal Advisory Committee Act directs the Office
of Manaqement and Budaet and the agencies to prescribe
administrative guidelines and management controls ali-
cable to advisory committees.   The act states that com-
mittee management should be   overned by uniform standards
and procedures.  Even though OMB hs issued standards and
guidelines, it has failed to provide the effective leader-
ship and adequate guidance necessary to insure implementa-
tion.  In addition, the agencies we visited have not pro-
vided adeouate guidelines for their own personnel.

     OMB's and the agencies' lack of guidance and enforce-
ment has led to the following managerial failures and
inconsistent committee standards and procedures:

     -- Because of uncertainties about   which types of
        committees fall under the act,   some agencies
        may charter certain committees   while others
        may leave them unchartered and   thus beyond
        the reach of OMB and the act.

     -- Incomnatible cost fiqures--the result of incon-
        sistent cost computation methods--make it
        difficult for the Congress and OM9 to evaluate
        a committee's cost effectiveness.

     -- Charters, which can be an instrument for agency
        accountability, are written in aeneral terms.

     --A repnort---a uantifiable measure of committee
       productivity--is defined differently among and
       within agencies.

     -- No established procedures for evaluating and
        following up on committee recommendations have
        been developed, except for Presidential com-
        mittees (as reauired by the act).

     Agency officials complain about inadequate OMB guid-
ance, while OMB officials say the agencies are ultimately
responsible for committee management.  We believe that
both OMB and the agencies must exert more administrative
leadership.  OMB should insure that uniform Government-wide
committee procedures are maintained.  The agencies must
strongly enforce these procedures through specific and

consistent guidelines and oversight. Unless these
guidelines are improved and implemented properly, the in-
consistencies we found among and within the five agencies
will continue to exist.

     OMB guidelines are unclear about the status of sub-
groups and ad hoc groups, causing inconsistent decisions
among agencies on whether or not to charter a committee.
Additionally, agencies have failed to adequately oversee
and guide their personnel regarding the formation of sub-
groups and ad hoc groups.
     Although the act includes subgroups within its ccm-
mittee definition, OMB's Circular A-63 does not expand on
the act's definition. OMB, however, does have an informal
working definition to determine if a subgroup requires a
charter separate from the parent committee. Subgroups with
any of the following characteristics have to be chartered
     -- Membership different from the parent committee.
     -- A function different from or additional to that
        of the parent committee.
     -- The capacity for independent action.

But, since OMB has not formally communicated this definition
to the five agencies we reviewed, they have developed their
own criteria for subgroups.
     Three agencies' committe management guidelines state
that any proposed subgroup having a member who is not on
the parent committee must be separately established. One
agency further distinguishes between formal subgroups
having the characteristics of an advisory committee and
informal subgroups having some or none of the characteris-
tics. The latter do not have to be chartered or adhere to
the act's provisions.
     A fourth agency emphasizes that subgroups should be
separately chartered, not if their membership differs,
but if they possess the following characteristics:
specific membership, defined purpose, periodic meetings,
and an organizational structure. The fifth agency's

guidelines merely state that the act applies to subgroups,
without any further explanations or breakdowns.

     A key distinction made by OMB between a subgroup
that should be chartered separately and one that should
not be is whether the subgroup has committee members not
on the parent committee.  However, one agency creates
subgroups with one or more committee members and a number
of hired consultants who are not ccnsidered "outside
members."  OMB and agency officials said the main distinc-
tion between a consultant and an outside member is their
title, since they often do the same things for the same pay.

      According to an OMB official, the agencies are respon-
sible for classifying the individual as a consultant or
outside membeL.   For example, one agency separates members
not on the parent committee into two categories:   consult-
ants and outside members. The agency's general counsel
believes that a subgroup composed of one parent committee
me-mber assisted by consultants need not be individually
c   -tered and cannot be regarded as a subcommittee.  His
rat onale is that the subgroup is neither a wholly new
committee nor a reaular subcommittee composed wholly of
parent committee members.   It is merely an extension of
the committee through the use of consultants, and the law
does not restrict the number of consultants who may work
with a committee.

     As a result of the general counsel's opinion, the
agency has established 37 subgroups, according to the unit
official, each having from two to four consultants.
Although the agency   ives public notice of meetinas between
committee members and consultants, such extensive use of
consultants could easily lead to committees'   ettina
surreptitious advice, violating the openness and full dis-
closure intent, if not the letter, of the act.

     One agency occasionally uses fact-findinq study panels,
in addition to regular subcommittees, to gather information
for a chartered parent committee.  These panels are usually
staffed by parent committee members and consultants. The
aqency's general counsel has decided that these panels do
not have to be chartered separately because they are only
fact-finding groups and do not provide advice or recommen-
dations. Conseauently, they do not have to announce their
meetings or adhere to any other provisions of the act.

     We recognize the legal distinction made by the agency's
general counsel but believe that a definite possibility for
abuse exists.  The major problem is the difficulty in dis-
tinguishing between advice and fact findinq and in assuring
that study panels merely provide facts.  For example, one of
the agency's committees had several study panels providing
facts in the form of advice, thus overstepping their purpose.

     Similarly, at another agency visited, one operating
unit had a committee using a subgroup which was not sepa-
rately chartered, because its purpose was fact finding.
This subgroup comprised members not on the parent committee
and held meetings without publishing notices.  The rationale
for not chartering the subgroup was the same used by the
agency with the study panels. However, when we uestioned
the existence of this subgroup, the agency decided that
such a fact-finding subgroup could fall under the act.   The
subgroup has since been eliminated and open hearings will
be used instead.

     An OMB official agreed that chartering fact-findinq
committees is a gray area because of the difficulty in
separating advice from fact finding.   He said that he was
unaware of the agency's use of study panels but that, in
any case, the Department o Justice must finally determine
whether they should adhere to the act.

     We believe that OMB should provide, in its guidelines,
a definitive list of which subgroups should adhere to the
act.  This would help insure uniform interpretation and
reporting throughout the Federal Government.

Ad hoc groups

     OMB Circular A-63 provides no guidance on the status
and chartering of ad hoc qroups--defined only as committees
lasting less than a year--but does reauire the agencies to
report such groups in their annual report material.  Lacking
adequate OMB  uidance, two of the five agencies visited did
not furnish their operating units with detailed procedures
on ad hoc roups. As a result, operatino units varied in
their chartering and reporting of ad hoc groups.

     Three of the aqencies we visited included in their
guidelines some clarification of the status of ad hoc
groups.  One agency's guidelines indicate that ad hoc
groups are covered by the act if they have a fixed member-
ship and periodic meetings. The other two aqencies' guide-
lines include ad hoc groups within their definition of an
advisory committee.  Thv o not, however, distinguish

between an ad hoc group that meets once and one that meets

     Because of one agency's unclear ad hoc group guide-
lines and weak oversight, its operating units interpret ad
hoc group chartering and reporting requirements differently.
For example:

     An operating unit official stated that even a
     one-time ad hoc meeting should be chartered to
     insure that public notice is given.  To avoid a
     possible misunderstanding about the need to
     charter one-time meetings, this operating unit's
     policy is to convene a meeting of one of its
     standing committees.  The desired specific topic
     is discussed at this meeting and the public is
     invited to participate.  However, another
     operating unit's guidelines state that "ad hoc
     groups * * * called to meet once or twice to
     provide advice and counsel on a specific plan or
     program" need not be covered by the Federal
     Advisory Committee Act.  Consequently, a number
     of similar meetings, which would have been
     publicly announced by the other operating unit,
     take place within this unit without the public's
     knowledge and OMB's oversight.

      Lack of agency criteria and oversight regarding ad hoc
groups has also resulted in discrepancies within another
agency's operating unit.       The agency's guidelines include
ad hoc groups within its definition of a committee but do
not specify whether one-time meetings or periodic meetings
should be chartered.       However, the agency CMO explained
that,   even if   a  group meets only once to provide a consen-
sus  of  advice,    that group should be chartered as a commit-
tee.    An operating unit's CMO, on the other hand, indicated
that ad hoc groups need not be chartered unless they hold
regular meetings and have a regular membership.        Such
differences    in   interpretation should be resolved.

Other groups
     A particularly troublesome situation exists at one
operating unit, concerning committees serving programs not
included in the President's budget.       This unit requested
OMB approval in  establishing  these   committees;   however, OMB
denied approval  mainly  because  it  did  not  want to be culpable
for establishing  committees  that   would  serve  programs not in
the President's  budget.  OMB did  say  that   if these programs
were approved by the President, such committees would be con-
sidered for chartering. This statement, however, did not
resolve OMB's conflict with the unit.

     Partly as a result of this conflict, the unit main-
tained and used 18 unchartered committees through fiscal
years 1974 and 1975.  These committees reviewed 46  ercent
of the agency's grant proposals during calendar year 1975,
but were never reported in the President's annual report and
never adhered to the act's provisions.  Thus, the operating
unit was violating the act in fiscal years 1974 and 1975.
However, the unit officials said that since February 1976
OMB has concurred in the chartering of 11 new initial
review groups, and, at the present time, all charters being
requested by the department on behalf of the unit are get-
ting OMB approval.

     Due to its conflict with OMB, the above-mentioned unit
is using groups made up of consultants to review many of
its grants.  Because these groups consist of consultants,
the agency feels it does not have to charter them or see
that they adhere to the provisions of the act.  Agency
officials say the groups' meetings are merely staff reviews
in which the consultants give their individual opinions.

     The use of such groups in the operating unit is exten-
sive, and even one of the unit's officials  uestions such
use, saying it produces lower  uality reviews and under-
mines the accountability standards intended by the act.
Also, these groups' use of consultants could be violating
the intent, if not the letter, of the act.  Therefore, they
should be chartered or terminated as soon as possible.

     OMB should develop stringent and uniform guidelines on
both subgroups and ad hoc groups, emphasizing that such
groups should not be used to circumvent the act, unwittingly
or otherwise.  A standard definition can insure that aency
guidelines are consistent.


     Our   analysis of committee charters   indicated that the
statements about a committee's purpose ar. vague.      Also,
the charters fail to specify the amount of time needed by
a committee to accomplish its objectives.

     OMB requires that agencies terminate a committee when
it is no longer fulfilling its purpose. The charter is
the basic document describing that purpose. However, some
charters do not specifically describe the committee's mis-
sion. Hence, we believe that neither OMB nor the agencies'

CMOs can determine precisely what a committee's purpose is
and when a committee is no longer fulfilling that purpose.

