Holding the Government Accountable

Disclosing Oversight Recommendations: How Are Agencies Doing?

(Photo Illustration: Leslie Garvey / POGO)

Thanks to a law passed in 2019, federal agencies are now required to report the recommendations they have received from two government watchdogs — the Government Accountability Office and agency inspectors general — as well as how they plan to respond to those recommendations. The law was meant to encourage transparency into the challenges agencies face, as well as accountability for implementing solutions. Regrettably, three years after the Good Accounting Obligation in Government Act (GAO-IG Act) went into effect, a disappointingly low number of agencies are in full compliance with its basic reporting requirements, new research from the Project On Government Oversight shows.

Every year inspectors general (IGs) throughout the federal government investigate agency programs and audit budgets to promote efficiency and root out waste, fraud, or abuse. Similarly, the Government Accountability Office (GAO), the investigative branch of Congress, reviews agency activities and evaluates the compliance and effectiveness of major programs. The reports produced by IGs and GAO often include specific recommendations the agency should consider.

The GAO-IG Act, signed into law on January 3, 2019, requires agencies to annually report to Congress key information related to the recommendations received from the GAO or agency IGs. Specifically, the law requires agencies to report the following information in their budget justifications to Congress:

  • A list of each public recommendation received from either the GAO or the IG that is still open or unimplemented and more than a year old
  • The status of each open recommendation, including an implementation timeline for recommendations the agency is adopting and a detailed justification for recommendations the agency has chosen not to implement
  • Explanations for any discrepancies between the agency’s list of recommendations and the recommendations listed by GAO and the agency IG

It is important to note that the GAO-IG Act does not require agencies to implement all GAO and IG recommendations, merely to publicly track and respond to those recommendations that remain open after a full year. While the objective recommendations in these reports are often helpful to agencies, there are times when agencies disagree on some of them. Other times they may agree with the general direction of a recommendation but have concerns that delay or prevent implementation of the precise action recommended.

The annual reporting approach ensures that none of the recommendations gets ignored or lost, that the agency offers a clear response to each, and that other entities — such as members of Congress or the public — can easily review both the recommendations and the responses. This creates accountability in a simple but very helpful way.

Unfortunately, most major agencies are not fully complying with the reporting requirement of the GAO-IG Act even though the law has been in place for several years.

POGO reviewed the fiscal years 2020, 2021, and 2022 budget justification materials from 19 major agencies to evaluate how well the agencies complied with all three aspects of the reporting requirements.

Agencies that Fulfilled All Three Requirements

POGO’s review found that by fiscal year 2022 just four agencies — the Departments of Justice, Homeland Security, and Commerce, along with the Social Security Administration — were in full compliance with the law.

Just four agencies were in full compliance with the law.

The Social Security Administration provides a strong example of full reporting compliance. The agency’s 47-page report covers all recommendations more than a year old for which it hasn’t taken final corrective action. The report includes four tables listing the status of open and closed recommendations from both GAO and the agency’s IG. The report also includes a table detailing two recommendations that the IG lists as open in its semi-annual reports to Congress but that the agency asserts are closed, providing both the status description from the IG report and the agency’s explanation.

Agencies that Fulfilled Some Requirements

Ten agencies, just over half of those reviewed, did fulfill some of the requirements. However, they still failed to meet all the requirements by fiscal year 2022 to varying degrees.

For instance, the Department of Health and Human Services fell just short of fulfilling the requirements. The agency issued a 672-page report detailing the more than 900 recommendations received more than a year ago that are still open or are closed and unimplemented, providing information about the exact reports the recommendations originated from, whether the agency concurred, and the status of implementation. The report also notes a discrepancy between the number of IG recommendations the agency considers open (454) and the number of recommendations the IG lists as remaining open for more than a year (486), and includes a blanket explanation that there is a discrepancy because the remaining recommendations were directed at specific states or grantees rather than HHS components. However, this explanation is insufficient. The GAO-IG Act requires that each recommendation and its status be listed in order to make them available for public review, so all discrepancies and explanations should also be listed individually to allow the public to determine if each explanation is justified.

Other agencies were missing more significant portions of the required reporting. The Department of Agriculture’s 75-page report, for example, appears to list all open recommendations from both GAO and the agency IG, but there are no implementation details for the recommendations the agency is adopting or detailed justifications for those the agency is rejecting. Additionally, the list appears to be missing any recommendations that the agency closed because it had successfully implemented them.

The eight agencies that complied with some of the reporting requirements are

  • Department of Agriculture;
  • Department of Education;
  • Department of Health and Human Services;
  • Department of Housing and Urban Development;
  • Department of State;
  • Department of Transportation;
  • Department of the Treasury;
  • Department of Veterans Affairs;
  • Environmental Protection Agency; and
  • Office of Personnel Management.

Agencies that Did Not Comply with Any Requirements

POGO’s review found five major agencies that failed to comply with any aspect of the GAO-IG Act from 2019. These agencies either had no GAO-IG Act reporting at all or had reporting that failed to meet the specific requirements laid out in the law.

For example, although the Department of Energy includes in its report a short section (starting on page 354) that lists ongoing audits and assessments from GAO and the agency IG, there is no listing of individual recommendations or their status. The Small Business Administration takes a similar approach in its reporting, which includes (on page 170) just a simple list of GAO and IG reports with open recommendations, but no details on individual recommendations.

The agencies that failed to comply with any of the reporting requirements are

  • Department of Defense;
  • Department of Energy;
  • Department of the Interior;
  • Department of Labor; and
  • Small Business Administration.


In light of the continued failure of many agencies to fully implement the GAO-IG Act reporting requirements, POGO recommends that agencies review their reporting process prior to submitting the fiscal year 2023 budget justifications and make any necessary changes.

Many agencies should review how they report discrepancies between their accounting of open recommendations and those included in annual GAO and agency IG reports. Numerous agencies have complied with the requirements for detailed reporting on open recommendations but either failed to include anything on discrepancies or offered too little information to enable public accountability.

Agencies should list each recommendation that differs from the GAO and IG annual reports. If there are no discrepancies, an agency should include a clear statement confirming that the recommendations listed by the agency in its GAO-IG reporting match the number and content of those included in the annual reports from GAO and the agency IG.

Agencies should also review the data points being reported for each open recommendation. The law specifies three data points for each public recommendation listed from GAO or the agency IG:

  • The implementation status of the recommendation
  • A detailed justification for recommendations the agency decides not to implement
  • A timeline for implementation for recommendations the agency is adopting

Agencies should ensure all three data points are provided for each open recommendation. Leaving out a clear status, implementation timeline or date, or explanation for recommendations rejected by the agency would constitute a failure to comply with the reporting requirements.

More fundamentally, some agencies need to ensure that their reporting includes an actual list of individual open GAO and IG recommendations along with status and explanations of the agency’s planned actions. Simply linking to the GAO’s and the agency IG’s annual reports containing open recommendations, an approach some agencies attempted, does not satisfy the reporting requirements. The GAO-IG Act requires reporting on each open recommendation.

And finally, Congress should carefully review the GAO-IG Act reporting each agency submits with its next budget justification documents to ensure that each agency is fully complying with the requirements. Congress should instruct any agencies found to be deficient in their GAO-IG Act reporting to update their budget justification materials as soon as possible with the required information.