GAO-21-104325, COVID-19: Reviewing Existing Policies Could Help Selected Agencies Better Prepare for Dedicated User Fee Revenue Fluctuations

Summary

GAO-21-104325 is a Government Accountability Office report to congressional committees dated September 29, 2021, prepared under a CARES Act provision for GAO to review the effects of the COVID-19 pandemic. It examines how executive branch agencies' dedicated user fee revenues changed after the pandemic began and how the FAA, the National Park Service and U.S. Citizenship and Immigration Services managed those changes. GAO found that after the national emergency declaration in March 2020 these revenues were about 39 percent lower than the previous 3-year average for the same period. It found that FAA has not documented plans to review its cash management plan and that NPS has not analyzed its 35 percent carryover policy since 2010. GAO recommends that FAA and NPS review that plan and policy, and the Departments of Transportation and the Interior concurred.

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Full text

United States Government Accountability Office

Report to Congressional Committees

September 2021

COVID-19
Reviewing Existing
Policies Could Help
Selected Agencies
Better Prepare for
Dedicated User Fee
Revenue Fluctuations

GAO-21-104325


September 2021

COVID-19

Highlights of GAO-21-104325, a report to
congressional committees

Reviewing Existing Policies Could Help Selected
Agencies Better Prepare for Dedicated User Fee
Revenue Fluctuations

Why GAO Did This Study

What GAO Found

Each year, federal agencies collect
billions of dollars in dedicated user fee
revenue from fees charged to users of
federal goods and services, which are
dedicated by law for a specific purpose
or program. The COVID-19 pandemic
disrupted critical government
operations for agencies that rely on
these revenues.

Executive branch agencies’ revenues from dedicated user fees were lower in
fiscal year 2020 and in the first half of fiscal year 2021 compared to average
annual revenues in fiscal years 2017 through 2019, the 3 fiscal years prior to the
start of the COVID-19 pandemic. Following the declaration of the pandemic as a
national emergency in March 2020, these revenues were about 39 percent lower
than the previous 3-year average during the same period.
Executive Branch Agencies’ Revenue from Dedicated User Fees in Fiscal Year 2020 Was
Lower Overall than the Previous 3-year Average

The CARES Act included a provision
for GAO to review the effects of the
pandemic on public institutions of the
U.S. This report examines how
dedicated user fee revenues have
changed since the onset of the
pandemic and how selected agencies
managed revenue changes related to
the pandemic, among other objectives.
To determine revenue changes, GAO
compared dedicated user fee revenues
in fiscal years 2020 and 2021 to
amounts from prior years. GAO
selected three agencies to review—
FAA, NPS, and USCIS—based on
whether they relied on dedicated user
fee revenue to a high (FAA and
USCIS) or low (NPS) extent, among
other factors. GAO interviewed officials
at the selected agencies and reviewed
relevant documents to determine how
these agencies managed revenue
changes, and compared those actions
to internal control standards and
leading practices for fee design.

What GAO Recommends
GAO is recommending that FAA and
NPS review their cash management
plan and target carryover balance
policy, respectively, and document
processes to review the plan and
policy in the future. The Departments
of Transportation and the Interior
concurred with GAO’s
recommendations.
View GAO-21-104325. For more information,
contact Jeff Arkin at (202) 512-6806 or
arkinj@gao.gov.

Note: For more details, see figure 2 in GAO-21-104325.

The Federal Aviation Administration (FAA), National Park Service (NPS), and
U.S. Citizenship and Immigration Services (USCIS) all prioritized spending on
essential expenses, sought to increase available funds or operational flexibilities,
and relied on carryover balances to cover essential expenses during the
pandemic. However, FAA and NPS have not documented plans to review certain
management plans and policies.
•

•

FAA drafted a cash management plan containing measures to help it carry
out mission-critical functions in a time of Airport and Airway Trust Fund
(AATF) revenue instability. FAA officials told GAO they may revisit the plan to
align it with leadership priorities in case of future AATF revenue instability.
However, FAA has not documented plans to conduct such a review, which
could help FAA better prepare for future periods of revenue instability.
NPS parks relied on funds carried over from previous years during the
pandemic to various extents, depending on local circumstances. NPS
requires many fee-collecting parks to carry over no more than 35 percent of
the previous year’s revenue from certain fees. The agency has not
completed an analysis to determine the efficacy of this policy since its
implementation in 2010. Because of this, NPS may not be maintaining its
carryover balances in the most effective way.
United States Government Accountability Office


Contents

Letter

1
Background
Executive Branch Agencies’ Revenues from Dedicated User Fees
Declined during the COVID-19 Pandemic
Selected Agencies’ Dedicated User Fee Revenues Decreased
after the Onset of the Pandemic
Selected Agencies Enhanced Revenue Monitoring and Processes
for Making Projections during the Pandemic
Two of Three Selected Agencies Have Not Reviewed Certain
Monitoring and Management Processes Used during the
Pandemic
Conclusions
Recommendations for Executive Action
Agency Comments and Our Evaluation

3
10
16
29
33
43
44
44

Appendix I

Objectives, Scope, and Methodology

48

Appendix II

Methodology for the Analysis of Executive Branch Agencies’
Dedicated User Fee Revenue

54

Appendix III

Comments from the Department of Transportation

59

Appendix IV

Comments from the Department of the Interior

60

Appendix V

GAO Contact and Staff Acknowledgments

62

Table 1: Airport and Airway Trust Fund Excise Tax Lines and
Revenue Sources

6

Table

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Figures
Figure 1: Executive Branch Agencies’ Monthly Revenue from
Dedicated User Fees, Fiscal Year 2020 Compared to
Average Dedicated User Fee Revenue from Fiscal Years
2017 through 2019
Figure 2: Executive Branch Agencies’ Quarterly Revenue from
Dedicated User Fees, Fiscal Years 2020 and 2021
Compared to Average Dedicated User Fee Revenue from
Fiscal Years 2017 through 2019
Figure 3: Executive Branch Agencies’ Monthly Revenue from
Dedicated User Fees, First Half of Fiscal Years 2020 and
2021 Compared to Average Dedicated User Fee
Revenue from Fiscal Years 2017 through 2019
Figure 4: Airport and Airway Trust Fund Gross Receipts, Fiscal
Years 2019 and 2020
Figure 5: Seven-Day Average of Transportation Security
Administration Airport Checkpoint Numbers, Jan. 2019 to
June 2021
Figure 6: Airport and Airway Trust Fund Gross Receipts, Oct.
2019 through Apr. 2021
Figure 7: National Park Service Recreation Fee Revenue, Oct.
2018 through Mar. 2021
Figure 8: National Park Service Concession Franchise Fee
Revenue, Oct. 2018 through Mar. 2021
Figure 9: U.S. Citizenship and Immigration Services Fee
Revenue, Oct. 2018 through Mar. 2021
Figure 10: U.S. Citizenship and Immigration Services Immigration
Examinations Fee Account Revenue, Mar. 2020 through
Feb. 2021 Compared to Mar. 2019 through Feb. 2020
Figure 11: Sign to Promote Social Distancing in Great Falls Park,
Virginia
Figure 12: Timeline Depicting Major Cost-Cutting Actions Taken
by U.S. Citizenship and Immigration Services during the
COVID-19 Pandemic

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11

13

14
17
19
20
22
23
25
26
28
37

GAO-21-104325 COVID-19


Abbreviations
AATF
COVID-19
FAA
GTAS
IEFA
IOAA
NPS
OMB
TAS
USCIS
USSGL

Airport and Airway Trust Fund
Coronavirus Disease 2019
Federal Aviation Administration
Governmentwide Treasury Account Symbol Adjusted Trial
Balance System
Immigration Examinations Fee Account
Independent Offices Appropriation Act of 1952
National Park Service
Office of Management and Budget
Treasury Account Symbol
U.S. Citizenship and Immigration Services
United States Standard General Ledger

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Letter

441 G St. N.W.
Washington, DC 20548

September 29, 2021
Congressional Committees:
Each year, the U.S. government collects billions of dollars in dedicated
user fee revenue—revenues from fees charged to users of federal goods
and services that are dedicated by law for a specific purpose or program.
In fiscal year 2019, executive branch agencies collected approximately
$105 billion in dedicated user fee revenue. Dedicated user fees help fund
a variety of programs and operations. For example, fees paid by the
public to visit national parks help fund visitor experience improvements.
The global Coronavirus Disease 2019 (COVID-19) pandemic, which
caused serious economic repercussions and turmoil, disrupted fiscal year
2020 dedicated user fee revenues and critical government operations for
executive branch agencies. 1
The CARES Act includes a provision for us to review the effect of the
COVID-19 pandemic on the health, economy, and public and private
institutions of the U.S. 2 This report addresses (1) how executive branch
agencies’ revenues from dedicated user fees have changed since the
onset of the COVID-19 pandemic; (2) how dedicated user fee revenues
have changed at selected agencies during the COVID-19 pandemic; (3)
how selected agencies monitored revenue instability risks related to the
COVID-19 pandemic; and (4) how selected agencies managed revenue
changes during the COVID-19 pandemic, including the use of selected
program reserves, and the extent to which those actions aligned with
requirements and guidance.
To address our first objective, we analyzed data from the Department of
the Treasury’s Bureau of the Fiscal Service’s Governmentwide Treasury
Account Symbol Adjusted Trial Balance System (GTAS). Agencies use
GTAS to provide proprietary financial reporting information and
information about budget execution to Treasury. To determine how
dedicated user fee revenues changed during the COVID-19 pandemic,
1We regularly issue government-wide reports on the federal response to COVID-19. For

the latest report, see GAO, COVID-19: Continued Attention Needed to Enhance Federal
Preparedness, Response, Service Delivery, and Program Integrity, GAO-21-551
(Washington, D.C.: July 19, 2021). Our next government-wide report will be issued in
October 2021 and will be available on GAO’s website at https://www.gao.gov/coronavirus.

2Pub. L. No. 116-136, 134 Stat. 281 (2020).

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we reviewed dedicated user fee data for all executive branch agencies
that submitted dedicated collection revenue in fiscal year 2020. 3
We analyzed these data from October 2017 through March 2021, the
most recent data available at the time of our analysis. We analyzed
relevant financial accounts to determine which to include in our scope of
dedicated user fees. For instance, we limited our analysis to revenue
transaction accounts and excluded accounts that we determined were not
related to user fee-type revenue. Some of these determinations, which we
based on information from Bureau of the Fiscal Service documents and
officials and our knowledge of agencies and financial accounts, were
necessarily judgmental. The inclusion of other financial accounts in our
analysis—such as donations or forfeitures—could also have been
reasonable and would have yielded different results.
To assess the reliability of the GTAS data, we reviewed relevant
documentation, interviewed knowledgeable officials at the Bureau of the
Fiscal Service, and conducted electronic data testing. We determined that
these data were sufficiently reliable to indicate general trends in
dedicated user fee revenues across the executive branch. For additional
details about our scope and methodology, including how we scoped our
GTAS analysis and analyzed dedicated user fee revenue data across the
executive branch, see appendixes I and II.
To address our remaining three objectives, we selected three agencies
for review to serve as illustrative examples of how dedicated user fee
revenues changed during the pandemic and how agencies responded to
these changes: the Department of Transportation’s Federal Aviation
Administration (FAA), the Department of the Interior’s National Park
Service (NPS), and the Department of Homeland Security’s U.S.
Citizenship and Immigration Services (USCIS). To understand the
potential effects of the COVID-19 pandemic across a range of revenue
situations, we selected agencies based on the extent that they relied on
dedicated user fee revenue in recent years–both high reliance (FAA and
USCIS) and low reliance (NPS), according to Office of Management and
Budget (OMB) data.
We also considered contextual information in our selection process,
including whether an agency was potentially financially affected by the
3For the purposes of this report, we collectively refer to departments, agencies, bureaus,

government corporations, and other government entities as “agencies.”

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COVID-19 pandemic, whether an agency’s activities were related to
economic sectors most affected by the pandemic, and media reports of
agencies affected by the pandemic. We reviewed revenue, budget, policy,
and planning documents at each selected agency, and interviewed
knowledgeable agency officials, to determine how dedicated user fee
revenues changed during the pandemic, how selected agencies
monitored revenue instability risks, and how selected agencies managed
revenue changes during the pandemic.
To assess the reliability of revenue data related to each selected agency,
we reviewed the data for reasonableness and compared these values to
amounts in agency budget justification documents when possible. We
determined that these data were sufficiently reliable to calculate revenue
changes at selected agencies following the onset of the COVID-19
pandemic.
To address our fourth objective, we assessed selected agencies’ revenue
monitoring and management processes during the COVID-19 pandemic
against Standards for Internal Control in the Federal Government
(Principle 12 – Implement Control Activities) and leading practices for fee
design options that we identified in prior work. 4
We conducted this performance audit from May 2020 to September 2021
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

Background

Dedicated collections are revenues dedicated by law for a specific
purpose or program, and dedicated user fees are a subset of those
collections. User fees are charges to users for goods or services provided
by the federal government. User fees are an approach to financing
federal programs or activities that, in general, are related to some
voluntary transaction or request of government services above and
beyond what is normally available to the public. User fees may also be
4GAO, Standards for Internal Control in the Federal Government, GAO-14-704G

(Washington, D.C.: Sept. 2014); and Federal User Fees: Fee Design Options and
Implications for Managing Revenue Instability, GAO-13-820 (Washington, D.C.: Sept. 30,
2013).