     The act requires the agencies to include in the
charters the amount of time the committee needs to fulfill
its purpose.   Only one agency reviewed included such infor-
mation in its charters.   However, a closer examination of
one of that agency's bureaus showed that 47 of 48 charters
stated that the committees would exist for an "indefinite
duration."   In another bureau. 21 of 31 charters had similar
statements.   All other agencies used the automatic 2-year
lifespan between renewals as the time needed by the commit-
tees (except ad hoc groups).

     The agencies should use more exact estimates of
committee lifespans.  ThE only estimate thaL should be
difficult is for grant and proposal review committees,
because of their continuing function.  However, even these
committees should not be considered "immortal."

     The committee charter should not be a mere formality,
but a tool for agency accountability.   It should also be
a document that provides the Congress, OMB, and the public
with essential and accurate information on committee acti-
vities.  OMB should require that agencies be specific in
outlining a committee's pirpose, because a vague purpose
is confusing and provides no information to measure a com-
mittee's usefulness.  OMB should also insure that the
agencies include in committee charters the estimated time
a committee needs to accomplish its purpose.   This would
force the agencies to think of committees as temporary
ratner than permanent bodies.


     The costs the agencies provide for the President's
annual report and OMB's comprehensive review are incomplete
and not comparable.   The report and the review require
agencies to subnit the costs attributable to each committee.
In the annnual report forms which are used in the compre-
hensive review, OMB recommends several cost items that must
be considered; however, nowhere does OMB give a standardized
method for computing the costs.   Agencies have also failed:
first, they provide no standardized method for program
officials to use in computing committee costs and, second,
they are not insuring that CMOs carefully review and ques-
tion whatever cost calculation methods the program officials
end up using.

     The OMB guidelines say nothing about including the
agency administrative overhead costs as part of committee

costs.  Nor is the present annual report form designed to
capture su.. costs; it requests only Federal staff support
and total committee costs for each committee.  Not including
administrative overhead costs as part of committee costs
could result in cost understatements at large agencies.
The following chart describes, by staff-years and grade
level, the administrative overhead costs for the five
agencies visited.  According to the data provided us, about
58 staff-years (73.33 staff-years less 15.35 staff-years)
of Federal support in time and costs were not included in
the President's annual report for calendar year 1975.

               Committee Management Staff-Years by Giade Level
                                                              ½neral SCh-dule Gr:ote

    Agency         16      15        14       13                        I           1:J         9       .                         i1.                                iiit                1   l4

NSF          ,      0f                                             1.0.
                                                                   1:.                                                                                                      ;   .   .

EPA                                                     1      .                                                                           1.

  (not? aj                1.0        .25          .     1.         i.
                                                                   I.                           .       ,             .

  (note      a;                      .0        I..1.0 2.9          { .35           2.     9.        .       .2      4. .      ]   ..     11.H        7 .,                                ,
I   ter iJr
    (note {,)      .13'          I                                 -..                                                    2               1..                                       . I.

       rotal       .1     2.      3.5             ,3    4.9             .37        2.[. - 12.       .               -..                  13.
                                                                                                                                          3.         .i            ...      .       ..

i I   Icludeo r, otll Co)m..-rc7 s         3ut  J\;           -t .:~n_d;  t:l.J ill.
                                                                                f      'i:    s:z. lil.. ')J .I ?j
                                                                                                                I % -I     rIt i 3[I . I I                              TI I     I *
    COSt3, which ate ir        l Ieli       in tr.e         ]-er         S: vi -,    . \irinistrition            f1oi . I1 I F . l I ;t.ltf                           ;I .: )Ir.     I
    tneso tlo operating Inis                total           15.353      taft years.

o/ lnI luae;      ornly dep rltment        levl        a1n    E urau          ot    Lan:I      3lll.ment         .omritt      .    ri1.ig..O    nt        l0I-t.

     The costs reported by the various committees within all
the agencies fell into such categories as:

               -- Direct costs only.  Includes salary, travel, and
                  per diem allowances for comnmittee members. Also
                  includes travel and per dem for Federal employees.

               -- Direct costs plus an estimate of agency staff time
                  devoted to committees.

               --Direct costs plus calculated staff time and agency

     Many costing variations existed within agencies.   In
one agency, costs were consistently computed to include only
direct costs, not Federal staff support costs.   Therefore,
its cost figures were incomplete.   An agency official said
that the Federal staff support costs were not included
because determining how much Aime a staff member devoted to
committee activities was difficult.

     Lack of clear guidelines and CMO oversight has
produced different computation methods at the five agencies
visited. Following are several examples:
     1.   Cost figures are not consistent or comparable.
          One committee includes direct costs but excludes
          2.5 staff-years of Federal staff support costs.
          Another committee includes all direct costs plus
          an estimate of staff support costs.
     2.   One operating unit's committees include direct
          costs, staff support costs, and an overhead
          factor for the entire operating unit. Another
          operating unit's committee includes direct costs
          and an estimate of staff time devoted directly
          to committee activities.

     3.   One operating unit, recognizing the inadeaua-
          cies of past reporting practices, has developed
          a standard method for all its committees which
          accounts for both direct and indirect costs.
          The operating unit's budget analysis section
          reviews all the cost data. Another operating
          unit within the same agency includes only
          direct costs and a staff support cost estimate.
     Agencies said they had no trouble computing direct
costs, such as committee members' salary and per diem,
travel, and consultant fees, because they were easily
accountable. However, as shown by the above examples,
agencies did have trouble estimating Federal staff support
costs because of t   difficulty in separating committee
activity staff time from staff time spent on other duties.
     Agencies' inability to accurately determine staff
support not only provides a misleading figure on Federal
staff time spent on committee activities, but also affects
the cost data. In most cases, the figures in the annual
report and comprehensive review data are not the best
estimates of the Federal staff support costs necessary to
manage ommittee activities.

     The lack of a standard definition of "resort" results
in inaccurate and misleading figures being included in both
the annual report and comprehensive review. Although OMB
requests information on the number of reports issued by a
committee, it has never defined "resort." The agencies have
been left to develop their own definition. As a result,
there are inconsistent definitions and inaccurate counts of
reports among and within agencies.
     As noted earlier, the number of reports issued is an
indicator of a committee's productivity and usefulness.   It
is also a basis for comparing committees, but an inconsistent
or nonexistent definition makes such comparisons difficult.

     For example, one agency we visited reauires that all
the operating units' committees submit brief annual sum-
maries of their activities; the agency then counts these as
committee reports when compiling the annual report and
comprehensive review material.  However, another agency
also requires these summaries but does not consider them to
be committee reports.  Two other agencies consider only
formally published documents as reports, while another
incl! es in its definition of report the act's reauired
"Ant al Closed Meeting Report" and formally published docu-
ments sent to the head of the agency.  Such discrepancies
can only confuse OMB, the Conqress, and the public when
they compare the cutnut of committees from various aaencies.

     The discrepancies are not just among agencies, how-
ever, they also abound within agencies. Only two of the
five agencies we visited provided their personnel with a
standard definition of a report.  But since they do not
enforce the use of that definition, these two agencies have
just as much internal confusion over what a report is as
the agencies that have no definition.

     For example, one agency's committee management guide-
lineb define committee reports as "specific subject reports"
which are "issued, made, or approved by any department
advisory committee."  These reports, according to the agency
CMO, are the onl; ones that should be noted in the annual
report and comprehensive review. One of the agency's opera-
ting units does follow these guidelines in computing the
number of its committees' reports.  However, another
operating unit does not; it includes minutes of meetings as
reports.  Had it adhered to the guidelines, this operating
unit would have issued zero--instead of 40--reports in 1975.

     In another agency, whose committee management handbook
does not formally define a report, varying interpretations
have been made by and within its operating units.  Within
one operating unit, a committee's recommendations and the
operating unit's feedback are considered to constitute a
report.  Within another operating unit, one official views
a report as a "comprehensive document on a specific topic
for the agency head," while another defines a report as a
publication authored and produced by the committee on is
own initiative.

     Due to such inconsistencies, cited report figures do
not provide the Congress, OMB and the public with an
accurate picture of committee productivity.  Such a picture
is impossible until a standard definition of a report is
developed. OMB and the agencies should jointly develop a
definition to be used and enforced by all Federal agencies.


     Neither OMB nor the agencies we visited have estab-
lished standard procedures which insure that agencies
follow up on committee recommendations. Without a followup
system it is difficult to evaluate a committee's usefulness
or be assured that agencies consider their committees'
advice when formulating policies and programs.  Such a
system is needed to assure the committees and the public
that agencies use committees properly and effectively.

     As it did with the definition of report, OMB left the
responsibility for feedback or followup to the aencies,
who, in 'urn, left it to their proaram officials. As a
result, various methods have been used to provide feedback
to committees.  For purposes of this review, we have
divided the feedback methods used into two types:   formal
and informal.  Formal feedback is a written response from
the agency to its committees; informal feedback is an oral
response.  Most committees get informal feedback.   For
example, ne agency program official said his committee
would see the results of its recommendations primarily in
the way operatinq unit policies were implemented. Althouah
the agency head and the operating unit director had met
with committee members to discuss both formal and informal
recommendations, no formal feedback system existed.

     Only infrequently did we find committees receiving
formal feedback.   For example, at one agency's operating
unit, program officials prepared a statement of committee
recommendations and proposed agency actions after each
committee meeting.   Other agencies sometimes used the same
system;  other times the committee would send a letter to
the agency head listing its recommendations and requestinq
feedback. Again, however, formal feedback was rare; we
found no agencywide policy of providing written feedback
and followup on committee recommendations.

      We believe that an effective followun and feedback
system is essential to evaluating committee usefulness and
need.   Aencies should respond in writino to recommendations
and should indicate why they agree or disaqree with them.

The response should also indicate, if possible, how and whe.n
the accepted recommendations will be implemented.

     A followup system is needed to insure that agencies use
committees properly and effectively.  OMB and the agencies
should jointly develop such a system.  We have pointed out
this need in several prior reports (RED-76-33, Dec. 4, 1975,
and EMD-76-5, Aug. 2, 1976).

                            CHAPTER 4



      An important purpose of the Federal Advisory Committee
Act was to provide a mechanism   or controlling the number of
advisory committees and insuring that only committees with
well-, fined, necessary functions were allowed to exist.
However, OMB has provided only limited guidance as to what
attributes of a committee warrant its continuation and what
criteria to use in evaluating these attributes.   As a result,
reither OMB nor the agencies have systematically applied ob-
jective criteria to help evaluate a committee's usefulness.
Therefore, OMB and the agencies need to imorove the sub-
stance, uniformity, and effectiveness of the evaluation

     The act directs OMB and the aencies to    rescribe ad-
ministrative guidelines and management controls for commit-
tees, so that committee management will be governed by uni-
form standards and procedures.   Fven thouoh OMB has issued
standards and procedures, it has failed to nrovide the
leadership and  uidance necessary to insure implementation.
Also, the guidelines for the five agencies we reviewed are
too vaoue to help official:' properly administer and evaluate
committee activities.

      OMB and the agencies need to clarify what types of com-
mittees are covered by the act.   Agencies are unsure of the
status of sbgrouos and ad hoc groups.    As a result, Federal
agencies differ as to what   rouos they classify as commit-

     Committee charters should specifically state the com-
mittees' missions and the amount of time needed to accomplish
their missions.  However, an imprecise time schedule for
grant and  roposal review committees is understandable be-
cause of their continuing function.  But this does not mean
that they should be considered nermanent.

     The methods used to cetermine committee costs are not
consistent.  A  a result,  he costs reported bv the aaencies
are incomplete and not comparable.  Also, OMB auidelin.e are
silent on whether to include committees' administrative  ver-
head as Dart of the costs.  Excludina overhead results in a
substantial cost understatement at large agencies.

       The term "reoort" needs to be better defined.  OMB's
and   the agencies' lack of a standard definition results in

inconsistent and misleading figures being reported in both
the President's annul report and OMB's comprehensive re-
view.  Additionally, OMB and the agencies have failed to
establish an effective followup and feedback system for com-
mittee recommendations and reports.  Such a system is essen-
tial to evaluating committee usefulness and need.


     We recommend that the Director, OMB, in addition to
using the evaluaeion factors outlined in Circular A-63,
develop objective criteria, revis- and   Vearify OMB guide-
lines, and help Federal agencies formulate their own guide-

     More specifically, OMB should:

     -- Develop stringent, uniform guidelines on both sub-
        groups and ad hoc groups, emphasizing that such groups
        should not be used to circumvent the act, unwittingly
        or otherwise.

     -- Require that agency committee chatters (1) be clear
        and specific in stating their purposes and objectives
        and (2) include a specific timespan for a committee to
        accomplish its purpose.

     -- Issue more detailed guidelines to insure that cost
        estimates are consistent Government-wide.  Also, re-
        quite the arci s to submit committee administrative
       overhead   costs--in   lump sum figures--with   the   ager-
       cies'   annual report submissions.

     -- Work with the agencies in developing a standard defi-
        nition of "report" to be used and enforced by all Fed-
        eral agencies.  Also, jointly develop   monitoring and
        evaluation system to follow up on committee reports
        and recommendations.

                          CHAPTER 5

                     AGENCY COMMENTS AND

                       OUR EVALUATIONS

      The Office of Management and Budget, by letter dated
October 11, 1976, stated it generally agrees with the pur-
poses of   ur recommendations.  (See app. IV.)  Specifically,
it agreed with the concept that objective criteria be used to
evaluate the usefulness of committees.   It also agreed with
the need for better definitions and uniformity among agen-
cies.   However, it said that it has already begun changing
its guidelines and anticipates that these changes will in-
clude definitions of ad hoc groups, subgroups, reports, ap-
plicable costs, and other problem terms to help insure more
uniformity among agencies.

     OMB acknowledges that committee recommendations are an
important factor in evaluating a committee's activity.  How-
ever, it questions whether the possible improvements in com-
mittee management, gained by following up on committee recom-
mendations, would be outweighed by the administrative burden
and costs such additional requirements impose.  nMB said that
it is reluctant to add to the committee management cost or   to
the already substantial amount    of paperwork.

     We agree that such a followup system would require addi-
tional resources; however, it would also provide valuable in-
formation as to the usefulness of committees.

     OMB, in a letter dated January 18, 1977 (see app. V),
provided additional comments on our report.   It said it gen-
erally agrees with the purposes of the report's recommenda-
tions and, where appropriate, is taking actions to meet those
purposes.  OMB specifically agrees to the need for improved
guidelines for reporting costs of committees.   In this re-
gard, it provided costing guidelines to agency committee man-
agement officers on December 17, 1976.  We have reviewed
these revised procedures and, if properly adhered to by the
agencies, they should go far in correcting the cost reporting
problems we identified.  However, in its guidelines, OMB ac-
knowledged that it was probaoly too late for these guidelines
to be implemented in time to affect the costs reported for
the 1976 annual report on committee activity.

     The Department of the Interior, in its letter dated
September 30, 1976 (seE app. VI), agreed with our
recommendations orn the need to clarify the status of subgroups
and ad hoc groups, to   evelop a consistent method of deter-
mining costs, and to   efine "report."  The Department agreed

that these matters have Government-wide significance and need
uniform standards.

     The Department's main concern was over our emphasis on
developing objective criteria to assure that useless commit-
tees are identified.  It believed that if objective criteria
were developed, they should be applied cautiously.

     We agree.   In chapter 2 we identified several indicators
to be used as a basis for consistent, systematic, and objec-
tive evaluation.   However, we stated that these indicators by
themselves do not present a total picture of a committee's
worth.  They are not the ultimate answer; they are only a
mechanism to "flag" those committees which seem suspect.

     The Department also expressed concern over institu ing
a formal followup system for committee recommendations, be-
cause it would require additional resources and the results
would be highly questionable.  It stated that the real issue
is not tracking committee recommendations, but rather deter-
mining whether the recommendations have been heard by those
making the decisions or operating the program.

     We agree that such a system would require additional
resources; however, it would also provide valuable informa-
tion on committees.  We believe that a followup system would
insure that a committee's advice is being heard.  Also, page
16 of the report explains that we are concerned with more
than just the mere transmission of formal advice. We are in-
terested in who makes the recommendations, who receives them,
and how they affect the agencies' programs.

     The National Science Foundation, by letter dated Septem-
ber 30, 1976 (see app. VII), generally agreed with our find-
ings, conclusions, and recommendations.  It realized that
better guidelines and definitions were needed from OMB in
order to maintain uniform operations and improve committees'
performance.  The agency believed that adoption of our recom-
mendations would greatly benefit the entire committee progra .

     NSF agreed to the need for more detailed guidelines to
insure consistent cost estimates.   However, it thought that
staff and budgeting support should not be used as a sole cri-
terion for measuring committee value.   As we said on page 12,
our indicators are not all-inclusive and cannot by themselves
determine a committee's value.  But since agencies must de-
termine why costs are high or low and whether a committee
is cost-effective, they can use staff and budgeting support
as a factor in such a determination.

     While NSF saw the need for a standard report definition,
it believed that measuring the usefulness of committees by
the number of resorts generated overlooks the different com-
mittee functions.  For instance, proposal review panels do
not generate reports; they review proposals.   On page 16 we
said a report definition should be made flexible enough to
accommodate different committee functions.   For example, the
review panels' output is the proposals rev. ewed, and the
agency could summarize and explain the reviews' results and
combine them into a committee report.

     NSF did not agree that proposal review panels require a
written followup system for their recommendations.   However,
it agreed tnat, for other committees, written feedback should
be provided to advisory group members; it plans to develop
such a system.  NSF indicated that panel recommendations
weigh heavily in the final action taken and that, usually,
panel members are informed of the final action.   We believe
the panels should be allowed to formally comment on the
final agency action.   Additionally, this written feedback
would allow the Congress, OMB, and the public to find out
what the committees have done, and what impact they have on
the agency's programs.

      The Department of Commerce, by letter dated September 27,
1976 (see app. VIII), stated it generally agreed with the
need for more detailed guidelines for committee management--
especially guidelines which would (1) insure that cost esti-
mnates are consistent Government-wide, (2) add committee ad-
ministrative overhead costs to the annual report submission,
(3) define the term report as issued in the act, and (4) de-
velop a monitoring and evaluating system to provide followup
and feedback on committee reports and recommendations.   The
Department stated that this latter factor would require addi-
tional resources.   We, of course, agree.

     The Department agreed that there should be objective
criteria to evaluate committees.  It stated that it has   re-
scribed such criteria.  Its guidelines, however, merely re-
state the evaluation factors included in OMB's Circular A-63.
The Department's committee evaluation consists of answering
OMB's questions without systematically and thoroughly analyz-
ing the need for and accomplishments of a committee.

     The Department of Health, Education, and Welfare, by
letter dated November 30, 1976 (see app. IXi, stated that it
will follow up on the various points noted in our report.
HEW stated our report has stimulated improvemerts in costing
procedures.  Costing procedures have been drafted and are
now  eing shared with OMB and other agencies.

     HEW, however, believes that our conclusion that present
evaluation procedures do not insure identification of un-
needed committees is essentially unsubstantiated.  Also, HFW
stated that the report gives little evidence that unnecessary
committees exist, and what evidence is given is speculative
and based on indications developed by us. We believe that
the examples on page 10, the figures provided under the de-
scription of each indicator, and appendixes II and III pro-
vide ample evidence that the present evaluation procedures
need improvement.  Additionally, the indicators are based on
the information the agencies are supposed to use and provi'e
to OMB during the comprehensive review. The indicators
merely use the information available to uantitatively eval-
uate overall committee activities, something HEW has not done
so far.
     HEW stated that we do not mention the extensive review
of committee charter proposals that is performed at various
levels of review within its agencies, prior to submission to
OMB. We recognize that at HEW, because of its multitude of
agencies and highly structured system, each charter must go
through many levels of review. However, we found no evidence
that, once the originating agencies approved a committee
charter, any critical review was done at higher levels.
     HEW believes that it would be burdensome and unnecessary
to provide extensive justification for every peer review
group, when the necessity and effectiveness of the whole eer
review system has been adequately documented. The thrust of
this report was not to evaluate the necessity or effective-
ness of the eer review system, so we will not criticize or
defend it. However, we believe that every committee, includ-
ing peer review groups, must submit adeauate justification of
its value and need. The sketchy justifications that have
been provided do not allow MB to perform an adequate compre-
hensive review.
     HEW doubted that Circular A-63 could be amended to pro-
vide specific committee management guidelines which would
apply to all Government agencies. We disagree, because (1)
Circular A-63 already has management guidelines applicable
Government-wide, (2) the guidelines we suggested (see p. 31)
merely refine Circular A-63, (3) OMB, with the cognizance of
the other four agencies reviewed, has already begun to amend
Circular A-63, and (4) we believe a major intention of the
act was to provide just such uniform guidelines. Further,
the President's annual report to the Congress is meaningless
unless all the agencies provide consistent and comparable in-
formation by following the same specific guidelines.

     HEW had the   following comments about the   indicators:

     "* * *The number of meetings a committee has had
     is not much use as an indicator of need, without
     knowing when the committee was established, pur-
     pose of the committee, and other like factors.