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collected through excise taxes. 5 For the purposes of this report, we
include excise taxes with a “user pays” element within our definition of
user fees. 6
Agencies derive their authority to charge fees either from the Independent
Offices Appropriation Act of 1952 (IOAA) or other statutory authority. 7 The
IOAA provides agencies broad authority to assess user fees or charges
through regulation for services or things of value they provide. The IOAA
itself does not provide authority for agencies to retain fees they collect. 8
Some agencies, however, have specific statutory authority to retain and
use fees without additional legislative action.
Carryover Balances
Carryover balances are composed of two
elements:
•

unobligated funds, and

•

obligated funds for which payment has
not yet been made.

Source: GAO. | GAO-21-104325

Regulations prescribed by the heads of executive agencies are subject to
policies prescribed by the President. 9 For agencies whose fee collections
are available for obligation on a no-year or multi-year authority basis,
unobligated balances can be carried forward from year to year. 10 OMB
Circular No. A-25 establishes federal guidelines regarding user fees
assessed under the authority of the IOAA and other statutes, including
5Although payroll taxes comprise a large portion of all federal dedicated collections, for the

purposes of this report, we do not consider them a direct transaction from the public to the
federal government in exchange for a good or service and, therefore, have excluded them
from our scope of dedicated user fees.

6The Congressional Budget Office has defined user charges as fees or taxes that are
based on benefits individuals or firms receive from the federal government or that in some
way compensate for costs they might impose on society or its resources. See
Congressional Budget Office, The Growth of Federal User Charges (Washington, D.C.:
Aug. 1993). For budget purposes, we define user fees as fees assessed on users for
goods or services provided by the federal government. See GAO, A Glossary of Terms
Used in the Federal Budget Process, GAO-05-734SP (Washington, D.C.: Sept. 2005).
7Pub. L. No. 82-137, 65 Stat. 268 (1951), codified at 31 U.S.C. § 9701.
8Agencies may have specific statutory authority to deposit fees into receipt accounts but

may not use them without further congressional appropriation of the funds (offsetting
receipts), or specific statutory authority to credit the collections to an expenditure account
and use the fees without additional congressional appropriation (offsetting collections).

931 U.S.C. § 9701.
10Budget authority can be provided for one or multiple years, while some budget authority
never expires. An obligation is a definite commitment that creates a legal liability of the
government for the payment of goods and services ordered or received, or a legal duty on
the part of the U.S. that could mature into a legal liability by virtue of actions on the part of
the other party beyond the control of the U.S. An agency incurs an obligation, for example,
when it places an order, signs a contract, awards a grant, or purchases a service. An
unobligated balance is the portion of obligational authority that has not yet been obligated.

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the scope and types of activities subject to user fees and the basis upon
which the fees are set. 11 It also provides guidance for executive branch
agency implementation of fees and the disposition of collections. 12
Under OMB Circular No. A-25, agencies must review their user fees for
agency programs biennially, to include: (1) assurance that existing
charges are adjusted to reflect unanticipated changes in costs or market
values; and (2) a review of all other agency programs to determine
whether fees should be assessed for government services or the user of
government goods or services.

Federal Aviation
Administration

FAA is responsible for the safety and oversight of commercial aviation.
The agency does this by conducting safety inspections, operating the air
traffic control system, and researching improvements to aviation safety,
among other things. The majority of FAA’s appropriations in the
Consolidated Appropriations Act, 2021, were from the Airport and Airway
Trust Fund (AATF), which accounted for approximately 95 percent of
FAA’s fiscal year 2021 enacted budget. 13 The remaining 5 percent of
FAA’s appropriations that year came from general revenues. 14
The AATF helps fund the development of a nationwide airport and airway
system and funds FAA investments in air traffic control facilities such as
capital investments, construction and safety improvements at airports,
and technological upgrades to the air traffic control system. 15 The AATF
receives income from a variety of excise taxes paid by users of the
national airport and airway system, and may receive other appropriations.
11Office of Management and Budget, User Charges, Circular No. A-25 Revised

(Washington, D.C.: July 8, 1993).

12OMB Circular No. A-25 does not apply to the activities of the legislative and judicial

branches of government or to mixed ownership government corporations as defined in 31
U.S.C. § 9101.
13Pub. L. No. 116-260, div. L, 134 Stat. 1182, 1830 (2020).
14General revenues are held in General Fund accounts, which hold all federal money not

allocated by law to any other fund account.

15The AATF was established by the Airport and Airway Revenue Act of 1970. Pub. L. No.

91-258, § 208, 84 Stat. 219, 250 (1970) codified, as amended, at 26 U.S.C. § 9502. FAA’s
authority to collect aviation excise taxes through the AATF, as well as spend from the trust
fund, is periodically extended by statute. The most recent reauthorization statute was
signed into law on October 5, 2018, and extended FAA’s funding and authorities through
fiscal year 2023. FAA Reauthorization Act of 2018, Pub. L. No. 115-254, 132 Stat. 3186,
3199-200, 3428 (2018).

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The largest source of tax income is generated through the transportation
of passengers (see table 1).
Table 1: Airport and Airway Trust Fund Excise Tax Lines and Revenue Sources
Percentage of fiscal year 2019
trust fund gross tax receipts

Tax line

Revenue source

Transportation of Persons by Air

Domestic passenger ticket tax; domestic flight
segmenta tax (excluding flights to or from rural
airports); and tax on mileage awards (frequent flyer
awards tax)

68.3 percent

Transportation of Property by Air

Tax on domestic cargo or mail

3.4 percent

Use of International Air Facilities

Tax on international arrivals and departures; and tax
on flights between the continental U.S. and Alaska or
Hawaii (or between Alaska and Hawaii)

24.2 percent

Aviation Fuel Commercial Use

Domestic commercial fuel tax

2.7 percent

Aviation Fuel Other than Gasolineb

Domestic general aviation jet fuel tax

0.1 percentc

Aviation Gasoline

Domestic general aviation gasoline tax

0.2 percent

Source: Federal Aviation Administration and Department of the Treasury data. | GAO-21-104325

A flight segment consists of one takeoff and one landing.

a

Taxes collected on kerosene used in aviation are initially deposited in the Highway Trust Fund and
then transferred by accounting adjustments to the Airport and Airway Trust Fund. Pub. L. No. 109-59,
§ 11161(c), 119 Stat. 1144, 1972 (2005).
b

c
This percentage includes fiscal year 2019 gross tax receipts for Liquid Fuel – Fractional Ownership
Flight.

Income deposited in the AATF is subject to congressional appropriations;
therefore, while receipts are authorized to be deposited in the trust fund,
congressional action is required for FAA to use the funds. Balances in the
AATF are invested in Treasury securities and accrue interest.
AATF income tends to reflect general economic conditions, which can
affect the number of tickets purchased, the fares paid by passengers, the
amount of fuel purchased, and the value of air cargo shipped. Treasury
estimates AATF income levels based on these factors, which inform how
much is appropriated to FAA to spend. 16 Since the AATF’s creation in
1970, aggregate annual income has generally exceeded spending
16To ensure that revenues deposited into the trust fund are used for aviation purposes
and that FAA’s capital account is funded to the fully authorized level, the total budget
resources made available from the AATF must be equal to the sum of 90 percent of the
estimated level of receipts plus interest credited to the AATF and the actual level of
receipts plus interest credited to the AATF in fiscal years 2014-2018. 49 U.S.C. §
48114(a)(1).

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commitments from FAA’s appropriations, resulting in a surplus. This
surplus is referred to as the trust fund’s uncommitted balance. 17

National Park Service

NPS manages the National Park System with the purpose of conserving
the scenery, natural and historic objects, and wildlife therein and to leave
them unimpaired for the enjoyment of future generations. 18 Funding for
NPS comes from two sources: 19
Annual appropriations. NPS generally receives funding through annual
appropriations acts, which provide funds used by parks or applicable
entities, such as states and local governments. In fiscal year 2021, these
appropriations constituted approximately 75 percent of NPS’s enacted
budget.
Fees, donations, and other funding sources. NPS collects and uses
funds from fees, donations, and other miscellaneous charges. These
include:
•

Recreation fees. The Federal Lands Recreation Enhancement Act
authorizes NPS to collect and use recreation fees, including entrance
fees and amenity fees for certain equipment and services, such as
campgrounds. 20 The act states that not less than 80 percent of the
recreation fees and admission revenues collected at a specific unit or

17The uncommitted balance is the amount of cash in excess of what is required to cover
future expenditures of unpaid budget authority, or the amount of the AATF cash balance
that is “unclaimed” by existing appropriations, according to an FAA projections document.
1854 U.S.C. § 100101. This report collectively refers to the park units, national scenic and
national historic trails, and wild and scenic rivers that NPS manages as “parks.”
19In its budget justification, NPS calls these funding streams discretionary and mandatory
appropriations. It uses “discretionary appropriations” to refer to funding that comes from
the annual appropriations process while it uses “mandatory appropriations” to refer to
funding that includes fees and donations. Mandatory amounts typically refer to the level of
budget authority, outlays, or other budgetary resources that are controlled by laws other
than appropriations acts.
20At a specific site or area, these fees shall only be used for repair, maintenance, and
facility enhancement related directly to visitor enjoyment, visitor access, and health and
safety; interpretation, visitor information, visitor service, visitor needs assessments, and
signs; habitat restoration directly related to wildlife-dependent recreation that is limited to
hunting, fishing, wildlife observation, or photography; law enforcement related to public
use and recreation; direct operating or capital costs associated with the recreation fee
program; and a fee management agreement established under section 6805(a) or a visitor
reservation service. Pub. L. No. 108-447, div. J. tit. VIII, 118 Stat. 2809, 3377 (2004)
codified as amended at 16 U.S.C. §§ 6801-6814.

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area of federal land management shall remain available for
expenditure at that park. The Secretary of the Interior may determine
the need for a reduction in that percentage, but not below 60 percent
of these revenues may be retained by a park. Recreation fees
represented approximately 6 percent of NPS’s enacted budget in
fiscal year 2021.

U.S. Citizenship and
Immigration Services

•

Concession franchise fees. The National Park Service Concessions
Management Improvement Act of 1998 authorizes NPS to collect and
use franchise fees from concessioners who operate restaurants,
lodges, and other business operations inside parks. 21 These fees are
generally assessed as a percentage of the concessioners’ total gross
receipts. Concession franchise fees represented about 2 percent of
NPS’s enacted budget in fiscal year 2021.

•

Donations. NPS is authorized by law to receive and use cash
donations from individuals, nonprofit organizations, and
corporations. 22 Cash donations represented approximately 1 percent
of NPS’s enacted budget in fiscal year 2021.

•

Other miscellaneous charges. These other charges include
transportation fees NPS collects to operate public transportation
systems in parks; rents collected for employee housing; rents for
leases of buildings and associated property to businesses, individuals,
and government entities; and funding from Treasury for certain
pension payments for U.S. Park Police annuitants. NPS also collects
fees for commercial use authorizations, which include small-scale
commercial activities, such as leading workshops or tours. These
other funding sources accounted for approximately 16 percent of
NPS’s enacted budget in fiscal year 2021.

USCIS, an agency component of the Department of Homeland Security,
is responsible for administering the federal government’s immigration
services function. USCIS is charged with adjudicating applications and
petitions for immigration benefits, such as humanitarian relief, adjustment
to lawful permanent resident status, change or extension of nonimmigrant
(i.e., visitor) status, and naturalization. USCIS processes millions of such
immigration benefit and other requests, including for employment
authorization, each year; and provides services such as immigration
21Pub. L. No. 105-391, tit. IV, 112 Stat. 3497, 3503 (1998), codified as amended at 54

U.S.C. §§ 101911-101926.

2254 U.S.C. §§ 100725, 101101.

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status verification for federal, state and local public benefit-granting
agencies, and resources for new residents and citizens.
To fund the cost of processing and adjudicating applications and
associated support services, USCIS charges a variety of fees.
•

Immigration Examinations Fee Account (IEFA). This account
comprises USCIS fee collections from two sources: (1) fees collected
for processing applications for immigration benefits (i.e., non-premium
processing fees), which USCIS uses to fund program operations; and
(2) premium processing fees collected for expedited review of certain
applications. 23 Revenues from IEFA accounted for approximately 96
percent of USCIS’s enacted budget for fiscal year 2021.