     "* * *While the provision of negligible or no
     staff support might lead one to raise auestions
     about a committee, in other cases data on staff
     costs would provide no useful information for
     assessing the need for a committee.

     "* * *The life of a committee can only be measured
     in terms of proqram needs; therefore, to allot a
     specific number of years for the life-span of a
     committee would serve no useful purpose.  FACA al-
     ready requires the renewal or rechartering of ad-
     visory committees every two years, and calls for
     the filing of charters at that time with the two
     Congressional committees.

     "* * *The distinction between who initiates a re-
     commendation--the agency or the committee--is in
     our opinion, meaningless.   Similarily [sic], we
     do believe it would be inappropriate to use the
     number of reports and recommendations from a com-
     mittee as a guide to its usefulness.  * * *"

     Again, we stress that the indicators are only a guide to
committee evaluation; they are not a "be all, end all---

     HEW agrees with our recommendation to seek alternatives
to advisory committees, but not where individual initial
(peer) review groups and le 4slatively  established national
advisory councils are concerned, because tne peer review sys-
tem has been established and approved by the Congress with
full consideration of the alternatives.   But even for peer
review committees, we are suggesting that HEW consider alter-
natives, and, if none are found, then a committee could be
instituted or continued when needed.

     HEW agrees that administrative costs relatinq to the
operation of particular committees should be reported by com-
mittees, but that an agency's administrative/management costs
to meet procedural and paperwork requirements should not be
so reported.  However, without all staff support costs, the
Congress does not have a true measure of committee program

     HEW felt that a "report" may not be an accurate measure
of effectiveness of certain committees, such as grant review

committees.  Again, we indicated that a report definition
should be made flexible enough to accommodate the different
types of committee functions.

     HEW believes that it is unlikely that our recommended
followup system would meet the needs of different types of
committees and, further, that it would greatly increase
costs and paperwork.  We believe that a followup system
flexible enough to meet the peculiarities of each type of
committee could be set up.  We agree that additional costs
and paperwork may be incurred with such a system.

                          CHAPTER 6

                       SCOPE OF REVIEW

     To determine how effectively th~ Office of Management
and Budget and the agencies were carrying out their respon-
sibilities under the act, we evaluated OMB's and the agen-
cies' criteria and procedures for establishing, continuing,
or abolishing advisory committees.

     We analyzed records and interviewed agency officials at
OMB; the Department of Health, Education, and Welfare- the
Department of the Interior; the Department of Commerce; the
National Science Foundation; and the Environmental Protection
Agency.  We did our work at the agency offices in the Wash-
ington, D.C., area between February and July 1976.

     Additionally, we developed statistical information on
all advisory committees for calendar years 1974 and 1975.

APPENDIX I                                          APPENDIX   I

                              COMMISSIONS IN THE FEDERAL

             The Federal Government often uses special
             study commissions to examine problems or
             issues of national concern and to recommend
             action by the executive branch and the
             In spite of the extensive study efforts and
             expenditure of large amounts of money, bene-
             fits expected from some of these studies are
             not being achieved because their recommenda-
             tions are not being acted upon by the
             responsible Federal agencies.
             This condition has been largely attributable
             to the absence of an effective followup sys-
             tem under which the executive branch would
             promptly take a position on the merits of
             commission recommendations and develop and
             execute a plan for adopting those which merit
             action. Also, because study reports sometimes
             take positions whi3h members of the appropriate
             congressional committees do not find readily
             acceptable, they do not always receive strong
             backing and interest in the Congress.

             GAO recognizes that not all study commission
             recommendations merit implementation but be-
             lieves such studies call for careful executive
             and legislative branch consideration.

             GAO recommends that the Office of Management
             and Budget provide the necessary leadership
             in the executive branch to establish effective
             followup systems on study commission recommen-
             dations. (See p. 29.)

             GAO also recommends that the Congress consider
             the following actions:
                  -- Legislation creating future study
                     commissions specify as clearly as
                     possible a commission's study objec-
                     tives and an action program by the

                                 39                    RED-76-33
APPENDIX I                                           APPENDIX I

              executive branch to evaluate recom-
              mendations and carry out those
              meriting implementation.

             -- The Federal Advisory Committee
                Act be strengthened by reouiring
                that the executive branch period-
                ically report to the Congress on
                the status of action taken. This
                would be similar to the require-
                ment in the December 1974 act
                creating the Commission on Federal

             --The appropriate House and Senate
               committees having jurisdiction in
               the area covered by a study com-
               mission hold hearings about the
               commission's findings and recom-
               mendations to provide oversight
               over the executive branch action
               program and development of neces-
               sary legislative changes.
               (See p. 29.)
      GAO discusses two important study reports
      issued during the last 5 years which did not
      receive adequate consideration. These reports
      were issued by the Public Land Law Review
      Commission in June 1970 and by the National
      Water Commission in June 1973.   (See chapters
      2 and 3.)

      Other similar examples, cited in this report,
      are the report by the National Commission or
      Urban Problems issued December 12, 1968, and
      the report by the National Commission on
      Materials Policy issued Ju~ne 27, 1973.
      (See pp. 14 and 16.)
      By contrast, effective procedures have been
      instituted to evaluate and implement the recom-
      mendations in the December 1972 report by the
      Commission on Government Procurement. A
      satisfactory followup system evolved with
      participation by both the legislative and the
      executive branch and GAO performing a monitor-
      ing role. This system could well serve as a
      model for taking action on similar future
      studies.  (See p. 18.)

APPENDIX I                                        APPENDIX I

        The Office of Management and Budget
        concurs with this report's purpose and
        goal and the need for increased efforts
        by all branches and levels of govern-
        ment to consider study commission
        recommendations. The Office, however,
        does not agree with GAO's recommenda-
        tions for new legislation to require
        more formal followup systems.
        (See p. 32.)
        The Department of the Interior also agrees
        with the general thrust of the report and
        recommendations but cautions that study
        commissions are only advisory and the
        merits of their recommendations should
        not be presumed. The Department claims
        it has made use of appropriate commission
        recommendations although such actions may
        not have been documented in the manner
        contemplated by GAO.  (See p. 36.)

APPENDIX                 II                                                                                                                                                                                                   APPENDIX   II

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Sections throughout these appendixes marked "deleted"
refer to material, contained in our draft report,
which has been revised or which has not been included
in the final report.

Also, page references throughout these appendixes
refer to our draft report and may not correspond to
this final report.

APPENDIX IV                                                            APPENDIX   IV

         -..   i~   X     OFFICE OF MANAGEMENT AND BUDGET
                                WASHINGTON.   D.C   2050

                                                            OCT 11   1976

      Mr. Victor L. Lowe
      Director, General Government Division
      U.S. General Accounting Office
      Washington, D. C.  20548

      Dear Mr. Lowe:

      We have reviewed the draft report "Evaluations of the Useful-
      ness of Federal Advisory Committees Need Improvement," con-
      cerning the administration of the Federal Advisory Committee
      Act (FACA;.

      The FACA, as you know, is one of a number of statutes enacted
      during the past few years on the subject of "openness in qov-
      ernment," and one which has required complex and rapidly-
      changing management procedures and guidelines to carry out.
      This complexity, and the diversity inherent when more than
      sixty Executive branch departments and agencies have more
      than 1,200 advisory bodies of different types and with dif-
      fering functions, necessitates the cooperation of all branches
      of government if the purposes of the Act are to be met.   The
      draft report, by calling our attention to some present short-
      comings in the management of committees, and by making useful
      recommendations, is a welcome example of such cooperation.

      We are in general agreement with the purposes of the recom-
      mendations stated in the chapter "Conclusions and Recommenda-
      tions."  Specifically, we agree with the concept that objectivt
      criteria be utilized in evaluating the usefulness of advisory
      committees.  In fact, OMB's Circular No. A-63, Advisory Com-
      mittee Management, and procedures related to the annual com-
      prehensive review and committee renewal do now require use of
      most of the criteria suggested by GAO.  As we continue to
      evaluate the results of the annual comprehensive review, we
      will also consider ways in which these criteria, or others,
      might be used -- or guidelines for their use might be improved
      -- to provide a better basis for determining the usefulness of
      advisory committees.

      The draft report recommends quantitative and qualitative agency
      evaluations of recommendations made by advisory committees.
      Certainly, commnittee recommendations are an important factor
      in any evaluation of a committee's activity.   However, as I

APPENDIX   IV                                                    APPEN)IX   IV

       indicated in my testimony before the Subcommittee on Reports,
       Accounting, and Management of the Senate Committee on Govern-
       ment Operations, on March 8, 1976, and elsewhere, "I am
       troubled by his apparent emphasis on the gathering and report-
       ing of quant  ative information, without full consideration of
       whether the -;sible improvements in committee management
       sought . . .   e   o tweighed by the administrative burden and
       costs such additional requirements impose." The draft report
       suggests that committee management administrative costs may
       already be substantial. Without very careful study, and a
       thorough cost/benefit justification, I would be very reluctant
       to add any requirements, applicable to all of the many kinds
       of advisory committees, which might add to this cost burden
       or to the already substantial amount of paperwork.
      The need for better definitions, and uniform applications, has
      become apparent in a number of areas since the Act became
      effective in 1973, and since OMB's guidelines were issued in
      1974.  During this period, too, we have gained the experience
      and guidance (through Congressional hearings, court decisions,
      etc.) which will enable us to develop those definitions -- as
      the "informal" definition of subgroups, cited in the draft re-
      port, was developed. We have already begun work on revised and
      updated guidelines, and I anticipate that these will include
      definitions of ad hoc groups, subgroups, reports, applicable
      costs -- as well as a number of other problem terms -- and help
      ensure more uniform application.
      While we agree generally with the purposes of the recommenda-
      tions, we are concerned that the discussion in the draft trans-
      mitted by your letter of August 26, 1976, is too often based
      on incomplete information, arrives at unwarranted -- and always
      negative -- conclusions, and fails to recognize significant
      progress already made, or efforts underway, to accomplish the
      objectives of the Act. Our discussions with your staff were
      rather comprehensive and we anticipate that as a result these
      many difficulties will be rectified in your next draft. How-
      ever, the sheer number and detail of them effectively pre-
      cludes detailed comment here especially since we expect them
      to be resolved by your staff. We look forward to commenting
      more specifically to those problems which may still remain
      after your coming revision.

                                         Dncerely,      /

                                        6ames T. Lynn

APPENDIX        V                                                   APPENDIX V

       '                   OFFICE OF MANAGEMENT AND BUDGET
       '/                         WASHINGTON. D.C.   20503

                                                                JAN 18 1977

    Mr. Victor L. Lowe
    Director, General Government Division
    U. S. General Accounting Office
    Washington, D. C.  20548

    Dear Mr. Lowe:

    We have reviewed the revised draft of the report "Evaluations
    of the Usefulness of Federal Advisory Committee Need Improve-
    ment," concerning the administration of the Federal Advisory
    Committee Act (FACA). While substantial changes have been
    made in the draft on which I commented on October 11, 1976,
    the current draft still presents a distorted picture of OMB's
    role in the committee management process, and includes over-
    simplifications and unwarranted judgements. For example:

            -       The report sates that GAO has identified factors
                    to be used in evaluating advisory committees, but
                    that neither OMB nor the agencies have used these
                    factors to develop objective criteria.  In fact,
                                                              s those
                    OMB and the agencies do use factors such ..
                    cited, and only if it is meant that the factors
                    are not used as "objective criteria" (a term
                    neither defined nor explained) is the statement
                    even partially true.


    As I indicated, we are in general agreement with the purposes
    of the report's recommendations and where appropriate, taking
    actions to meet those purposes.  However, I regret that the
    report does not present a more accurate and more balanced --
    and therefore more useful -- contribution to addressing the
    complex problems of advisory committee management.

    Our detailed comments are attached.

                                                S' cerely?

                                                 ames T. Lynn


APPENDIX V                                                   APPENDIX V


          Draft Report "Evaluations of the Usefulness of
          Federal Advisory Committees Need Tmprovement"



page ii, para. 1     The sentence "OMB's Circular . . objective
                     criteria" is both incorrect and confusing.
                     It is not clear here, or elsewhere in the re-
                     port, what the differences are between "factors"
                     "objective criteria," or "evaluation indicators."
                     Clearly, a number of the factors in A-63 (number
                     of committee meetings, costs, etc.) are the same
                     as the evaluation indicators cited as identified
                     by GAO.  They are also used in the review of com-
                     mittees, as we have discussed with GAO staff,
                     hence the sentence is apparently incorrect. How-
                     ever, if "objective criteria" is meant to be some
                     sort of formula, employing these factors, which
                     could be applied to all committees to determine
                     their necessity, the report should so state.
                     Moreover, we would appreciate the assistance of
                     GAO in developing such a formula, if one is
                     feasible, applicable to all committees -- as we
                     requested in earlier staff discussions.

page ii, para.   3   We question the finding that OMB "has not been
                     providing the effective management and leader-
                     ship envisioned by . . ." FACA.   On the one hand,
                     the report does not describe what was envisioned
                     by FACA.  On the other, while we recognize that
                     there are unresolved issues, the statement seems
                     at variance with the sentiments expressed in the
                     Senate hearings last year on amendments to the


 APPENDIX   V                                              APPENDIX V


page iii, para. 2   The paragraph indicates that "substantial
                    committee program costs" are not included
                    in the Annual Report and, therefore, the
                    Report does "not present an accurate estimate
                    of advisory committee program costs to the
                    Federal Government."  We have gathered from
                    staff discussions that this refers to the
                    costs of overall committee management, not
                    the costs of individual committees.  We agree
                    that these are substantial, and are not in-
                    cluded in the Annual Report. However, as
                    we have pointed out to GAO staff, the cost
                    data in the Annual Report is that required
                    by Section 6(c) of FACA, and the lack of'
                    other data is not, therefore, a shortcoming
                    of the Annual Report.

page iii, para. 2   A subparagraph on page iv indicates that
                    neither OMB nor agency guidelines give a
                    definition of "report."   While, again, we
                    agree that there has been a lack of uniformity
                    of application, the GSA Standard Form 248,
                    prepared in conjunction with OMB, and used by
                    agencies to submit the information for the
                    Annual Report, does contain such a definition
                     (and indicates that "report" should not include
                    minutes of meetings).


APPENDIX V                                                  APPENDIX V




page 5, para. 1    The first sentence ("the process . .. or con-
                   tinued."), while presumably a summary of the
                   chapter, states as a fact, without qualification,
                   what is reallyonly a GAO opinion, i.e., that
                   the establishment, renewal, and annual review
                   processes do not ensure that only needed com-
                   mittees are established or continued. The state-
                   ment should be qualified.

page 5, para. 2    This paragraph implies that GAO identified
                   several "evaluation indicators," not hereto-
                   fore used, that would lead to a "more com-
                   prehensive and qualitative analysis of advisory
                   committee activities."  As we have indicated,
                   most of these factors were cited in OMB Circu-
                   lar No. A-63 (Transmittal Memorandum No. 3,
                   September 3, 1975), and were used by OMB and
                   the agencies in the annual comprehensive review
                   for calendar year 1975.

page 6, para. 2    This paragraph restates, with somewhat less
                   certainty, the introductory sentence of the
                   chapter (page 5, para. 1, see above).  More-
                   over, it is unclear whether it refers to, or
                   there are, one or multiple processes for es-
                   tablishing, evaluation, reviewing the need
                   for, or reducing the number of committees -
                   and which, if any or all - are deficient.

page 8, para. 1    The statement ". . . the four budget examiners
                       . devoted
                         .         . .   . from 3 staff-days . . . to
                   10 staff-days .. ." is highly misleading with-
                   out additional information concerning such
                   factors as the number of committees involved

APPENDIX V                                              APPENDIX V

                   in the agencies for which the examiners are
                   responsible, whether or not their committee
                   reviews had involved the full cycle
                   (establishment, renewal, annual review), etc.,
                   and should be qualified accordingly.


page 12, para. 5   The description of the annual comprehensive
                   review, beginning with this paragraph and
                   continuing on pages 13 and 14, reflects a

  APPENDIX V                                              APPENDIX V


                   basic failure to understand the annual com-
                   prehensive review as conducted for calendar
                   year 1975. As we have described it in numer-
                   ous conversations, the annual comprehensive
                   review (as required by Section,7(b) of FACA)
                   is an OMB responsibility. To meet this re-
                   sponsibility, OMB required (A-63, Transmittal
                   Memorandum No. 3) each agency head to review
                   each committee using the factors enumerated
                   in the Circular, and make a recommendation
                   concerning the merger, revision, continuation,
                   or termination of those committees. While
                   agency heads are encouraged to terminate com-
                   mittees, or take other appropriate actinis as
                   a result of their review, neither the    'A nor
                   OMB requires such actions.   The docum-n :,cf
                   the agencies' reviews then are submitce
                   OMB, combined with the data submitted       the
                   Annual Report of the President, and this
                   "package" is reviewed by both CMS and the
                   appropriate program divisions (using informa-
                   tion available from prior reviews, consulta-
                   tions, and "personal knowledge of the agency's
                   needs, 'its role, and the priority of programs
                   being implemented").   On the basis of this
                   latter review, recommendations are made to the
                   President and to either the agency head or the
                   Congress on actions believed necessary. A
                   final judgement of a new annual review pro-
                   cedure, based on observations of a part of the
                   process, in a limited number of agencies, is,
                   at best, premature.

page 14, para. 2   This paragraph initiates a discussion, con-
                   tinued on the following pages, where the terms
                   "criteria", "objective qualitative analysis,"
                   "guidelines," "objective evaluation criteria,"
                   evaluation indicators," and "factors," are
                   used interchangeably to mean both the same and
                   different things. A clear definition of each
                   term would improve understanding. Finally,
                   the last sentence alleges that OMB and agency
                   failures, enumerated in tne preceding sentences,
                   allowed certain committees (unspecified) to
                   exist which "violate" one or more evaluation
                   indicators established by GAO without adequate
                   justification. Without knowing what committees
                   are involved, which evaluation indicators, and
                   what justification was reviewed (by whom, and
                   on what basis), tne statement is unwarranted.

APPENDIX V                                              APPENDIX V


page 14, para. 3   The last sentence indicates that FACA is
                   "not specific as to the criteria
                   to be used by OMB and the agencies. Lacking
                   either an indication of how much specificity
                   is necessary in GAO's opinion, or GAO's defi-
                   nition of "criteria", we would point out that
                   Sections 2(b), 5(b), and 9(a)(2) of the Federal
                   Advisory Committee Act do provide guidance on
                   the basis for establishing or continuing ad-
                   visory committees.

page 16, para. 2   Four examples are cited to demonstrate the need
                   for an evaluation system as prescribed by the

                   Example 1 - As stated, the panel was established
                   in 1973, and did not meet in 1974 or 1975.   That
                   fact was noted in the annual review (by the
                   agency, CMS, and OMB's program division) and
                   explained:  ". . . the time delay was partly
                   due to reorganizations taking place in the . .
                   Division which required some adjustments in
                   the technical background of panel members."
                   On the basis of discussions with the agency
                   concerning the uses to which the panel would
                   be put, and assuring the agency that the panel
                   would be thoroughly reviewed again in the next
                   renewal period, OMB agreed with the agency recom-
                   mendation to continue the panel.

                   Example 2 - This Presidential advisory committee
                   did not meet or take any actions, as GAO has
                   reported.  This inactivity was noted, however,
                   by both he responsible agency and OMB, and
                   proposals were made to revitalize the committee
                   to carry out its original purposes. When these
                   were unsuccessful, the committee was terminated.

                   Example 3 - This committee was established by
                   the Congress in 1972, hut its charter was not
                   filed (it could neither meet nor take action),
                   nor members appointed, pending disestablish-
                   ment of an Executive branch agency with over-
                   lapping functions, until 1975. This was noted
                   in the annual comprehensive review by both the
                   agency and OMB, and the committee was continued
                    (since it is now fully constituted) to carry
                   out the purposes for which it was established.

APPENDIX V                                               APPENDIX V


                   Example 4 - Cites two committees, both es-
                   tablished by the Congress before enactment
                   of the Federal Advisory Committee Act, which
                   have been inactive.  In both cases, the lack
                   of meetings, etc., was noted by both the re-
                   sponsible agencies and OMB. In one case,
                   both the agency and OMB have recommended that
                   the committee be terminated (Congressional
                   action is required); in the other, a review
                   of the reasons for the lack of meetings, and
                   the functions to be performed, led the agency
                   to recommend that the committee be continued,
                   and OMB agreed.