•

Fraud Prevention and Detection Fee. The Department of Homeland
Security imposes this fee on nonimmigrant petitioners to fund the
costs of activities related to preventing and detecting fraud for all
immigration benefit types, including efforts to oversee and enhance
policies and procedures pertaining to the performance of law
enforcement background checks on applicants and petitioners. 24 The
Department of Homeland Security receives one-third of the revenue,
and the remaining revenue is shared between the Department of
Labor and the Department of State. Revenues from this account
represented about 1 percent of USCIS’s enacted budget for fiscal
year 2021.

•

H-1B Nonimmigrant Petitioner Fee. This fee is imposed on an
employer, excluding employers of certain educational institutions, for
certain petitions for nonimmigrant workers under the H‐1B program. 25
The Department of Homeland Security receives 5 percent of the H‐1B
Nonimmigrant Petitioner Fee collections; the remaining amount is
shared between the Department of Labor and the National Science

23The Immigration and Nationality Act, as amended, directs USCIS to deposit all
adjudication fees into the IEFA. 8 U.S.C. § 1356(m). USCIS may set fees for providing
adjudication services at a level that will ensure recovery of the full costs of providing all
such services, including the costs of adjudication services provided without charge to
certain immigrants, such as those seeking asylum in the U.S., and any additional costs
associated with the administration of the fees collected. As such, Congress has
permanently appropriated amounts collected for these purposes. The Immigration and
Nationality Act, as amended, sets the premium processing fee at $2,500, except that the
premium fee for a petition for classification of a nonimmigrant described in subparagraph
(H)(ii)(b) or (R) of section 1101(a)(15) of the act shall be $1,500. 8 U.S.C. § 1356(u).
248 U.S.C. § 1184(c)(12)-(13), 1356(v).
258 U.S.C. § 1184(c)(9), (11), 1356(s).

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Foundation. In fiscal year 2021, revenues from this account
represented approximately 0.4 percent of USCIS’s enacted budget.

Executive Branch
Agencies’ Revenues
from Dedicated User
Fees Declined during
the COVID-19
Pandemic
Executive Branch
Agencies’ Dedicated User
Fee Revenues Fell
Starting in March 2020
and Remained Lower
Than Average into 2021

Executive branch agencies’ revenues from dedicated user fees were
lower in fiscal year 2020 and in the first half of fiscal year 2021 compared
to average revenues collected during comparable periods from fiscal
years 2017 through 2019, the 3 fiscal years prior to the beginning of the
COVID-19 pandemic. 26 Specifically:
•

In fiscal year 2020, total revenues ($96.5 billion) were about 6 percent
(or $6.7 billion) lower than the average total revenues in fiscal years
2017 through 2019 ($103.2 billion).

•

In the first half of fiscal year 2021 (October 2020 through March
2021), total revenues ($42.7 billion) were about 8 percent (or $3.5
billion) lower than the average total revenues in the first half of fiscal
years 2017 through 2019 ($46.2 billion), and about 16 percent (or
$8.2 billion) lower than the total revenues in the first half of fiscal year
2020 ($50.8 billion).

During the first 5 months of fiscal year 2020 (October 2019 through
February 2020), executive branch agencies’ revenue from dedicated user
fees largely followed trends from previous years. However, starting in
March 2020, when the federal government declared the COVID-19
pandemic a national emergency, executive branch agencies collected
lower-than-average amounts of these revenues. Dedicated user fee
revenues in May 2020 were particularly low in comparison to previous
years, with revenues approximately 65 percent lower than the average
May revenue in fiscal years 2017 through 2019. This trend continued
26In order to determine how revenues during the pandemic compared to revenues prior to

the pandemic, we compared fiscal year 2020 and 2021 revenue data to the average
revenues from the 3 years prior to the pandemic (fiscal years 2017 through 2019).

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through the second half of fiscal year 2020, with the exception of August
2020, when revenues slightly exceeded the previous 3-year average, as
shown in figure 1.
Figure 1: Executive Branch Agencies’ Monthly Revenue from Dedicated User Fees, Fiscal Year 2020 Compared to Average
Dedicated User Fee Revenue from Fiscal Years 2017 through 2019

Notes: Due to the government shutdown that occurred from December 22, 2018, through January 25,
2019, the Department of the Treasury cancelled the reporting requirement for January 2019, resulting
in zero revenue reflected for that month. The average value for that period is therefore smaller than it
might have otherwise been without a government shutdown. For instance, the average dedicated
user fee revenue across fiscal years 2017 and 2018 was approximately $6.1 billion, compared to the
$4.1 billion average from fiscal years 2017 through 2019.
Because the Department of the Treasury does not require agencies to submit revenue data for
October, we split revenue reported in November evenly across October and November to avoid
having artificially high revenue reflected in this graph.

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On average, for fiscal years 2017 through 2019, the amount of dedicated
user fee revenue increased in each quarter. In fiscal year 2020, however,
revenues decreased in the third quarter (April through June 2020), just
after the U.S. government declared the COVID-19 pandemic a national
emergency.
During the third quarter of fiscal year 2020, total dedicated user fee
revenues across executive branch agencies were lower than the previous
3-year third quarter average by about 39 percent, or approximately $10.0
billion. These revenues were also lower in the fourth quarter of fiscal year
2020 compared to the previous 3-year average for that quarter by about 4
percent, or approximately $1.4 billion. In the first two quarters of fiscal
year 2021, revenues remained lower than quarterly revenues collected in
2020 and average quarterly revenues collected from 2017 through 2019
(see fig. 2).

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Figure 2: Executive Branch Agencies’ Quarterly Revenue from Dedicated User
Fees, Fiscal Years 2020 and 2021 Compared to Average Dedicated User Fee
Revenue from Fiscal Years 2017 through 2019

Notes: Due to the government shutdown that occurred from December 22, 2018, through January 25,
2019, the Department of the Treasury cancelled the reporting requirement for January 2019, resulting
in zero revenue reflected for that month. Despite this, the average value for that second quarter is
similar to what it might have otherwise been without a government shutdown. For instance, the
average dedicated user fee revenue in the second quarter of fiscal years 2017 through 2019 was
approximately $24.7 billion, compared to the $24.4 billion average across fiscal years 2017 and 2018.
Fiscal year 2021 data include revenue through March 31, 2021, or through the end of the second
quarter, the most recent data available at the time of our analysis.

In fiscal year 2021, dedicated user fee revenue continued to be generally
lower in comparison to average revenues from fiscal years 2017 through

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2019. Revenues for fiscal year 2021 were lower than fiscal year 2020
revenues in all 6 months with available data, and lower than the average
fiscal year 2017 through 2019 revenues for 5 of the 6 months with
available data, as shown in figure 3.
Figure 3: Executive Branch Agencies’ Monthly Revenue from Dedicated User Fees, First Half of Fiscal Years 2020 and 2021
Compared to Average Dedicated User Fee Revenue from Fiscal Years 2017 through 2019

Notes: Due to the government shutdown that occurred from December 22, 2018, through January 25,
2019, the Department of the Treasury cancelled the reporting requirement for January 2019, resulting
in zero revenue reflected for that month. The average value for that period is therefore smaller than it
might have otherwise been without a government shutdown. For instance, the average dedicated
user fee revenue across fiscal years 2017 and 2018 was approximately $6.1 billion, compared to the
$4.1 billion average from fiscal years 2017 through 2019.

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Because the Department of the Treasury does not require agencies to submit revenue data for
October, we split revenue reported in November evenly across October and November to avoid
having artificially high revenue reflected in this graph.

A Majority of Executive
Branch Agencies’
Dedicated User Fee
Revenue Declined in
Fiscal Year 2020,
Particularly in the Third
Quarter

Dedicated user fee revenue declined in fiscal year 2020 for most of the 25
executive branch agencies that collected these revenues. Specifically, 16
of these 25 agencies collected lower revenues from dedicated user fees
in fiscal year 2020 compared to the previous 3-year average, while seven
agencies collected higher revenues. Two agencies had no revenue from
dedicated user fees in fiscal years 2017 through 2019.
Some agencies had smaller declines in dedicated user fee revenue on an
annual basis, but had much more severe declines on a quarterly basis.
For example, the Department of Transportation had an approximately 11
percent decline in revenue in fiscal year 2020 compared to the previous
3-year average. However, in the third quarter (April 2020 to June 2020),
Transportation had about a 63 percent decline in dedicated user fee
revenue from the second quarter (January 2020 to March 2020). In
comparison, its dedicated user fee revenue increased by about 3 percent,
on average, from the second to third quarters in fiscal years 2017 through
2019. Overall, 18 of 25 executive branch agencies had dedicated user fee
revenue declines from quarters 2 to 3 in fiscal year 2020, while seven
agencies had increases.
Across all of the 25 executive branch agencies that collected dedicated
user fee revenue in fiscal year 2020, there were 118 unique dedicated
user fee accounts that had dedicated user fee revenue in fiscal years
2017 through 2019. 27 Of these accounts, 56 percent (66 accounts) had
lower revenues from dedicated user fees in fiscal year 2020 compared to
the previous 3-year average. Some dedicated user fee accounts did not
have overall declines in fiscal year 2020, but had revenue changes in the
third quarter following the onset of the COVID-19 pandemic. For example,
Transportation’s highest revenue-generating dedicated user fee account
was the Highway Trust Fund. This account’s revenues increased by
about 1 percent in fiscal year 2020 compared to the previous 3-year
average, but declined by about 45 percent from the second to third
quarter of fiscal year 2020.

27An additional six accounts did not have dedicated user fee revenue in fiscal years 2017
through 2019.

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Selected Agencies’
Dedicated User Fee
Revenues Decreased
after the Onset of the
Pandemic
Gross Receipts That Fund
FAA Fell during the
Pandemic Due to a Tax
Holiday and Decreased Air
Travel Demand

In fiscal year 2020, the Airport and Airway Trust Fund (AATF)—which
funds most of FAA’s operations, investments, and grants—had gross
receipts totaling approximately $9 billion, according to Monthly Treasury
Statement data. 28 This amount was $6.8 billion (43 percent) lower than
gross AATF receipts in fiscal year 2019, according to Monthly Treasury
Statement data, as seen in figure 4. 29

28In fiscal year 2020, approximately 97 percent of FAA’s annual budget was appropriated

from the AATF. This percentage excludes amounts appropriated to FAA by the CARES
Act.

29Congress appropriated $14 billion to the AATF from general revenues in October 2020.
Continuing Appropriations Act, 2021 and Other Extensions Act, Pub. L. No. 116-159, §
1204, 134 Stat. 709, 728 (2020). The additional funding ensured that FAA operations
could continue despite the decreases in excise tax collections, according to FAA officials.

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Figure 4: Airport and Airway Trust Fund Gross Receipts, Fiscal Years 2019 and 2020

Notes: Gross receipts represent the total amount received by the U.S. government without regard to
refunds or other offsets, for the month.
According to Federal Aviation Administration officials, some spikes in revenue are due to the Bureau
of the Fiscal Service’s quarterly certification of excise tax amounts collected into the Airport and
Airway Trust Fund. For example, the February 2020 spike was the result of an approximately $1.46
billion upward adjustment for the quarter ending September 2019, according to officials. Similarly,
negative revenue in May 2020 was the result of a downward adjustment of $150 million for the
quarter ending December 2019.

On March 27, 2020, the CARES Act established a tax holiday for the
remainder of 2020 for four of the six excise taxes that fund the AATF—
transportation of persons by air, transportation of property by air, aviation

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fuel for commercial use, and use of international air facilities. 30 Receipts
for these four excise taxes totaled approximately $7.1 billion in fiscal year
2020, or about 59 percent lower than the $17.4 billion collected in fiscal
year 2019. These excise taxes collectively accounted for about 99
percent of fiscal year 2019 AATF gross excise tax collections.
Demand for air travel decreased during the pandemic, and this decreased
demand continued into 2021 after the tax holiday expired on December
31, 2020, resulting in lower-than-usual excise tax revenues and
potentially fewer AATF funds available for future appropriations to FAA in
fiscal year 2022 and beyond, according to FAA officials. Figure 5 shows
the 7-day average number of people who passed through Transportation
Security Administration airport checkpoints from January 2019 to June
2021.

30Pub. L. No. 116-136, tit. IV, § 4007, 134 Stat. at 477, codified at 15 U.S.C. § 9046.

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Figure 5: Seven-Day Average of Transportation Security Administration Airport Checkpoint Numbers, Jan. 2019 to June 2021

Note: We obtained Transportation Security Administration checkpoint travel numbers from
https://www.tsa.gov/coronavirus/passenger-throughput, accessed July 20, 2021.

AATF revenues have increased in 2021, compared to 2020, due to both
the expiration of the excise tax holiday and increased demand for air
travel. However, average annual domestic airfare receipts dropped from
$352.27 in 2019 to $292.20 in 2020, indicating that revenues may not
fully recover until airfares also recover, even with increased demand for

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air travel. 31 Figure 6 shows that AATF gross receipts following the
expiration of the tax holiday on December 31, 2020, continued to be lower
than gross receipts prior to the implementation of the tax holiday on
March 27, 2020.
Figure 6: Airport and Airway Trust Fund Gross Receipts, Oct. 2019 through Apr. 2021

Notes: On March 27, 2020, the CARES Act established a tax holiday for certain excise taxes that
fund the Airport and Airway Trust Fund. This tax holiday expired on December 31, 2020. Pub. L. No.
116-136, tit. IV, § 4007(c), 134 Stat. 281, 477 (2020), codified at 15 U.S.C. § 9046(c).
Gross receipts represent the total amount received by the U.S. government without regard to refunds
or other offsets, for the month.