                   Of the five committees cited as examples, only
                   one could have been terminated by unilateral
                   agency action (three required Congressional
                   action, one Presidential).  Despite this, in
                   each instance during the nnual comprehensive
                   review, the agencies and OMB did question the
                   committees' inactivity (a factor that the report
                   alleges is not used), and explain it and take
                   appropriate actions   Rather than indicating
                   a need for a different process, the examples
                   appear to illustrate that present procedures
                   do provide for a meaningful evaluation of

page 17, para. 2   The second sentence indicates that data is
                   available (on committee meetings, costs, etc.)
                   but is not used by OMB or the agencies. As we
                   have indicated, the data is used and, we believe,
                   both "systematically and effectively" to evaluate
                   committees.  However, if the report's allegation
                   is dependent upon the use of the data as an
                   "objective criteria" (applicable to each of
                   over 1,200 committees), then that term ought
                   to be explained and defined.

pages 17--25       These pages discuss the proposed "evaluation
                   indicators" (meetings, costs, age, etc.),
                   primarily in agency-wide terms:  For example,
                   an agency has 57 committees, of which 10 had
                   no meetings, 11 had one, and 36 had more than
                   one.  While such statistics have some super-
                   ficial appeal, they provide little real infor-
                   mation about committee activities (of the
                   committees with few or no meetings during a

  APPENDIX V                                                APPENDIX V


                       given year, how many were newly established t
                       the end of the year, or how many of those were
                       terminated during the year, etc.).  More i-
                       portantly, it is implicit in FACA that com-
                       mittees be reviewed on an individual basis,
                       annually, and at the time of establishment or
                       renewal -- and it is this principle n upon
                       which OMB and agency procedures are based,
                       using all information available. In our
                       judgement these procedures, though subject
                       to further refinement, do provide for the
                       systematic and consistent assessment of the
                       need for, and usefulness of, individual advi-
                       sory committees.



 page 29, para. 1&3   In each of these paragraphs the report cites
                      instances concerning the use of consult.nts,
                      and each pragraph ends with speculation that
                      such practices might be used to circumvent the
                      letter or intent of the Act.  Any number of
                      practices might be used to circumvent the Act;
                      without some evidence (none is provided bf the
                      report) that such is the case, this peculation
                      is wholely unwarranted.

 page 37              As we have indicated to GAO staff, we agree
                      that there is a need for improved guidelines
                      for the reporting of costs of advisory com-
                      mittees.  As you may know, agency committee
                      management officers were given guidelines for
                      the costs of advisory committees, by OMB, on
                      December 17, 1976.



 page 40              As noted earlier, while there may be a lack
                      of uniformity of application, the GSA Stand-
                      ard Form 248, used by agencies to submit in-
                      formation for the Annual Report of the Presi-
                      dent, does include a definition of "report."

APPENDIX VI                                                          APPENDIX VI

         ·   f        United States Department of the Interior
                                  OFFICE ()1 TlE SEC:RETAkY
                                   WASHINGIO(N, D . 20240

                                     SEP 30 1976

         Mr. Henry Eschwege
         Director, Community and Economic
           Development Division
         U. S. General Accounting Office
         Washington, D. C. 20548

         Dear Mr. Eschwege:

         We appreciate the opportunity to comment on the draft report entitled
         "Evaluations of the Usefulness of Federal Advisory Committees Need

        Our immediate reaction is one of concern at the suggested application
        of sweeping generalizations with regard to advisory committees. We
        question whether universal standards can be imposed on a program having
        such a diversity of 'functions.

        The function of an advisory committee often extends well beyond the
        narrow role oi rendering formal advice, into the wide realm of the
        desirable interaction created between Government and the private
        sector in the public involvement process. While this is a somewhat
        intangible factor, it is a most important one in determining the
        usefulness of an advisory committee.

        Specifically, we offer the following comments with respect to certain
        report items:

                 1.    Evaluation indicators.

                     The report places strong emphasis on the development of
                 "objective criteria" as the method of assuring that advisory
                 committees not serving a useful purpose are identified. It
                 suggests that committees with no meetings should be questioned
                 as to their usefulness, that limited budget and staff support
                 could indicate a lack of agency commitment to the committee's
                 activities, that extremely old committees should be suspect
                 as to their continued usefulness and that if a committee makes
                 no reports or recommendations, it should be considered suspect.

                     We have, in this Department, committees which would meet
                 all of the suggested criteria and some which would fail to meet
  4OcIUTo~       most or all. There would be, however, little distinction in
        e5i      the value and effectiveness of any of these committees.

APPENDIX VI                                                        APPENDIX VI

           Accordingly, if there is to be development of "objective
       criteria," we believe they should be applied cautiously. Such
       criteria should not become a mechanistic test by which the
       future status of committees will be determined. Significant
       demonstrable benefits not meeting quantifiable "objective
       criteria" is and should continue to be the overriding
       consideration for many committees.

       2.   Clarification of certain definitions and procedures.

           The report -ecommends clarification of the status of sub-
       groups and a,hc committees, a consistent method of determining
       costs and te d fining of what constitutes a "report."

           For reporting purposes, these matters have Governaent-wide
       significance, and we concur in the need for uniform standards.

           It is our understanding that these issues will be addressed
       in forthcoming revised guidelines from the Office of Management
       and Budget.

       3. Followup system for reports and recommendations.

           The report stresses the need for an effective system to
       monitor advisory committee recommendations. Again, the
       emphasis placed on that function indicates clearly that no
       cognizance is taken of the important functions performed by
       advisory bodies beyond the mere transmission of formal advice.
       Even if such a followup system were mandated as to the formal
       advice rendered by a committee a most ponderous clerical
       procedure would be required, paperwork and staff cost would
       be increased considerably and the results would be highly

           As stated by Deputy Assistant Secretary Richard h. Hite
       before the Senate Subcommittee on Reports, Accounting and
       Management on March 10, 1975:

            "The nature of the Interior Department and its
            advisory committees is such that recommendations
            from the committees cannot always be tracked in
            "score-card" fashion. In any decision by the
            Department a multitude of views are presented and
            it is rare that a decision can be said to have
            adopted or rejected an advisory committee's recom-
            mendation. Furthermore, there may be a period of
            years which intervenes between the initial advice
            or recommendation and a final decision to pursue
            a course of action. During this period, the
            initial advice, more than likely, tends to lose
            any recognizabli identity.

APPENDIX   VI                                                    APPENDIX VI

            "The questinn of how many recommendations are
            acted upon affirmatively is not necessarily
            indicative of the effectiveness of an advisory
            cornittee program. The real issue is whether
                 c the advice rendered has been heard by
                  making the decisions or operating the

  We would be pleased to discuss in detail any of the specifics contained
  in the report.

                                   Sincerely yours,

                                   Albert C. Zapan
                                   Assistant Secretary for
                                     Administration and Management

APPENDIX VII                                                  APPENDIX VII

                       NATIONAL SCIENCE          FOUNDATION
                            WASHINGTON.   D.C.    20550


       DIRECTOR                                      September 30, 1976
Mr. Gregory J. Ahart
Director, Human Resources Division
U.S. General Accounting Office
Washington, D.C. 20548

Dear Mr. Ahart:

This is in response to your letter of August 27 requesting
comments on the GAO report entitled "Evaluation of the Use-
fulness of Federal Advisory Committees Need Improvement."

Our comments of the draft report consist of some general
observations concerning the report's conclusions and certain
specific comments concerning items pertaining to NSF.

Overall, we agree with 'the findings, conclusions, and recom-
mendations of the draft report. We realize the need for
better guidelines and definitions from OMB in order to
maintain uniform operations and improve the performance
of advisory committees.   We believe if GAO's recommendations
are adopted, they will greatly benefit the entire Federal
advisory committee program.

One observation though is that GAO failed to indicate that
any of the five agencies had a workable committee management
program.  I personally believe that the Foundation's program
has been quite  effective, considering the relatively brief
period of time since the enactment of the Federal Advisory
Committee Act and the small number of people who have been
involved with the management of the program in NSF and OMB.
The OMB Coammittee Management Secretariat has been a tremendous
help to this agency and I believe the present staff should
be given more credit for what they have accomplished in
the past year than was indicated in your report.

Our major comment on this report is that, while the GAO team
recognizes that there are se/eral types of advisory committees
(page 27) it does not take this factor into consideration in
its criticisms and recommendation.  The management of advisory
committees will not be improved by refusing to recognize these
differences and instituting across-the-board procedures.

Our comments on the specific sections of the report are con-
tained in the following paragraphs:

APPENDIX VII                                        APPENDIX VII


3.   Page 41,   2 - Staff support costs

We agree that we need more detailed guidelines to insure
consistency on cost estimates of all Federal advisory com-
mittees.   However, with regard to criteria to be used for
determining a committees value, we would like to point
out that negligible staff and budgeting support cannot
be used as a sole criterion for measuring value.   An effort
must be made to determire why costs are low.   In the case of
proposal review panels, costs are low because there are no
specific program staff costs associated only with the grant
review panel operation.   Also, many of our consultants receive
no compensation for the many hours they spend reviewing proposals
prior to attending the formally convened panel meeting.    None-
theless, their advice is essential.   In fact, the NAS Committee
Report, "Social and Behavioral Science Programs in NSF,"
recommended: "Panels should be created for all programs now
lacking them and should be used regularly by all programs."
The use of these panels has been proven cost-effective.
Comparable panel expertise could not be obtained by any other
means, for the amount presently expended.

Another point is that any time budget and staff support
is used as a criterion, it guarantees that money and support
will be provided to a committee - whether or not it is needed -
just to keep it alive.  We don't believe that we should judge
a committee's value on the cost of its inputs.

4.   Page 43, 12 - Definition of report

While we see and very much need a standard definition of a
report, we feel that measuring the usefulness of all advisory
groups by the number of reports generated overlooks the
functions of the advisory group.  For instance, proposal review
panels do not generate report; they review proposals.

5.   Page 45 - Oral feedback

For proposal review panels, we do not believe requiring a
follow-up system is germane.  The grant review panel provides
a recommendation on each proposal.  This recommendation is
taken into account and weighed heavily by at least four levels
of review and is reflected in the final action taken. Usually,
panel members are informed of final action.

APPENDIX VII                                          APPENDIX VII

In other cases, we agree that writter feedback should be provided
to the advisory group members and plan to have the programs
develop a system.  However, we do not believe this function
belongs entirely with our Committee Manage'ent Officer or
with OMB.  Neither office have the staff o expertise to
follow-up on committee recommendations.

We are attempting to improve our committee management operations
and are considering having our advisory group members fill out
an annual questionnaire to determine their 'subjective' evaluation
of the usefulness of the committee.

We appreciate the opportunity to comment on the GAO draft
report and trust that the foregoing comments will be useful.
We will be pleased to discuss this matter in more detail at
a mutually agreeable time.

                           Sincerely yours,

                                     .   Ar       '
                           Richard C. Atkinson
                             Acting Director

APPENDIX VIII                                                     APPENDIX      VIII

                                      UNITED STATES DEPARTMENT OF COMMERCE
                                      The Assistant Searetary for Adminiltration
                           V~'4r      Washington, 0 C. 20230

    SEP 27 1976

 Mr. Henry Eschwege, Director
 Community and Economic Development
 U.S. General Accounting Office
 Washington, D.C. 20548

 Dear Mr. Eschwege:

 This is in response to your letter to the Secretary, dated August 26, 1976,
 inviting comments on GAO's draft report entitled "Evaluations of the Use-
 fulness of Federal Advisory Committees Need Improvement."

 Generally, we are in agreement with the recommendations regarding the need
 for more detailed guidelines in certain aspects of advisory committee manage-
 ment, especially instructions which would:   (1) insure that cost estimates
 are consistent Governmentwide; (2) add committee administrative overhead costs
 to the annual report submission; (3) define the term "reports" as used in the
 Federal Advisory Committee Act; and (4) develop a monitoring and evaluation
 system to provide follow up and feedback on committee reports and recommenda-
 tions. This fourth factor would, of course, require additional resources,
 and we suggest that GAO address this point in its final report.

 In our concurrent consideration of the draft and its references to this Depart-
 ment as cited in the listing you provided, we noted several points which
 warrant individual comment. These are set forth in the enclosure, arranged
 according to the sequence of the reference list.

 Commerce is totally committed to the "openness in government" concept from
 which the Fedeial Advisory Committee Act derives. Within the past year, a
 new staff level division was established to emphasize this commitment and to
 provide policy and guidance in implementation of the referenced Act, the
 Freedom of Information Act, as amended, the Privacy Act of 1974, and the
 Federal Reports Act. Accordingly, we appreciate this opportunity to comment
 on the results of your survey prior to its final release.


        s nt
           Secret   y f


APPENDIX VIII                                                   APPENDIX VIII

                           U.S. DEPARTMENT OF COMMERCE

                      Comments re Selected Provisions of the
                               GAO Report Entitled:
                    "Evaluations of the Usefulness of Federal
                             Advisory Committees Need

     1. Pages 16 and 17 are premised on an assertion that OMB and agency
     officials have not developed objective criteria to help evaluate a
     committee's usefulness to determine whether a committee should be
     continued or abolished, and four examples of criteria for such an
     evaluation are set forth in the report's prefatory digest.

        While we agree with the need for such criteria, this broad assertion
    fails tc recognize the renewal evaluation instructions Commerce officially
    prescribed a/ two years ago, requiring (among other things):

         "A summary of the committee's accomplishments and activity since
          the date of its extant charter, to include number of meetings
          held, reports issued, advice or recommendations rendered, and
          annual cost of operation." b/

                                  [Del      ted

    a/U.S. Department of Commerce Committee Management Handbook, November 1,
      1974 (the "Handbook" hereinafter).

    b/This requirement (Handbook, page 2-21) specifically includes three of
      the four criteria which GAO lists as exemplary indicators, "age of a
      committee" being the sole omission.

APPENDIX VIII                                                    APPENDIX VIII

  5. Page 45 of the report also disparages agency oral feedback with respect
  to committee recommendations, a technique which is apparently used in
  connection with many Federal committees, including several Commerce bodies.
  This topic was discussed by GAO and Commerce staff, and the essence of tle
  Department's position is also presented in the letter transmitting this

      In brief, Commerce subscribes to the ideal of a formal procedural sys-
  tem for tracking every recommendation of a committee, following through on
  each one, and formally advising the members of the ultimate disposition of
  each, but such a system would require significant additional allocation of
  resources whJih will not be available in the foreseeable future. Given the
  resources currently available, we believe that our committees are being kept
  reasonably well-informed on the status of their recommendations.

  6. Other selected provisions of the report are recognized (and appreciated)
  as being complimentary of the Department's efforts. These include the
  requirement that any subcommittee having a member who is not on the parent
  committee must be separately chartered under the Act (page 31) and the
  Commerce position that internal administratively-required reports are not
  to be counted as committee reports of a productive nature (page 43).

APPENDIX   IX                                                  APPENDIX IX

                            OFFICE OF THE SECRETARY
                              WASHINGTON. D.C.   Wo01

                                    NOV 30 1976

     Mr. Gregory J. Ahart
     Director, Human Resources
     United States General
       Accounting Office
     Washington, D.C.  20548

     Dear Mr. Ahart:

     The Secretary asked that I respond to your letter of
     August 26 which asked for our comments on your draft
     report, "Evaluations of the Usefulness of Federal
     Advisory Committees Need Improvement." The enclosed
     comments represent the tentative position of the
     Department and are subject to reevaluation when the
     final version of this report is received.

     We appreciate the opportunity to meet with your staff,
     and to comment on this draft report before its publication.

                                         Sincerely yours,

                                         /Jo n D. JYouf4
                                         Aistant Secretary, Comptroller


APPENDIX IX                                                   APPENDIX IX

   Comments of the Department of Health, Education, and Welfare on the
   General Accounting Office Draft Report, "Evaluations f the Usefulness
   of Federal Advisory Committees Need Improvements"

   We strongly and sincerely believe in the principles of Federal Advisory
   Committee openness and accountability which have been established in law
   by the Federal Advisory Committee Act and applicable provisions of the
   Freedom of Information Act, Privacy Act, Government in the Sunshine Act,
   and various health, education and welfare statutes. It is in this
   spirit that the Department's comments, both the extensive oral pre-
   sentations already made and the written ones following are offered.
   The Congress has assigned this Department over 300 programs to carry out
   for the nation in the fields of health, education, and welfare, and we
   must get advice, in the open and accountable manner prescribed by these
   laws, from an interested public in order to discharge our responsi-
   bilities well. Under the Federal Advisory Committee Act, this consensus
   advice from outside Government must come from duly chartered Federal
   Advisory Committees, and the continuing establishment, management and
   termination of these committees is a function of major importance in the
   Department. Usually the more amorphous the program given us to carry
   out, the more useful the advice from an advisory committee.
   The Federal Advisory Committee system can provide not only advice to
   program leaders, but also a continuing analytical evaluation, from
   expertise outside the Government, of the fiscal and program impact of
   all manner of events and recommendations as they occur or are projected.
   We will follow up on the various points noted in the draft report. In
   fact, the section on estimated and actual costing procedures has already
   stimulated additional improvements in this aspect of our advisory
   committee management procedures, in that we are already sharing drafts
   of these projected improvements with OMB and other agencies which may
   find them beneficial.
   Comments on Specific Sections of the Report
   1. Report Chapter 2: "Present Evaluation Procedures Do Not Insure
   Identification of Unneeded Committees"
   We believe GAO's conclusion that present evaluation procedures do not
   insure identification of unneeded committees is essentially unsubstanti-
   ated. The report gives little evidence that unnecessary committees
   exist, and what evidence is given is speculative and based on indicators
   developed by the GAO.

APPENDIX   IX                                                  APPENDIX IX

 2. Report pages 6 to 9: "Establishment and Renewal Evaluation Pro-
 cedures Needs Improvement"
      a. This section should, but does not mention the extensive
      review of all charter proposals at various levels within the
      agencies prior to their submission to OMB.
      b. We do not believe it desirable to place the responsibility for
      evaluation of Federal advisory committees on the OMB. Each agency
      has a legal responsibility to ensure that its programs are being
      carried out in accordance with the intent of Conaress and the
      policies of the Administration. Without any doubt, agency responsi-
      bility extends to advisory committee activities.
 3.   Report pages 10 to 16:   "Comprehensive Review Has Not Been Effective"
      a.   Page 10, last paragraph.


           (2) Criticism is made by the GAO (pages 10 and 12) of sketchy
           justifications for review committees. It would be a burden-
           some and unnecessary exercise to provide extensive justi-
           fication for every peer review group, when the necessity and
           effectiveness of the whole peer review system-has been ade-
           quately documented.
      b. It should be stressed in this section that the mandate of FACA
      is not simply to reduce numbers of committees, but also to keep the
      number to that which is essential. Annual Comprehensive Reviews,
      designed in large part to reduce the number of committees, some-
      times also identify a need for additional committees.
      c. The GAO report implies in this section that the absence of
      detailed uniform advisory committee standards and procedures hich
      result in differing approaches among agencies is a detriment. This
      implication should be carefully examined. Certain general norms
      are needed and are already in place; FACA specifies certain standards,
      and OMB Circular A-63 further implements the provisions of FACA.
      While it may be desirable to amend Circular A-63 to clarify additional
      aspects or direct certain management practices, it is doubtful that
      discrete and specific guidelines could be devised which would be
      applicable to all government agencies.

APPENDIX   IX                                                  APPENDIX IX


  5.   Report pages 19 to 28:   "Proposed Evaluation Indicators"
  In our opinion there are problems and/or other considerations that
  should be noted with respect to indicators selected by GAO ". . . that
  can provide a good idea as to whether an advisory committee is useful,
  and whether it is serving its purpose":
       o Committee Meetings. The number of meetings a committee has had
       is not much use as an indicator of need, without knowing when the
       committee was established, purpose of the committee, and other like
       o Budget and Staff Support. While the provision of negligible or
       no staff support might lead one to raise questions about a committee,
       in other cases data on staff costs would provide no useful infor-
       mation for assessing the need for a committee.
       o Committee Age. The life of a committee can only be measured in
       terms of program needs; therefore, to allot a specific number of
       years for the life-span of a committee would serve no useful
       purpose. FACA already requires the renewal or rechartering of
       advisory committees every two years, and calls for the filing of
       charters at that time with the two Congressional committees.
       o Reoorts and Recommendations. Tl,e distinction between who
       infiThates a recommendation--the agency or the committee--is in our
       opinion, meaningless. Similarily, we do believe it would be
       inappropriate to use the number of reports and recommendations from
       a committee as a guide to its usefulness.