31Bureau of Transportation Statistics, Airline Origin & Destination Survey, Average

Domestic Airline Itinerary Fares, accessed July 19, 2021,
https://www.transtats.bts.gov/AVERAGEFARE/.

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According to Federal Aviation Administration officials, some spikes in revenue are due to the Bureau
of the Fiscal Service’s quarterly certification of excise tax amounts collected into the Airport and
Airway Trust Fund. For example, the February 2020 spike was the result of an approximately $1.46
billion upward adjustment for the quarter ending September 2019, according to officials. Similarly,
negative revenue in May 2020 was the result of a downward adjustment of $150 million for the
quarter ending December 2019.

The impact of the COVID-19 pandemic was unprecedented, according to
FAA officials. For example, U.S. airlines carried 96.3 percent fewer
scheduled service passengers in April 2020 than in April 2019, according
to the Bureau of Transportation Statistics. The agency also reported that
U.S. airlines carried 557 million fewer passengers in 2020 than in 2019,
down 60 percent year-to-year.

NPS Revenues
Decreased in Spring 2020
and Are Expected by NPS
Officials to Be Lower Than
Usual through Fiscal Year
2021

NPS revenues from dedicated user fees—those from recreation and
concession franchise fees—were down overall in fiscal year 2020, despite
being higher than fiscal year 2019 revenues in the months prior to March
2020. The primary contributor to reductions in recreation and concession
franchise fee revenues in fiscal year 2020 was the change in consumer
demand due to the COVID-19 pandemic, according to NPS officials.
Unlike natural disasters that may affect some parks, the pandemic
affected the entire park service, and NPS officials described the
pandemic’s disruption to operations and revenue as “substantial.”
Recreation fees. Prior to the start of the pandemic, fiscal year 2020
recreation fee revenues from October 2019 through February 2020 ($93.5
million) were higher than the same period in fiscal year 2019 ($70.4
million). In fiscal year 2020 overall, however, NPS collected $243 million
in revenue from recreation fees. This amount was about 29 percent lower
than projected fiscal year 2020 collections ($344.6 million) and about 22
percent lower than fiscal year 2019 collections ($309.9 million). According
to NPS officials, the lower revenue resulted in fewer funds available for
the execution of projects and program management at NPS parks.
Even with lower dedicated user fee revenues across the agency in fiscal
year 2020, some NPS parks collected increased recreation fee revenues
depending on location, according to NPS officials. Recreation fee
revenues are driven by park visitation, and consumer demand varies by
park, according to NPS officials. For example, these officials told us that
some NPS parks have been particularly affected by revenue loss, while
others have seen higher-than-ever demand for activities such as boating
or camping. These increases in recreation fee revenues were potentially
due to higher demand for outdoor activities during the COVID-19
pandemic.

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NPS expected fiscal year 2021 recreation fee revenues to be similar to
fiscal year 2020 revenues. In the first half of fiscal year 2020, however,
recreation fee revenues were higher in some months than revenues for
those months in fiscal year 2019, as shown in figure 7.
Figure 7: National Park Service Recreation Fee Revenue, Oct. 2018 through Mar. 2021

Note: According to National Park Service officials, negative recreation fee revenue in April 2020 was
due to mass recreation.gov refunds from facility closures due to the Coronavirus Disease 2019
pandemic.

Concession franchise fees. From October 2019 to February 2020, NPS
collected $42.6 million in concession franchise fee revenue. This amount
was 8.3 percent higher than concession franchise fee revenues collected
during the same period in fiscal year 2019 ($39.4 million). By March 2020,

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however, concession franchise fee revenues were lower than in fiscal
year 2019, a trend that continued for the remainder of fiscal year 2020.
These revenues totaled $69.8 million in fiscal year 2020. This amount
was about 50 percent lower than projected fiscal year 2020 collections
($138.4 million) and about 48 percent lower than fiscal year 2019
collections ($134.3 million). Overall, concession franchise fee revenues
have generally been lower than in fiscal year 2019 since the pandemic
began, and NPS expects these revenues to remain lower than fiscal year
2019 revenues for the next few fiscal years. Figure 8 shows concession
franchise fee revenue for fiscal years 2020 and 2021, through March
2021, compared to concession franchise fee revenues for fiscal year
2019.
Figure 8: National Park Service Concession Franchise Fee Revenue, Oct. 2018 through Mar. 2021

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Concession franchise fee revenues are based on concessioners that
operate hospitality and recreation services in NPS parks. Public health
regulations aimed at reducing the spread of COVID-19 affected NPS
concessioners, according to NPS officials, including limited capacity in
visitor centers and indoor dining restrictions. According to NPS officials,
these changes have contributed to less revenue from concessions
operations, resulting in fewer concession franchise fee revenues for NPS.
NPS collected nearly 50 percent of its annual concession franchise fee
revenue in the last quarter of each fiscal year from 2015 through 2019.
Because of this, parks typically spend money that they collected in the
prior fiscal year to maintain operations early in a new fiscal year,
according to NPS officials. In fiscal year 2020, however, NPS collected
only about 30 percent of its concession franchise fee revenue in the last
quarter. According to NPS officials, the agency will face uncertainty over
the coming years about whether concession franchise fee revenues and
spending will remain lower than normal.

USCIS Had Immediate
Revenue Declines during
the Pandemic, but
Revenues Have Largely
Recovered

USCIS revenues from dedicated user fees initially decreased following
the declaration of the COVID-19 national emergency. Some of these
revenue decreases were due to travel restrictions imposed by the U.S.
and other countries following the emergency declaration and USCIS field
office closures, according to USCIS officials.
The largest revenue decreases for USCIS’s dedicated user fees occurred
at the beginning of the pandemic when overall revenues decreased by
about 40 percent. This decrease persisted for approximately 6 weeks in
March to May 2020, according to USCIS officials, with the lowest
revenues of the pandemic occurring in April 2020. Even with this dip in
revenue, USCIS collected fee revenue between June 2020 and March
2021 that was generally equal to or higher than revenues from June 2019
through March 2020, as shown in figure 9.

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Figure 9: U.S. Citizenship and Immigration Services Fee Revenue, Oct. 2018 through Mar. 2021

Revenue for USCIS’s Immigration Examinations Fee Account (IEFA), the
agency’s largest fee account, decreased from $354.9 million in March
2020 to $209.6 million in April 2020, a drop of about 41 percent. While
IEFA revenues initially fell, they began to increase in May 2020 and
reached fiscal year 2019 levels in June 2020, as shown in figure 10.

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Figure 10: U.S. Citizenship and Immigration Services Immigration Examinations Fee Account Revenue, Mar. 2020 through
Feb. 2021 Compared to Mar. 2019 through Feb. 2020

While overall IEFA revenues were close to pre-pandemic levels by June
2020, recovery differed between non-premium IEFA revenues (i.e.,
revenue from fees collected for processing applications for immigration
benefits) and premium IEFA revenues (i.e., revenue from fees collected
for expedited review of certain applications). For example, non-premium
IEFA revenue from October 2020 to March 2021 totaled $1.7 billion. This
was $ 228.5 million (15.6 percent) higher than the $1.47 billion in
projected revenue for that period.
While non-premium IEFA revenues had been higher than forecasted from
October 2020 through March 2021, premium IEFA revenues during this
period ($344.7 million) were approximately 16 percent lower than forecast
($410.1 million). USCIS officials primarily attributed this to Presidential
Proclamations issued in 2020 suspending the entrance of non-immigrant

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workers into the U.S. through March 2021, which resulted in fewer nonimmigrant application filings with USCIS. 32 According to USCIS officials,
such non-immigrant applications drive premium processing fees and
revenue. These officials said that although deviations from IEFA premium
revenue forecasts were large, they were within historical ranges.
Revenue changes at USCIS also varied among the agency’s
approximately 100 forms. Some USCIS forms had increased submissions
during the pandemic. For example, USCIS received an influx of I-539
forms, Application to Extend/Change Nonimmigrant Status, because the
COVID-19 pandemic prevented people from traveling home to their
countries of origin, according to USCIS officials.
Conversely, the immigrant visa workload decreased during the pandemic,
according to USCIS officials. These officials told us that individuals
seeking to immigrate to the U.S. would typically obtain a visa abroad from
an embassy or consulate and then travel to the U.S. However, since the
pandemic prevented most international travel, these types of immigrant
visas decreased by over 90 percent, according to USCIS officials.

Selected Agencies Had
Both Incidental Cost
Savings and Additional
Expenses as a Result of
the COVID-19 Pandemic

Officials at all three selected agencies said they had marginal cost
savings related to the pandemic, such as decreased costs for travel.
Similarly, all three agencies incurred marginal expenses related to the
pandemic, including personal protective equipment, enhanced cleaning
services, and new signage, according to agency officials.
FAA officials told us the drop in air traffic since the pandemic began had
little effect on FAA’s costs, other than lower overtime costs because FAA
did not staff at the levels it typically does for peak travel seasons. FAA did
incur additional costs for expenses such as enhanced cleaning services
in its buildings. Officials said that, although there has been some cost
variation over time, these additional savings and costs generally offset
each other.
According to NPS officials, the pandemic resulted in a general reduction
in travel costs, but the agency incurred additional costs for expenses such
32See, for instance, Executive Office of the President, Suspension of Entry as Immigrants

and Nonimmigrants of Persons Who Pose a Risk of Transmitting 2019 Novel Coronavirus
and Other Appropriate Measures To Address This Risk, Proclamation 9984, 85 Fed. Reg.
6709 (Feb. 5, 2020); and Suspension of Entry as Immigrants and Nonimmigrants of
Certain Additional Persons Who Pose a Risk of Transmitting 2019 Novel Coronavirus,
Proclamation 9993, 85 Fed. Reg.15045 (Mar. 16, 2020).

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as additional signs to inform park visitors of social distancing
requirements during the pandemic (see fig. 11), personal protective
equipment for staff, and Plexiglas barriers to separate and protect staff
and visitors.
Figure 11: Sign to Promote Social Distancing in Great Falls Park, Virginia

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USCIS had some cost savings associated with travel and training during
the pandemic, as well as additional costs as a direct result of the
pandemic, according to USCIS officials. These officials said the pandemic
eliminated most travel and training at USCIS, as spending on these items
declined due to health concerns related to the pandemic. USCIS’s
additional costs ranged across a wide variety of services, equipment, and
supplies such as personal protective equipment, facility cleaning, air
filters for buildings, and Plexiglas barriers for interview and customer
service counters, according to officials. These officials said that, as of
May 28, 2021, USCIS had obligated and expended $19.9 million for costs
specifically related to the pandemic since it started tracking such costs on
February 20, 2020.

Selected Agencies
Enhanced Revenue
Monitoring and
Processes for Making
Projections during the
Pandemic
FAA Developed Revenue
Projection Processes to
Monitor Cash Flow and
Activities during the
Pandemic

Prior to the pandemic, FAA relied on Treasury’s Office of Tax Analysis to
project AATF revenues, according to FAA officials. 33 These officials told
us they closely monitored the revenues and cash balances of the AATF
prior to the pandemic for two general purposes:
•

Recommending to Congress an allocation between the AATF and
general revenues. In order to do that, officials said they need a
sense of what the AATF balances are and what they are likely to be.

•

Internal control over financial recording. Although FAA does not
record excise tax receipts, agency officials said they have a
responsibility to oversee their agency’s financial statements, and to
follow up on anything that seems irregular.

33According to FAA officials, Treasury took responsibility for AATF revenue projections in

2011 to align with its projections responsibilities for other agencies. FAA does not manage
the collection of revenues that support the AATF, as Treasury collects those revenues
based on tax provisions written in U.S. law. Pub. L. No. 91-258, § 208, 84 Stat. at 250,
codified at 26 U.S.C. § 9502(b).

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FAA officials told us they also relied on data from Treasury to monitor
actual AATF excise tax receipt figures prior to the pandemic. Treasury’s
Bureau of the Fiscal Service provides data on actual AATF revenues on a
quarterly basis, according to FAA officials. These officials told us that FAA
receives a monthly statement from the Bureau of the Fiscal Service and
has therefore never had “real-time” data on AATF balances. This
limitation did not negatively affect FAA’s financial monitoring prior to the
pandemic, according to FAA officials, even if revenues were less than
Treasury projected, as the trust fund historically had balances large
enough to cover FAA obligations and outlays.
During the pandemic, however, these limitations led FAA to develop its
own internal AATF revenue projections, according to FAA officials.
Officials told us they based their AATF revenue projections for calendar
year 2021 on a wide variety of sources, including
•

airline filings with the U.S. Securities and Exchange Commission;

•

guidance and investor updates from airlines that provide short-term
forecasts of operations, load factors (percent of occupied seats on
flights), and price changes;

•

published data on weekly traffic levels;

•

historical data on AATF revenues;

•

Transportation Security Administration passenger screening statistics;

•

conversations with industry executives; and

•

forecasts from sources such as Moody’s and Standard & Poor’s.

FAA officials told us they also based revenue projections during the
pandemic on assumptions about current and future air traffic levels—
including when air traffic might return to normal levels—to determine how
much the AATF might have been affected by the pandemic after the
expiration of the tax holiday on December 31, 2020. Additionally, during
the pandemic, FAA officials also said that they reviewed AATF balances
in more detail than they had previously. For example, officials reported
that they began calculating the trust fund’s unobligated balances, which

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they said was a more precise measure of available funding than the
uncommitted balance that they had used as a metric in the past. 34

NPS Used Established
Approaches for Evaluating
Revenues and Costs
during the Pandemic

NPS officials told us that prior to the pandemic, they typically examined
planned spending for recreation and concession franchise fee revenues
on an annual basis. For recreation fee revenues, parks conducted an
annual 5-year project prioritization exercise each fiscal year to determine
spending plans, according to NPS officials, and they continued adjusting
these plans as needed throughout the year. Similarly, for concession
franchise fee revenues, NPS headquarters staff typically looked at park
spending plans once a year and engaged with regional and park officials
to update them as needed, according to NPS officials.
During the pandemic, parks began monitoring recreation and concession
franchise fee revenues and evaluating planned projects funded by these
revenues on a more frequent basis than in typical years, according to
NPS officials. These officials said that NPS instructed parks to conduct
their recreation and concession franchise fee revenue and project
prioritization reviews in April 2020 to reevaluate spending priorities. This
iteration of the exercises included a new rating system where parks could
indicate which projects were necessary to continue, which could continue
if additional funding became available, and which could be delayed until
future years, according to NPS officials.
NPS also continued its pre-pandemic process of tracking park revenues
and obligations on a monthly basis during the pandemic, according to
NPS officials. NPS parks did not have a mandate to examine their
revenues more frequently than monthly during the pandemic, but they
had the ability to do so by checking register receipt amounts or
conducting fee deposit reconciliation against data in their accounting
systems, according to NPS officials.
NPS officials said the pandemic reinforced that the processes in place
were valuable and able to be used beyond the annual exercise. For
example, officials said the cash flow tools used to monitor concession
franchise fee revenues helped parks make adjustments as these
revenues changed during the pandemic. NPS officials said the pandemic
34The uncommitted balance is the amount of cash in excess of what is required to cover

future expenditures of unpaid budget authority, or the amount of the AATF cash balance
that is “unclaimed” by existing appropriations, according to an FAA projections document.
The unobligated balance is the amount of budget authority that remains available for
obligation in unexpired accounts.

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demonstrated to park staff that the revenue and project prioritization
processes that rely on local input and knowledge are effective in
emergency situations.

USCIS Reevaluated Its
Revenue Projections
Multiple Times during the
Pandemic
Volume Projection Committee
U.S. Citizenship and Immigration Services
(USCIS) has a Volume Projection Committee
that projects and periodically updates form
application and petition volume estimates for
workforce, resource, and production planning
purposes. For example, the committee
identifies upcoming policy changes that could
affect the number of people applying for
certain forms and will adjust projections
accordingly.
The committee develops and formally reviews
these workload projections at least twice
every fiscal year and disseminates the
projections for public review at least once a
year.
Primary committee membership comprises
representatives from the following USCIS
offices:
•

Service Center Operations Directorate;

•

Field Operations Directorate;

•

Refugee, Asylum and International
Operations Directorate;

•

the Office of the Chief Financial Officer;

•

the Office of Policy and Strategy; and

•

the Office of Performance and Quality.

Source: USCIS Volume Projection Committee charter
document and interviews with USCIS officials. |
GAO-21-104325

After the pandemic began, USCIS had decreases in revenue that led it to
reevaluate its revenue projections more frequently in fiscal year 2020,
according to officials. 35 The agency revised its revenue and workload
projections in April, June, and July 2020 due to uncertainty resulting from
the pandemic. Additionally, officials said that during the pandemic, they
regularly evaluated volume and revenue performance compared to both
forecasted amounts and prior-year actual amounts.
USCIS did not conduct stakeholder consultation with its Volume
Projection Committee for revenue and workload projections during the
pandemic, as it normally would have, according to agency officials. These
officials said that if revised forecasts are determined to be necessary
going forward, USCIS will attempt to consult with a larger range of
Directorates and Program Offices than it was able to in fiscal year 2020.
At that time, the severity and unprecedented nature of the situation
required rapid action by a few critical participants, according to officials.
These officials said they were operating under a crisis mentality to
produce new numbers rapidly during the pandemic, so there was little
time for the typical revision process.
In addition to revising revenue projections more frequently, USCIS
officials told us they monitored and communicated about revenue trends
more frequently during the pandemic. These officials said that prior to the
pandemic, they monitored revenue and communicated this information to
agency leadership on a monthly basis but began doing this weekly during
the pandemic. Having more timely revenue data allowed agency
leadership to make decisions with the most up-to-date information during
the pandemic, according to USCIS officials. Officials told us this practice
would likely continue after the pandemic. Having timely information is
paramount for the agency’s cash flow management as it allows quick
identification of emerging trends, according to USCIS officials. These
officials said they will determine the need to revise projections if revenue
35According to USCIS officials, the agency conducts an annual revenue projection
exercise, focusing on the following fiscal year, and typically does not reevaluate its
projections, which have been within 2 percent of actual collections over the 5 fiscal years
prior to fiscal year 2021. This includes fiscal year 2020, according to officials, which
finished with revenue collections within 1.7 percent of original projections despite
significant revenue dips in April and May 2020.

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substantially differs from projected amounts or if form-filing behavior
undergoes rapid, unexplained changes.
During the pandemic, USCIS also began monitoring non-payroll spending
more closely. Rather than planning one quarter ahead, as it had done
historically, officials said they examined non-payroll spending in 1- or 2month increments during the pandemic to determine which items to
obligate. This increased frequency led agency leadership to examine
funding needs more closely and obligate smaller amounts at a time,
according to USCIS officials. These officials told us that they intended to
reserve as much funding as possible in order to have funds available to
continue operations in case revenue continued to decline.
Officials said that they felt confident in USCIS’s fiscal year 2021 workload
and revenue projections and saw no indication at the time of our review
that additional revisions would be necessary for fiscal year 2021. Based
on their experience during the pandemic, USCIS officials said that the
Volume Projection Committee now considers at each meeting whether
the projections should be revised, which it did not routinely consider prior
to the pandemic.

Two of Three
Selected Agencies
Have Not Reviewed
Certain Monitoring
and Management
Processes Used
during the Pandemic
Selected Agencies’ Efforts
Prioritized Essential
Expenses, but FAA Has
No Formal Review
Process for Cash
Management Plan

In response to revenue declines and instability during the COVID-19
pandemic, all three selected agencies prioritized spending on essential
expenses and either implemented or planned to implement cuts in areas
not deemed mission-critical, as necessary. NPS and USCIS achieved
cost savings by limiting or delaying projects or contracts.
FAA. In response to the pandemic, FAA drafted a cash management plan
that it could have used during the pandemic in the event Congress had
not provided an appropriation, according to agency officials. The plan

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contained measures to help FAA carry out mission-critical functions in a
time of AATF revenue instability. FAA planned to implement the cash
management plan in October 2020 absent any appropriation from
Congress, according to agency officials. These officials told us FAA
developed the plan in coordination with the Department of Transportation
and the Federal Highway Administration, incorporating lessons learned
from the Federal Highway Administration’s existing cash management
plan for the Highway Trust Fund.
Each step in the cash management plan featured potential actions that
FAA would have taken to manage obligations and cash during a period
when the AATF’s revenues and balances declined. For example, the plan
included an option to minimize obligations that were not mission-critical,
with the intent of making funds available to cover payroll. According to
FAA officials, many individual components of the plan were relatively
small compared to the payroll expense and would have taken time to
have any effect on the agency’s cash availability. The cash management
plan also described the possible need to operate in a “shutdown” mode
similar to what happens when there is a lapse in appropriations and
authorization. This option would have been triggered when the AATF
cash balance reached a level that was insufficient to make new
obligations.
Agency officials told us they had internal discussions about implementing
the initial phases of the plan prior to October 2020 based on AATF
projections. However, they said that they delayed execution of the plan
because discussions with Congress indicated that the AATF was likely to
receive additional funding. According to these officials, FAA ultimately did
not need to use its cash management plan because Congress
appropriated additional funding to the AATF at the beginning of October
2020. 36
FAA officials explained that the cash management plan we reviewed
represented the circumstances and the agency’s options and priorities at
the time they drafted the plan. While FAA drafted this plan in direct
response to the COVID-19 pandemic, FAA officials told us they planned
to reassess the cash management plan to determine whether the plan
reflects the best options for FAA to address any potential future periods of
revenue instability. These officials said that doing so would better prepare
the agency if it needs to activate the plan in the future and noted that the
36See Pub. L. No. 116-159, § 1205, 134 Stat. at 728.

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plan should offer a number of options for officials to consider, depending
upon the situation.
FAA and Department of Transportation officials stressed that each
potential period of revenue instability requires its own set of options and
priorities. A senior Department of Transportation official also told us that
the cash management plan would need to be customized for any future
period of revenue instability. This official said that going through the
planning process in advance of any periods of revenue instability would
help protect internal controls at FAA. A senior FAA official from the Office
of Finance and Management told us that the agency may review the cash
management plan in fall 2021 and annually thereafter to help ensure it
aligns with leadership priorities. However, the agency does not have any
formal written plans or timeframes in place for conducting such a review,
in part because the additional appropriation into the AATF reduced the
imminent risk of revenue instability, according to FAA officials.
Standards for Internal Control in the Federal Government state that
agencies should implement control activities—procedures, techniques,
and mechanisms—through policies, in part by documenting and
periodically reviewing those policies. 37 For example, agencies can
document the offices responsible for assessing policies and procedures,
such as those found in FAA’s cash management plan. Agencies can also
periodically review policies and procedures for continued relevance and
effectiveness in addressing related risks, as well as document the
planned timing of those reviews.
Additionally, Congress, OMB, or other entities may change an agency’s
objectives or how an agency achieves those objectives, according to
Standards for Internal Control in the Federal Government. The agency
can then consider these changes in its periodic review of policies. By
developing and documenting processes for reviewing its cash
management plan to align with leadership priorities, FAA can better
prepare for and respond to potential future periods of revenue instability.

37GAO-14-704G.

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National Parks Deferred Projects and Made
Staffing Changes to Curtail Spending
During the Pandemic
•

Grand Teton National Park officials told
us they deferred a paving project in fiscal
year 2020 that would have been funded
with recreation fee revenue, after
determining that they could return to the
project the following year without an
adverse effect.

•

Yosemite National Park officials told us
they made staffing decisions based on
available recreation fee revenue in fiscal
year 2020.

•

Statue of Liberty National Monument
officials told us they did not hire any
summer staff and curtailed all permanent
hiring.

Source: National Park Service information. |
GAO-21-104325

NPS. To address revenue declines during the pandemic, NPS used its
existing cash flow analyses to prioritize spending at individual parks for
critical projects and staffing, according to NPS officials. These officials
said the agency’s use of cash flow plans at the park level allowed parks to
prioritize projects and identify those that could be deferred until
collections returned to normal levels.
These officials told us that the projects that parks prioritized tended to
relate to essential activities like maintenance, repairs, and custodial
services. Deferred projects included activities such as research studies,
printing park publications, or non-essential maintenance of trails or
boundary fences. In addition to deferring projects, some parks
implemented reductions or delays in staffing or contracts in the face of
decreased visitation and revenue declines during the pandemic.
USCIS. In response to revenue declines and uncertainty caused by the
pandemic, USCIS officials told us that they evaluated anticipated
expenses and prioritized those that would enable the agency to continue
providing the services that support its core mission. During the pandemic,
USCIS prioritized payroll—which accounts for 50 percent of the agency’s
budget—and other mission-critical expenses, such as rents, utilities,
leases, and physical security costs, according to USCIS officials. For all
other costs, USCIS implemented a spending freeze, expending funds on
an as-needed basis in the third and fourth quarters of fiscal year 2020.
USCIS officials told us they initially determined they would need to
furlough staff to maintain solvency after examining revenue projections
alongside essential spending. They developed a register of staff they
planned to furlough, and in June 2020 sent furlough notices to
approximately 13,400 affected employees. USCIS postponed its formal
furlough plans, and eventually cancelled them in August 2020, as a
combination of revenues returning to normal levels and cost-saving
measures improved the agency’s financial situation.
USCIS achieved significant cost savings through contract reductions and
the implementation of a hiring freeze that was in place from May 2020 to
April 2021, according to agency officials. In fiscal year 2020, USCIS
officials conducted a review of the entire contract portfolio to identify and
prioritize funding for contracts that provided the most critical missionessential services, such as information technology contracts to maintain
operations and secure networks and case management systems.
Through a combination of contract delays and reductions, USCIS’s net
obligations on contracts in fiscal year 2020 were approximately $500

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million less than in fiscal year 2019, according to USCIS officials. Figure
12 shows these and other cost-cutting actions USCIS took to manage
revenue instability during the COVID-19 pandemic.
Figure 12: Timeline Depicting Major Cost-Cutting Actions Taken by U.S. Citizenship and Immigration Services during the
COVID-19 Pandemic

Note: The Emergency Stopgap USCIS Stabilization Act was enacted within the Consolidated
Appropriations Act, 2021 and Other Extensions Act. Pub. L. No. 116-159, div. D, tit. I, 134 Stat. 709,
738 (2020).