APPENDIX   IX                                                   APPENDIX     IX

       o Alte-rn'tives. On page 27 it is stated that the evaluation
       processsi,.i5TTnclude information as to what alternatives other
       than cmmitteas are available. We see no reason for having to
       spell out alternatives for individual initial (peer) review groups
       and legislatively-establtihed national advisory councils. The peer
       review system has been established and approved by Congress with
       full consideration for the alternatives. lo us, it is unreasonable
       to set an approximate date for fulfillment of a committee's purpose
       in the case of committees which perform ongoing functions relating
       to the operation of continuing programs.
       o Costing Procedures. The GAO report expresses concern about
       possible under-reporting of administrative overhead costs. We
       would agree that administrative costs relating to the operation of
       particular committees should be reported by committees, but an
       agency's administrative/management costs to meet procedural and
       paperwork requirements connected with implementation af ACA should
       not be reported as committee support costs. We have discussed tnis
       with the OMB and the GAO study team, and believe the approach taken
       by our projected procedures will show fully the costs of monitoring
       openness and accountability, but show them separately, to be of
       more usefulness in legislating and accounting.
  6. Report pages 30 to 37:     "Adequate Definitions Needed for subgroups
  and Ad Hoc Committees"
  If the recommended action is taken by OMB concerning the development of
  a terminology for subgroups and ad hoc committees, certain factors need
  to be considered. Under some circumstances it is useful to obtain
  advice from competent people on an ad hoc basis. There is no need for
  a continuing committee, when consensus advice from outside the Govern-
  ment is needed urgently and time does not permit the chartering of a
  formal committee, nor when it is necessary to prevent a conflict of
  interest on the part of regularly appointed members in the review of
  grant applications. There would be no objection to identifying the
  individuals who provide advice, the function of the group, the cost and
  other information to the Congress and to the Public. In light of
  realities regarding the length of time involved to charter a committee
  and to clear appointment of members to chartered committees, application
  of FACA requirements to such groups would proba'ty end their usefulness.
  7.   Report pages 42 to 44:   "A Standard Report Definition is Needed"
  We believe the report should distinguish   the need--if any--for reports
  by types of committees. For instance, a    "report" may not be an accurate
  measure of effectivness of certain types   of committees such as grant
  review committees. Committees which are    solely advisory may correctly

APPENDIX IX                                                   APPENDIX IX

 place more reliance on "reports." Also the PAO report does not specify
 whether samples of minutes were reviewed to make this kind of assess-
 ment. Depending on the level of detail included, some minutes are
 comprehensive enough to be considered "reports."
 8. Report pages 44 to 46;    "Follow-up Procedures for Cummittee
 We believe it is unlikely that the WAO-recommended system of follow-up
 or feedback would meet the needs of different types of advisory com-
 mittees. Further, that it would result in a large increase in costs and
 paperwork associated with the operation of advisory committees.
 Other Comments
 We would like to make some very specific comments to the report re-
 garding the following:
     1. Improper use of ad hoc committees. The reasons stated on page
     7 for OMB nonconcurrence do not accurately reflect our experience
     of having a number of committees turned down by OP--because they
     would review grant applications for programs which the President's
     budget proposes to phase out. The inability of agencies to charter
     needed committees to provide peer review for grant applications--in
     spite of the fact that the Congress has consistently appropriated
     funds for these programs--is not addressed in the report. The
     report does not recognize the ongoing need for obtaining appropri-
     ate peer review and does not address how this problem can be


     4. The Congress should consider establishing a simple repeal
     mechanism to abolish committees established by statute, when


     6. The inconsistency in reporting cost figures can easily be
     remedied by revising the criteria for computing them on the annual
     reporting form.

APPENDIX X                                                     APPENDIX X

                            WASHINGTON, D.C.   20460
                             OCT 4 1976

                                                                    rFFICE OF
                                                            PLANNING ..NO MANAGEMENT

  Mr. Henry Eschweg,:
  Director, Community and Economic
    Development Division
  United States General Accounting Office
  Washington, D.C. 20548

  Dear Mr. Eschwege:

  We have received copies of the General Accounting Office draft report
  entitled "Evaluatioas of the Usefulness of Federal Advisory Committees
  Need Improvement," for review and comment on August 26. Although I
  cannot speak for the Office of Management and Budget (OMB) and the other
  four agencies re',iewd, I feel that the Environmental Protection Agency
  (EPA) has and will continue to improve its efforts to comply with the
  Act. For example, EPA has held no closed or partially closed advisory
  committee meetings for the past three years. All advisory committee
  meetings have been open and announced in the Federal Register 15 days
  prior to the meeting dates, with the exception of 4 late notices during
  1975 and 3 late notices during 1976 (these were late by one day). Most
  of the late notices were due to a backlog of wcrk at the Federal
  Register and emergency publication was not util ted. The National
  Drinking Water Advisory Council has been publishing their meeting
  notices 30 days i advance of meeting dates, which exceeds the 15-day
  requirement of the Federal Advisory Committee Act (FACA). In
  accordance with the OMB definition of "Balanced membehip" including
  appropriate attention to factors of sex, race, creed, national origin,
   and religion, EPA has made noteworthy progress in promoting balanced
  memberships for our committees. Currently, we have 50 members who are
   either women or minorities serving out of a total of 167 positions for
  which EPA has the final appointing authority. Thus, approximately one
   third of EPA-selected committee membership is composed of women and/or
   minorities. A substantial effort has been undertaken to locate techni-
   cally-qualified individuals among women and minority groups in order to
   achieve this balance.

   EPA has been diligent in keeping its number of advisory committees
   down to the minimum necessary, as required by the FAPr   The Agency

APPENDIX X                                                     APPENDIX X

  inherited 24 advisory committees on January 1, 1971, at its inception;
  and we began this year, January 1, 1976, with only 20 advisory commit-
  tees. During this period (1/1/71 through 1/1/76) EPA terminated 32
  advisory committees and the Adminitrator established 25 committees in
  addition to the 3 established by Congress.  Only four of the inherited
  committees are still in existence and two of these are in the process
  of being abolished at this time.

  Due to the various ramifications of the FACA and OB Circular A-63,
  the Agency Committee Management Officer works actively to discourage
  program officials from forming new advisory ccmmittees, suggesting
  that they explore alternative avenues for generating advice and
  diverse points of view. Suggested alternatives include greater use of
  "in-house" capabilities, public hearings, solicitation of comments
  from the public, use of contracts, experts, and consultants.

  OMB has also been diligent in their efforts to reduce the number of
  advisory committees within the Agency.  Two requests for renewal have
  been denied by GMB and the following eight advisory committees proposed
  for establishment by the Administrator were rejected by 0MB:

       Mobile Source Air ollution Control Advisory Committee (12/26/73)
       National Solid Waste/Hazardous Waste Management (12/26/73)
       Pesticide Extramural Advisory Committee (12/26/73)
       Advanced Fossil Fuels Research Advisory Commit.ee (9/4/75)
       Electric Utilities Research Advisory Committee (9/4/75)
       Western Energy Resources Development / isory Committee (9/4/75)
       Advisory Committee on Clean Air Act itiiementation (8/31/76)
       Instrumentation and Control Systems Advisory Committee for
         Wastewater and atet Management (8/31/76)

  We are still consciously looking for ways in which we can improve our
  uniformity of committee management.  As stated on page 4 of the draft
  report, EPA's Office of Planning and Management is currently conducting
  a study of our advisory committee activities also. Hopefully, we will
  have even better managerial procedures as a result of these two studies.

  We appreciate the opportnmitv to review and comment on this report prior
  to its submission to Congress.

  Sincerely your<.

  Alvin L. Alm
  Assistant Administrator
  for Planning and Management   (PM-208)

APPENDIX XI                                         APPENDIX XI

                     PRINCIPAL OFFICIALS


                  DISCUSSED IN THIS REPORT

                                        Tenure of office
                                       From           To

                   DEPARTMENT OF COMMERCE

    Juanita Kreps                   Jan.     1977    Present
    Elliot L. Richardson            Feb.     1976    Jan.  1977
    Rogers C.B. Morton              May      1975    Jan.  1976
    Frederick B. Dent               Feb.     1973    Apr.  1975

    Guy W. Chamberlin, Jr.
      (acting)                      Jan.     1977    Present
    Joseph E. Kasputys              Feb.     1976    Jan.  1977
    Joseph E. Kasputys (acting)     Jan.     1976    Feb.  1976
    Guy W. Chamberlin, Jr.
      (acting)                      Oct.     1974    Jan.   1976
    Henry B. Turner                 Apr.     1973    Oct.   1974


    Joseph A. Califano, Jr.         Jan.     1977    Present
    David Mathews                   Aug.     1975    Jan.  1977
    Casper W. Weinberger            Feb.     1973    Aug.  1975

    Vacant                          Jan.     1977    Presen t
    Marjorie Lynch                  Nov.     1975    Jan.   1977
    Vacant                          Jan.     197,    Nov.   1975
    Frank C. Carlucci               Jan.     1973    Jan.   1975

    Vacant                          Mar.     1976    Present
    Douglas J. Bielan               Oct.     1976    Feb.  1977
    Douglas J. Bialan (acting)      Mar.     1976    Oct.  1976
    William S. Ballenger            Jan.     1974    Mar.  1976

APPENDIX XI                                            APPENDIX XI

                                            Tenure of office
                                           From           To


    Francis N. Waldrop (acting)        Jan.     1977   Present
    James D. Isbister                  Aug.     1975   Jan.  1977
    James D. Isbister (acting)         Sept.    1974   Aug.  1975
    Dr. Robert Dupont (acting)         Jul'     1974   Sept. 1974
    Roger O. Egeberg (acting)          Ocx.     1973   June  1974

    Sherwin Gardner (acting)            Dec.    1976   Present
    Alexander M. Schmidt, M.D.          July    1972   Dec.  1976


    Cecil D. Andrus                     Jan.    1977   Present
    Thor,,as S. Kleppe                  Oct.    1975   Jan.  1977
    Stanley K. Hathaway                 June    1975   Oct.   1975
    Kent Frizzell                       May     1975   June  1975
    Rogers C.B. Morton                  Jan.    1971   Apr.   1975

    Richard R. Hite                     July    1971   Present

    Cur'   :rklund                      Juliv   1973   Present

    Gary E. Everhardt                   Jan.    1975   Present
    Ronald H. Walker                    Jan.    1974   Dec.  1974


    Douglas M. Costle                   Mar.    1977   Present
    John R. Quarles (acting)            Jan.    1977   Mar.  1977
    Russell E. Train                    Sept.   1973   Jan.  1977

    Richard Redenius                    Jan.    1977   Present
    Alvin L. Alm                        July    1973   Jan.  1977

APPENDIX XI                                            APPENDIX XI

                                              Tenure of office
                                             From           To


    Richard C. Atkinson (acting)       Aug.     1976    Present
    H. Guyford Stever                  Feb.     1972    Aug.  1976

    Eldon D. Taylor                    Aug.     1974    Present
    Eldon D. Taylor (acting)           July     1974    Aug.  1974
    Thomas Jenkins                     Sept.    1972    June  1974


    Bert Lance                         Jan.     1977    Present
    James T. Lynn                      Feb.     1975    Jan.  1977
    Roy L. Ash                         Feb.     1973    Feb.     1975

    Toney Head, Jr. (acting)          June     1976     Present
    Clifford W. Graves                Jan.     1974     June  1976

    William E. Bonsteel               Jan.     1975     Present
    Chester D. Warner                 Mar.     1974     Jan.  1975
    William B. Hawley                 Mar.     1973     Mar.  1974