Selected Agencies Sought
to Increase Available
Funds and Operational
Flexibilities during the
COVID-19 Pandemic

As selected agencies had declines in revenue during the COVID-19
pandemic, they each—to a varying extent—sought new flexibilities or
funding.
FAA. FAA officials said they worked with Congress on addressing the
AATF’s revenue instability during the pandemic using alternate funding.
These officials said that when FAA’s tracking of the AATF suggested the
balance could drop to zero in fiscal year 2021, the agency consulted with,

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and provided technical assistance to, Congress to identify a solution.
According to FAA officials, Congress developed various proposals and
ultimately appropriated $14 billion from general revenues to the AATF. 38
These officials told us the $14 billion will support FAA’s activities and
accounts through all of fiscal year 2021 and into fiscal year 2022, thus
mitigating the forecasted revenue instability.
With the combined effects of the public health emergency and the tax
holiday, fiscal year 2020 was the first time that the AATF had a decrease
in receipts that was both significant and sudden enough that Congress
could not address the source of FAA’s funding through its annual
appropriations process, according to FAA officials. The passage of the
CARES Act tax holiday on March 27, 2020, occurred soon after FAA’s
fiscal year 2020 appropriations became law (December 20, 2019) and the
agency delivered its fiscal year 2021 budget request to Congress
(February 10, 2020).
Because of this timing, AATF revenue instability resulting from the
pandemic would not have been addressed for at least half a year during
the fiscal year 2021 appropriations process, according to FAA officials.
Instead, Congress remediated the AATF’s revenue decline through a
general revenue additional appropriation to the trust fund. FAA officials
said they will continue to monitor the outlays, receipts, and cash balances
of the AATF and recommend an appropriate general revenue share of
funding in the annual President’s Budget request to Congress going
forward.
NPS. To address revenue declines during the pandemic, NPS sought
additional funds for one park to cover security-related expenses that
would normally be funded by revenue from fees, according to agency
officials. These officials told us they worked with the Department of the
Interior to obtain $7.9 million in funding for Statue of Liberty National
Monument through the department’s CARES Act appropriation for these
expenses. 39 These security services comprise more than half of the
park’s operating budget from fee revenue, according to NPS officials, and
are normally supported by fees from concessioners.
NPS officials told us the CARES Act funding the Department of the
Interior allocated to the park was vital in addressing the park’s significant
38Pub. L. No. 116-159, div. B, tit. II, § 1205, 134 Stat. at 728.
39Pub. L. No. 116-136, 134 Stat. at 547.

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revenue declines during the pandemic. NPS officials said they planned to
communicate the agency’s budgetary priorities to Congress through the
President’s Budget request, to address additional needs resulting from
the pandemic in the long term.
USCIS. USCIS officials said they worked with Congress in summer 2020
on legislation to allow flexibilities in the use of revenues from premium
processing fees, which agency officials said helped them manage
revenue declines during the pandemic. 40 Congress granted these
flexibilities in the Emergency Stopgap USCIS Stabilization Act. 41 The law
increased the premium processing fee amounts, expanded the number of
forms eligible for premium processing, and provided additional flexibilities
on the purposes for which premium processing funds can be used.
USCIS officials said they would continue to address future fund
availability through timely biennial fee reviews, as required by OMB
Circular No. A-25.

Selected Agencies Relied
on Carryover and Cash
Balances during the
Pandemic, but NPS Has
Not Completed a Planned
Review of Target Balances

With decreased incoming revenues from dedicated user fees during the
pandemic, selected agencies relied to varying degrees on existing cash
balances carried over from previous years and the first half of fiscal year
2020 to cover essential expenses.
FAA. During the pandemic, FAA executed its budget as required by law,
according to FAA officials, relying on AATF cash balances that were not
replenished by incoming revenue from waived aviation excise taxes. With
the cessation of virtually all revenue to the AATF under the tax holiday,
which was in place from March 27, 2020, through the end of calendar
year 2020, FAA relied almost exclusively on AATF cash balances to
execute its budget as normal, according to agency officials. When
Congress appropriated an additional $14 billion to the AATF in October
2020, FAA no longer needed to rely almost completely on existing cash
balances within the trust fund, according to these officials. 42 In addition,
new revenue from aviation excise taxes resumed with the expiration of
the tax holiday, although passenger volume had not yet returned to prepandemic levels as of June 2021.

40USCIS offers an optional service in which applicants pay an additional filing fee to
expedite the adjudication of certain forms to within generally 15 days.
41Pub. L. No. 116-159, div. D, tit. I, § 4102, 134 Stat. at 738.
42Pub. L. No. 116-159, div. B, tit. II, § 1205, 134 Stat. at 728.

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NPS. NPS parks relied on carryover balances during the pandemic to
varying extents, depending on local circumstances regarding both the
pandemic and spending plans or patterns, according to NPS officials.
Grand Teton National Park Visitation
Reached Record Levels in Fall 2020
Grand Teton National Park closed due to the
pandemic on March 24, 2020, beginning its
visitor season in mid-May with lower
attendance than normal. The number of
visitors to the park increased to typical levels
from June to August 2020, and then
increased to record levels in fall 2020. In
October 2020, for example, Grand Teton
National Park hosted an estimated 351,000
recreation visits—an 88 percent increase
compared to October 2019 and an all-time
high for visitation for that month.
Source: National Park Service information. |
GAO-21-104325

For example, Grand Teton National Park typically relies on carryover
balances from high spring and summer visitation to sustain operations in
the beginning of the new fiscal year in the fall, according to NPS officials.
Upon reopening after a 2-month closure in spring 2020, visitation at
Grand Teton National Park soon rebounded to pre-pandemic and then
record levels. This resulted in higher-than-expected revenue and a
sufficient carryover balance, which prevented the park from having to
make additional spending cuts during fiscal year 2021, according to NPS
officials.
Other parks, such as Yosemite National Park, do not generally rely on
carryover funds and do not typically maintain high carryover balances,
according to NPS officials. Prior to the pandemic, however, Yosemite
National Park set aside concession franchise fee revenue for a project the
park planned to start in fiscal year 2022. Park officials told us they were
able to divert these funds to cover fixed costs early in fiscal year 2021 as
they faced revenue declines from pandemic-related caps on visitation.
NPS headquarters monitors uncommitted balances that parks carry over
each year for both recreation and concession franchise fee funds,
according to NPS officials. While NPS manages concession franchise fee
unobligated carryover on a case-by-case basis, according to these
officials, a February 2010 policy requires all parks that collect over
$500,000 in recreation fees annually to carry over no more than 35
percent of the previous year’s recreation fee revenue. NPS put this policy
in place to encourage parks to spend recreation fee revenue to enhance
visitors’ park experiences rather than continuing to grow unobligated
carryover balances indefinitely, according to NPS officials.
NPS implemented the 35 percent carryover target policy at parks to meet
an agency-wide target for an unobligated fee carryover balance of no
more than $80 million by January 1, 2011. NPS officials told us the policy
was effective in helping reduce unobligated carryover balances to move
closer toward that goal, but said there have been no subsequent dollar
amount goals for service-wide carryover balances in the years since
2011.
NPS officials told us they usually approve parks’ waiver requests for the
carryover balance policy, especially if a natural disaster has occurred or a

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contract has been delayed. For example, in fiscal year 2019, 53 out of
153 recreation fee-collecting parks (35 percent) carried over amounts in
excess of the 35 percent limit; NPS headquarters granted waivers to all
53 parks to exceed that carryover limit, according to officials. 43 Parks may
request waivers for various reasons. For instance, staffing shortages,
natural disasters, and project cost increases resulted in delayed
obligations on park projects, according to a regional request for a fiscal
year 2019 carryover waiver. In 2020, NPS implemented a blanket waiver
of this maximum carryover policy, as parks faced revenue instability from
the effects of the COVID-19 pandemic.
Prior to July 2021, NPS had not recently assessed its target carryover
amount guidance for effectiveness or reasonableness, and NPS officials
were not aware of any formal, documented analysis the agency has
conducted to determine the efficacy of the policy since its implementation
in 2010. For example, NPS officials said they were unaware of any prior
agency analysis that provided the basis for the target carryover figure of
35 percent. NPS officials told us they began a review of the agency’s
carryover target policy in July 2021 and that, as of September 2021, the
effort was in the data collection phase.
NPS officials did not provide documentation related to this effort, and they
stated they did not have a planned date to conclude the effort because
their focus was on flexibility, innovation, and finding the best solution for
the agency. These officials said that, as part of the review currently
underway, they are considering a trial 3-year average instead of the
current fiscal year average to establish a carryover target. If implemented,
NPS would plan to review the trial at the end of fiscal year 2022 to
determine its success. NPS officials said they believed this would be a
continuous cycle of trial and evaluation to ensure that their final decision
was fully formed and vetted.

43If a park does not spend its recreation fee fund balance down to 35 percent or lower by
December of each fiscal year without an approved waiver, NPS headquarters has the
ability to decrease the portion of recreation fee revenue that the park keeps. Under the
Federal Lands Recreation Enhancement Act, fee-collecting parks retain at least 80
percent of revenue from recreation fees; the retention rate, however, may be reduced to
not less than 60 percent when revenues collected exceed the reasonable needs of a park.
16 U.S.C. § 6806. Under its maximum carryover policy, NPS reduces retention of gross
recreation fee park revenue to 60 percent for parks that fail to achieve the 35 percent
target for recreation fee carryover.

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In 2013, we reported that agencies relying on revenue from user fees
may benefit from having a reserve fund in place that will allow them to
continue providing goods and services despite fluctuations in collections,
and to act quickly in response to changing conditions. 44 We found that the
level of reserves should be assessed for reasonableness and justified
with program data and risk management considerations.
Additionally, agencies should implement control activities—procedures,
techniques, and mechanisms—through policies, in part by documenting
those policies, according to Standards for Internal Control in the Federal
Government. 45 These standards also say that an agency can periodically
review policies and procedures for continued relevance and effectiveness
in achieving the agency’s goals, such as NPS’s agency-wide target for an
unobligated fee carryover balance of no more than $80 million by January
1, 2011. Until NPS documents and implements its plans to review the
agency’s 35 percent carryover target policy—which agency policy
documents described as “stringent” at the time of its implementation—
NPS will not have assurance that the policy is still reasonable or effective
at meeting the agency’s current or future goals, including managing future
periods of revenue instability. Additionally, NPS may not be maintaining
its unobligated carryover balances in the most effective way.
USCIS. USCIS also relied on carryover balances in the face of decreased
revenue during the COVID-19 pandemic, and may have trouble rebuilding
carryover balances to target levels as planned fee increases are on hold,
according to USCIS officials. As USCIS had declines in fee collections
from late March 2020 through the beginning of May 2020, officials said
the agency relied on its carryover balance to fund operations during that
time.
USCIS officials projected that a routine fee review and an anticipated fee
increase that was due to go into effect in October 2020 would have

44GAO-13-820.
45GAO-14-704G.

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allowed the agency’s fees to meet its operational costs. 46 However, that
fee rule, which is not related to the pandemic, was subsequently enjoined
pending litigation. USCIS officials stated that, while the fee increase is
enjoined, it will be difficult for USCIS to rebuild its carryover balances to
projected levels by the end of fiscal year 2021 if the agency fully funded
its operational requirements. 47

Conclusions

The COVID-19 pandemic has caused serious economic repercussions
and turmoil in the U.S., and has affected government operations and
revenues. Across executive branch agencies, the most significant
dedicated user fee revenue decreases occurred immediately following the
start of the pandemic, from March through June 2020. Dedicated user fee
revenue at FAA, NPS, and USCIS generally reflected these declines.
To help monitor these changing revenues, these agencies used new and
existing revenue monitoring and projections processes. During the
pandemic, FAA developed a cash management plan that it could have
used to align remaining AATF cash balances to the agency’s missioncritical functions, though it ultimately did not need to. FAA officials told us
they plan to review the cash management plan for future use, but the
agency has not documented processes to review the plan to ensure that it
aligns with leadership priorities and can help the agency address future
potential periods of revenue instability. Similarly, NPS recently started a
review of its carryover balance target policy for parks, but this review is
still in its early stages. Documenting and implementing these review

46On August 20, 2020, the Immigrant Legal Resource Center and several other plaintiffs
filed suit challenging the Department of Homeland Security final rule published at 85 Fed.
Reg. 46799. On September 29, 2020, the U.S. District Court for the Northern District of
California preliminarily enjoined the Department of Homeland Security from implementing
or enforcing any part of the final rule. In the Spring 2021 Unified Agenda entry for the
rulemaking listed a November 2021 target date for a notice of proposed rulemaking that
would rescind and replace the changes made by the final rule and establish new USCIS
fees to recover USCIS operating costs. As a result, on September 9, 2021, the United
States District Court for the Northern District of California ordered that the case be stayed
to allow the Department of Homeland Security to either publish a notice of proposed
rulemaking regarding a proposed new fee rule or advising the plaintiffs that the
department will not propose a new fee rule. Immigrant Legal Resource Center v.
Department of Homeland Security, Case No. 4:20-cv-5883-JSW (N.D. Cal. May 13, 2021).
According to USCIS officials, this is not related to the effects of COVID-19 but is instead
an Administration priority.
47For more information on how the COVID-19 pandemic and other factors have affected

USCIS’s processing times, see GAO, U.S. Citizenship and Immigration Services: Actions
Needed to Address Pending Caseload, GAO-21-529 (Washington, D.C.: Aug. 18, 2021).

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processes would help FAA and NPS address potential disruptions in
dedicated user fee revenue in the future.

Recommendations for
Executive Action

We are making two recommendations, one to FAA and one to NPS.
The Administrator of the Federal Aviation Administration should review
the agency’s cash management plan to prepare for future periods of
revenue instability. As part of this review, the agency should develop and
document processes for future reviews of the cash management plan.
(Recommendation 1)
The Director of the National Park Service should document and
implement plans to periodically review the agency’s target rate for
recreation fee carryover balances at individual park units.
(Recommendation 2)

Agency Comments
and Our Evaluation

We provided a draft of this report to the Department of Transportation, the
Department of the Interior, the Department of Homeland Security, and the
Department of the Treasury for review and comment.
In Transportation’s comments, reproduced in appendix III, the department
agreed with our recommendation and said it would provide a detailed
response to the recommendation within 180 days of the report’s issuance.
The department also provided one technical comment, which we have
incorporated into the final report.
In its comments, which are reproduced in appendix IV, the Department of
the Interior agreed with a recommendation in our draft report to develop,
document, and implement plans to periodically review NPS’s target rate
for recreation fee carryover balances at individual park units. The
department’s comments also state that NPS plans to review its 35
percent carryover target rate to determine the efficacy of the policy and
the reasonableness of the carryover levels, and to set a schedule for
periodic review. NPS also provided additional information on the
development of its plans to review this policy, which we incorporated into
the final report as appropriate. Given this additional information, we have
modified the recommendation to NPS in our final report to focus on
documenting and implementing the agency’s plans to review its policy.
The Department of Homeland Security and USCIS provided technical
comments, which we incorporated into the final report as appropriate.
Treasury informed us that it reviewed the draft report and did not have
any comments.

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We are sending copies of this report to the appropriate congressional
committees and the Secretaries of Transportation, the Interior, Homeland
Security, and the Treasury. In addition, the report is available at no
charge on the GAO website at https://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-6806 or arkinj@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made key contributions to this report are
listed in appendix V.

Jeff Arkin
Director, Strategic Issues

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List of Committees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Rosa L. DeLauro
Chairwoman
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Frank Pallone, Jr.
Chair
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives

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The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard E. Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives

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Appendix I: Objectives, Scope, and
Methodology
Appendix I: Objectives, Scope, and
Methodology

This report examines (1) how executive branch agencies’ revenues from
dedicated user fees have changed since the onset of the Coronavirus
Disease 2019 (COVID-19) pandemic; (2) how dedicated user fee
revenues have changed at selected agencies during the COVID-19
pandemic; (3) how selected agencies monitored revenue instability risks
related to the COVID-19 pandemic; and (4) how selected agencies
managed revenue changes during the COVID-19 pandemic, including the
use of selected program reserves, and the extent to which those actions
aligned with requirements and guidance.
To address our first objective, we analyzed data from the Bureau of the
Fiscal Service’s Governmentwide Treasury Account Symbol Adjusted
Trial Balance System (GTAS). Agencies use GTAS to provide proprietary
financial reporting information and information about budget execution to
the Department of the Treasury. For our analysis, we reviewed data for all
executive branch agencies that submitted dedicated collection revenue
data in fiscal year 2020. We further scoped our analysis to specifically
review GTAS data related to agencies’ dedicated user fees and made
decisions about what GTAS entries were most likely to be dedicated user
fees.
We analyzed data from October 2017 (the start of fiscal year 2017)
through March 2021 (halfway through fiscal year 2021), the most recent
data available at the time of our analysis. We analyzed relevant financial
accounts to determine which to include in our scope of dedicated user
fees. We used our judgment to determine which were relevant, but other
decisions may be reasonable and yield different results. We compared
executive branch agencies’ dedicated user fee revenue in fiscal years
2020 and 2021 to the average dedicated user fee revenue for those
agencies in fiscal years 2017 through 2019 to determine how these
revenues changed during the COVID-19 pandemic. We also calculated
changes in dedicated user fee revenue at individual agencies by
comparing dedicated user fee revenue in fiscal year 2020 to average
annual amounts from fiscal years 2017 through 2019.
To assess the reliability of the GTAS data, we reviewed related
documentation, including data dictionaries and GTAS validation and edit
check documents; interviewed knowledgeable officials at the Bureau of
the Fiscal Service; and conducted electronic data testing for missing data
and obvious errors. Based on this assessment, we determined the data
were sufficiently reliable to indicate general trends in dedicated user fee
revenues across the executive branch. For additional details on how we

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Appendix I: Objectives, Scope, and
Methodology

scoped our analysis, treated the GTAS data, and determined which
revenue to include, see appendix II.
To address our remaining objectives, we selected three agencies for
review to serve as illustrative examples of how dedicated user fee
revenues changed during the pandemic and how agencies responded to
these changes: the Federal Aviation Administration (FAA), National Park
Service (NPS), and U.S. Citizenship and Immigration Services (USCIS).
We selected these agencies based on budget information and contextual
information, such as whether the agency’s dedicated user fee revenues
may have been affected by the COVID-19 pandemic and whether the
agency’s activities relate to sectors of the economy most severely
affected by the pandemic. We selected agencies across a range of
budget conditions to better understand how the pandemic potentially
affected agencies that have varying reliance on dedicated user fees.
To determine which agencies had potentially been affected by the
COVID-19 pandemic, we first analyzed agency budget data using the
Office of Management and Budget’s (OMB) MAX database. Agencies use
OMB MAX to report most of the information required for preparing the
President’s Budget, including information on budgetary resources,
outlays, and receipts. We reviewed OMB MAX data related to gross
budget authority, offsetting collections, and receipts from Schedule N
(Special and Trust Fund Receipts) for fiscal years 2015 through 2019 to
identify agencies with a significant share of offsetting collections and
receipts from Schedule N as compared to gross budget authority.
Offsetting collections result from businesslike transactions with the public
and other government accounts, and they include amounts collected for
materials or services furnished to the public, when authorized by law.
Schedule N shows the flow of funding into and out of special and nonrevolving trust funds. It shows new receipts deposited into the fund, new
appropriations taken out of the fund—including any amounts appropriated
but precluded from obligation—and the remaining balances of
unappropriated receipts, if any. We used these data, the most appropriate
data available at the time of our analysis, as a proxy for dedicated user
fees.
In our analysis of OMB MAX data, we excluded agencies with an average
share below 15 percent of offsetting collections and receipts from
Schedule N as a share of gross budget authority from fiscal years 2015
through 2019. We also excluded agencies with a fiscal year 2019 gross

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Appendix I: Objectives, Scope, and
Methodology

budget authority below $1 billion. This resulted in 73 agencies to
potentially review as part of the engagement.
To understand the potential effects of the COVID-19 pandemic across a
range of revenue situations, we ultimately selected two agencies that
were mostly funded by offsetting collections and receipts from fiscal years
2015 through 2019, and one that was not.
•

FAA’s average share of offsetting collections and receipts as a share
of gross budget authority from fiscal years 2015 through 2019 was
95.5 percent.

•

USCIS’s average share of offsetting collections and receipts as a
share of gross budget authority from fiscal years 2015 through 2019
was 108.1 percent. 1

•

NPS’s average share of offsetting collections and receipts as a share
of gross budget authority from fiscal years 2015 through 2019 was
20.6 percent.

We also considered the following contextual information in selecting
agencies to review.
•

Whether the agency was potentially financially affected by the
COVID-19 pandemic. Where possible, we reviewed Monthly
Treasury Statement data for each of the 73 agencies to determine
whether agency receipts had been potentially affected by the COVID19 pandemic. Specifically, we reviewed Monthly Treasury Statement
data from January through July 2020, as well as comparable data for
2019 (i.e., January through July 2019). We reviewed table entries for
each of the 73 agencies to determine whether they had gross receipts
data for any part of 2020. For those agencies that did have relevant
Monthly Treasury Statement data, we compared 2019 receipts to
2020 receipts and excluded agencies that had increased or relatively
flat gross receipts from 2019 to 2020.

•

Whether the agency’s activities related to economic sectors
most affected by the COVID-19 pandemic. We reviewed
information from the Bureau of Labor Statistics household survey and
establishment survey to determine economic sectors that were

1An agency’s offsetting collections and receipts from Schedule N can exceed the gross

budget authority.

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Appendix I: Objectives, Scope, and
Methodology

potentially affected by the pandemic. 2 The household survey
measures labor force status, including unemployment, by
demographic characteristics. The establishment survey measures
nonfarm employment, hours, and earnings by industry. We used
employment data as of July 2020 compared to the previous year from
these surveys to determine which agencies relying on user fees might
have lost revenue from those sources. Using available data in these
tables, we considered which affected economic sectors related to the
activities of the potential agencies to review. We did not use a lack of
Bureau of Labor Statistics data as a criterion to exclude agencies, but
the presence of such data provided additional context for our final
selection. Separate from the Bureau of Labor Statistics information,
we excluded agencies whose activities involved internal departmental
operations, administration, or management services, as those
activities are not public-facing and were less likely to be affected by
the COVID-19 pandemic.
•

Media reports of agencies affected by the COVID-19 pandemic.
We searched a variety of news media sources to determine whether
particular agencies appeared to be more affected by the COVID-19
pandemic. We did not use a lack of media reports as a criterion to
exclude agencies, but the presence of media reports provided
additional context for our final selection.

To address our second objective, we reviewed and analyzed dedicated
user fee revenue data at our three selected agencies to identify revenue
changes during the COVID-19 pandemic.
•

For FAA, we reviewed Monthly Treasury Statement data, which is
separate from GTAS data, on gross receipts into the Airport and
Airway Trust Fund (AATF) for fiscal years 2019 to 2021.

•

For NPS, we reviewed and analyzed recreation fee and concession
franchise fee data from fiscal years 2019 to 2021.

•

For USCIS, we reviewed and analyzed the agency’s fee revenue data
from fiscal years 2019 to 2021.

We also reviewed revenue, budget, and policy documents at each
selected agency, and interviewed knowledgeable officials from each
selected agency, to determine how the pandemic potentially affected

2Department of Labor, Bureau of Labor Statistics, The Employment Situation – July 2020,
USDL-20-1503 (Washington, D.C.: Aug. 7, 2020).

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Appendix I: Objectives, Scope, and
Methodology

revenues at each agency, including any additional expenses or cost
savings that each agency had as a result of the pandemic.
To assess the reliability of Monthly Treasury Statement data related to the
AATF, we reviewed documentation related to data reconciliation
procedures and reviewed the data for reasonableness by performing
manual checks for missing data, outliers, and obvious errors. To assess
the reliability of revenue data provided by NPS, we reviewed the data for
reasonableness and compared these values to amounts in the agency’s
fiscal years 2021 and 2022 budget justification documents. We also
reviewed documentation related to the submission of agency budget data
and interviewed knowledgeable officials about NPS parks’ revenue data
entry and reconciliation processes. To assess the reliability of revenue
data provided by USCIS, we assessed the data for reasonableness and
compared revenue amounts to historical collection amounts provided in
the agency’s fiscal year 2021 budget justification document. We
determined that these data were sufficiently reliable to calculate revenue
changes at selected agencies following the onset of the COVID-19
pandemic.
To address our third objective, we interviewed knowledgeable officials at
each of our three selected agencies to determine what revenue
monitoring and projections processes they used prior to and during the
COVID-19 pandemic. Officials described the timing of their processes,
how the pandemic affected their existing processes, and the changes
selected agencies made to those processes during the pandemic. We
also reviewed planning and projections process documents from NPS
and USCIS that described these processes.
To address our fourth objective, we assessed selected agencies’ revenue
monitoring and management processes during the COVID-19 pandemic
against Standards for Internal Control in the Federal Government
(Principle 12 – Implement Control Activities) and leading practices for fee
design options that we identified in prior work. 3 At FAA, we reviewed the
agency’s cash management plan, a policy document describing potential
actions the agency could have taken to address revenue instability during
the COVID-19 pandemic. At NPS, we reviewed policy documents related
to the agency’s recreation fee carryover target balances, which parks
3GAO, Standards for Internal Control in the Federal Government, GAO-14-704G

(Washington, D.C.: Sept. 2014); and Federal User Fees: Fee Design Options and
Implications for Managing Revenue Instability, GAO-13-820 (Washington, D.C.: Sept. 30,
2013).

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Appendix I: Objectives, Scope, and
Methodology

used to continue operating during the pandemic. At USCIS, we reviewed
the agency’s carryover balance target policies, fee review documentation,
and communications with employees regarding potential management
actions. We interviewed knowledgeable officials at each selected agency
to determine their operational priorities during the pandemic, how they
sought additional funding or flexibilities to address those priorities, and
how they relied on carryover and cash balances to continue operations
during the pandemic.
We conducted this performance audit from May 2020 to September 2021
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

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Appendix II: Methodology for the Analysis of
Executive Branch Agencies’ Dedicated User
Fee Revenue
Appendix II: Methodology for the Analysis of
Executive Branch Agencies’ Dedicated User
Fee Revenue

To determine how executive branch agencies’ revenues from dedicated
user fees have changed since the onset of the Coronavirus Disease 2019
(COVID-19) pandemic, we analyzed Department of the Treasury data
from the Governmentwide Treasury Account Symbol Adjusted Trial
Balance System (GTAS). We analyzed data from October 2017 (the start
of fiscal year 2017) through March 2021 (halfway through fiscal year
2021), the most recent data available at the time of our analysis.

Scope of Analysis

We analyzed data for executive branch agencies for which dedicated
collections revenue was included in GTAS in fiscal year 2020. Each entry
in GTAS—which equates to a monthly reporting of balances—falls under
two types of account codes. The Treasury Account Symbol (TAS)
account specifies the agency and the program area of the entry (for
example, the Department of Agriculture’s Timber Sales Pipeline
Restoration Fund). 1 The United States Standard General Ledger
(USSGL) account specifies the type of financial transaction of the entry
(for example, “Administrative Fees Revenue”). Every entry in GTAS
therefore has a specific TAS-USSGL combination.
A given TAS may have revenue accounted for under multiple USSGL
accounts, including some USSGL accounts that are clearly related to
dedicated user fees and some that are clearly unrelated. Likewise, a
given USSGL account may be used for TAS that are clearly related to
dedicated user fees and TAS that are clearly unrelated. Therefore, we
scoped our analysis by both TAS and USSGL to identify both the program
areas and the revenue types that were most relevant to dedicated user
fees.
We analyzed relevant TAS and USSGL accounts to determine which to
include in our definition of dedicated user fees, as described in this
section. Some of these determinations—which we based on information
from Bureau of the Fiscal Service documents and officials and our
knowledge of the agencies, TAS, and USSGL accounts—were
necessarily judgmental. The inclusion of TAS and USSGL accounts other
than those described below—such as donations or forfeitures—could also
have been reasonable, and would have yielded different results.
1A TAS is an identification code assigned by Treasury in collaboration with the Office of

Management and Budget (OMB) and the owner agency, to an individual appropriation,
receipt, or other fund account. The term “Treasury Account Symbol” is a generic term
used to describe any one of the account identification codes assigned by Treasury and is
also referred to as the “account.” All financial transactions of the federal government are
classified by TAS for reporting to Treasury and OMB.

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Appendix II: Methodology for the Analysis of
Executive Branch Agencies’ Dedicated User
Fee Revenue

Additionally, because of the structure of these accounts, any set of
decisions would result in including some revenue that is not actually from
dedicated user fees, and excluding some dedicated user fee revenue.
When we say “dedicated user fee revenue” in this report, it should be
understood to mean, specifically, revenue that was recorded under the
TAS and USSGL accounts we included in our analysis.
Treasury’s Bureau of the Fiscal Service classifies TAS accounts and
assigns them to an individual appropriation, receipt, or fund group based
on their characteristics and the nature of the transactions they support.
Many fund groups could potentially include dedicated user fees, but some
fund groups in the data we analyzed were more specifically focused on
dedicated user fees. We determined that TAS in the Special Funds,
Public Enterprise Revolving Funds, and Trust Funds groups were most
related to dedicated user fees, since these fund types are designed to link
revenue with their expenditure. We therefore limited our analysis to these
three fund types. We excluded TAS under the General Funds category,
which is credited with receipts that are not classified as dedicated
collections as defined by law for a specific purpose.
We limited our analysis of USSGL accounts (financial transaction types)
to revenue transactions. We consulted with the Bureau of the Fiscal
Service to identify which kinds of USSGL accounts were most related to
dedicated user fees, and we limited our analysis to those revenue
accounts. Within that range of revenue USSGL accounts, there were
account types that could have potentially included revenue streams for
dedicated user fees, such as “Revenue From Services Provided” and
“Tax Revenue Collected - Excise.” There were also a number of USSGL
accounts that were not related to user fee-type revenue, such as those for
contra and other transfer accounts. 2
We excluded all USSGL accounts not related to user fee-type revenue,
such as the account for “Tax Revenue Collected - Individual,” which
includes payroll tax revenue used to support a number of major
entitlement programs. Although payroll taxes comprise a large portion of
all federal dedicated collections, for the purposes of this report, we do not
consider them a direct transaction from the public to the federal
2For example, we excluded from our analyses USSGL account types related to custodial

collections processes, which represent amounts collected on behalf of receiving agencies.
In our analysis, the original collection from the public to the collecting agency would be
reflected in the revenue totals for the collecting agency and not in the revenues for the
receiving agency.

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Appendix II: Methodology for the Analysis of
Executive Branch Agencies’ Dedicated User
Fee Revenue

government in exchange for a good or service and, therefore, have
excluded them from our scope of dedicated user fees.
There were two USSGL accounts that agencies could use to categorize
revenue streams that did not fit into any other USSGL revenue account:
“Other Revenue” and “Tax Revenue Collected - Not Otherwise
Classified.” During our USSGL selection process, we found that some
agencies used these two USSGL accounts for revenue streams that
belonged under another USSGL category. For example, in fiscal years
2017 and 2018, the Department of Transportation categorized excise tax
revenue for its Airport and Airway Trust Fund (AATF) as “Tax Revenue
Collected - Not Otherwise Classified” before changing that account
designation to “Tax Revenue Collected - Excise” in fiscal year 2019. In
this example, we determined that revenue tied to the AATF belonged in
our scope based on our research of the trust fund.
Other TAS under these two USSGLs, however, we did not consider to be
user fee-type revenue. We developed a selection process for TAS
categorized under the “Other Revenue” and “Tax Revenue Collected Not Otherwise Classified” USSGLs to help ensure we excluded non-user
fee revenue streams from our analysis. We applied the following criteria:
1. Exclude TAS with annual revenues under $500 million for all fiscal
years in scope (2017 to 2021). 3
2. Exclude TAS that relate to payments, royalties, or forfeitures, as
indicated in the TAS name.
3. Exclude TAS that, based on the coding analyst’s professional
judgment and research and a second analyst’s independent
verification, were not user fee-type revenues. This step resulted in six
unique TAS included in our final selection of revenues within the
“Other Revenue” and “Tax Revenue Collected - Not Otherwise
Classified” USSGLs. These six TAS, along with those included as a
result of our USSGL selection process, brought the total to 124 TAS in
our final analysis.

3Because 95 percent of all revenues categorized under USSGL accounts “Other

Revenue” and “Tax Revenue Collected - Not Otherwise Classified” were from TAS with
annual revenues above $500 million in any fiscal year between 2017 and 2021, we
determined that this dollar amount threshold was appropriate for the needs of our
analysis. Although applying a threshold means we did not review nor include all TAS
under these USSGLs that could be user fee-type revenues, we did include the user feetype TAS under these account types that had the highest revenues.

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Appendix II: Methodology for the Analysis of
Executive Branch Agencies’ Dedicated User
Fee Revenue

Preparing the Data for
Analysis

Every entry in the GTAS data that the Bureau of the Fiscal Service
provided us represents either a beginning-of-month or end-of-month
balance for a specific TAS-USSGL combination. Balances are cumulative
month-to-month and restart at zero at the beginning of a new fiscal year.
We limited our analysis to the end-of-month balances. In general,
revenue by period (i.e., month of the fiscal year) for a particular TASUSSGL combination can be calculated by subtracting the prior month’s
ending balance from the current month’s ending balance. 4 However, we
found some types of missing data while conducting our analysis.
We determined our method of handling missing data would provide an
adequate approximation of the flow of dedicated user fee revenue over
the course of fiscal years 2017 to 2021. Below we describe the types of
missing data we identified and how we treated them in our analysis.
•

Period 1 of each fiscal year (October) is not included in our GTAS
data because Treasury does not require agencies to submit reports
for that month. Therefore, all October revenue first appears in the
balances for November. To avoid having artificially high November
revenue showing in our graphs, we spread all revenue reflected in
that month over October and November, at a 50:50 ratio for each
unique TAS.

•

If the ending balance of November is missing, we assumed there was
no activity for that account in both October and November. If another
month’s ending balance is missing, we assumed there was no activity
and—because balances are cumulative—implicitly filled in the
balance from the previous month. For example, if January had a
balance, but February was missing, we filled in February’s balance
with January’s balance, which equates in our analysis to no activity
and no new revenue for February. There are many cases where
revenue is missing for the first several months of the fiscal year, but
where revenue is present in all the subsequent months. The Bureau
of the Fiscal Service confirmed that it is normal and allowable for
agencies to start reporting revenue for a particular TAS-USSGL
combination only when activity begins for that fiscal year.

•

We learned from the Bureau of the Fiscal Service that January data
for fiscal year 2019 is missing for all agencies due to the fiscal year

4Agencies may report data into GTAS on a monthly basis. The Bureau of the Fiscal

Service refers to months as periods, with each new fiscal year beginning at Period 1, so
that October of each year is Period 1, and September of each year is Period 12.

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Appendix II: Methodology for the Analysis of
Executive Branch Agencies’ Dedicated User
Fee Revenue

2019 government shutdown. 5 We treated that month’s balances as
described above, with the result of no revenue reflected for the month
across executive branch agencies. In graphs that include average
values for fiscal years 2017 to 2019, the average value for January of
fiscal year 2019 is smaller than it might have otherwise been without a
government shutdown.
We confirmed with Bureau of the Fiscal Service officials that our
treatment of the above irregularities was appropriate. We also identified
cases in which particular TAS-USSGL combinations had months without
any revenue following months showing revenue (not including the 2019
shutdown period). We provided this list to Bureau of the Fiscal Service
officials, who explained that these cases generally fall into one of the
following situations:
1. The agency did not certify the TAS-USSGL combination for that
month.
2. The TAS-USSGL combination failed checks for validations or edits in
the GTAS system, which the Bureau of the Fiscal Service employs to
improve consistency in agency reporting.
3. The agency switched from using one USSGL to another.
We handled the first two situations by applying the same method
described above—assuming the balance from the previous month.
Though Bureau of the Fiscal Service officials told us the agency would
not use uncertified data for their own purposes, we determined that this
approach was the best approximation available to us of what likely
happened during the month with missing data. Bureau of the Fiscal
Service officials agreed this approach was reasonable for the purposes of
our analysis.

5A lapse in appropriations resulted in the federal government partially shutting down from

December 22, 2018, to January 25, 2019. Executive branch agencies’ GTAS reporting for
January of fiscal year 2019 was cancelled. Reporting for February was optional.

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Appendix III: Comments from the
Department of Transportation
Appendix III: Comments from the Department
of Transportation

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Appendix IV: Comments from the
Department of the Interior
Appendix IV: Comments from the Department
of the Interior

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Appendix IV: Comments from the Department
of the Interior

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Appendix V: GAO Contact and Staff
Acknowledgments
Appendix V: GAO Contact and Staff
Acknowledgments

GAO Contact

Jeff Arkin, (202) 512-6806 or arkinj@gao.gov

Staff
Acknowledgments

In addition to the contact named above, Kathleen Padulchick (Assistant
Director), Alyssia Borsella (Analyst in Charge), Paul Aussendorf, Ann
Czapiewski, Ashley Davis, Elizabeth Erdmann, Michele Fejfar, Rebecca
Gambler, Susan J. Irving, Amalia Konstas, Heather Krause, Meghan
Kubit, Samantha Lalisan, Hannah Laufe, John Mingus, Meredith Moles,
Katherine Morris, Dawn Simpson, Ardith Spence, and Carolyn Voltz made
key contributions to this report.

(104325)

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