What GAO Found
Chronic facility issues disrupted teaching and learning in schools nationwide in school year 2024-25, according to GAO’s nationwide survey of districts. GAO estimates that nearly one in five districts (19 percent) canceled school that year due to a facilities issue. These cancellations affected an estimated 2 million students, who lost an estimated 3.5 million days of learning as a result. Top reasons districts canceled school included plumbing emergencies and extreme classroom temperatures. One district GAO visited canceled school after classroom temperatures reached 110 degrees. GAO also estimates that nearly half of districts (47 percent) had chronic facility issues that often disrupted learning.
Estimated Percent of School Cancellations Due to a School Facilities Issue
Note: The 95 percent confidence intervals for these estimates are 15 to 24 percent of districts; 1.5 to 2.4 million students affected; and 2.5 to 4.5 million days of learning lost.
Districts frequently face funding constraints and have used strategies like investing in preventive maintenance to manage costs and better meet facility needs. GAO estimates that 55 percent of districts considered their most recent facilities budget insufficient to meet their needs. Districts often faced difficulty implementing capital projects and many deferred maintenance, which can lead to higher costs in the longer term. GAO found that districts with limited capacity to conduct preventive maintenance had more chronic facility problems and more disruptions to instruction. School leaders described taking steps to help address these challenges. They included making strategic investments in preventive maintenance and cost-saving measures, engaging in careful facilities planning efforts, leveraging expertise, and building community buy-in for capital projects.
Nationwide, district leaders had mixed views on the efficacy of state and federal policies related to school facilities. For example, an estimated 73 percent said that limited state formula funding for facilities hindered their ability to meet their facility needs. However, some states have implemented practices that survey respondents and others found helpful. For instance, according to research we reviewed, some states directed dedicated revenue sources to school facilities (e.g., from excise taxes), which helped support facilities funding. Others provided incentives to encourage districts to prioritize preventive maintenance. Finally, some states helped districts keep capital projects on track and on budget through steps like offering adaptable building design plans and expediting permitting.
Why GAO Did This Study
Public school facilities are critical in supporting student learning, civic life, and the long-term economic growth of the nation. Research has demonstrated that modern, well-maintained facilities with healthy indoor environments yield better student performance and health, higher teacher retention, and reduced absenteeism. When schools with outdated or improperly maintained facilities temporarily close buildings or classrooms, instruction and learning are disrupted.
GAO was asked to review lost instructional time associated with facility-related school cancellations across the U.S. This report addresses (1) the extent to which facility issues disrupt instruction in public schools; (2) facilities challenges school districts face and strategies they use to address them; and (3) district leaders’ views on state and federal policies related to school facilities and how states can help districts address systemic issues.
GAO conducted a nationally representative survey of public school districts (overall weighted response of 62 percent). Unless otherwise noted, estimates presented have a margin of error of no more than plus or minus 7 percentage points. In addition, GAO visited nine districts across Alabama, Maine, and Oregon. GAO selected states for variation in average spending per student, geographic region, and receipt of federal Supporting America’s School Infrastructure grant funds. Within these states, GAO selected districts for variation in urbanicity, poverty, and size. GAO also reviewed reports by state agencies, commissions, and legislative committees from 2016 through 2026 that examined school facility issues and potential solutions. GAO also interviewed officials from the Department of Education and from stakeholder groups, selected to capture a range of perspectives.
For more information, contact Jacqueline M. Nowicki at nowickij@gao.gov.
What GAO Found
The National Register of Historic Places is the nation’s official list of historic places worthy of preservation. The National Park Service (NPS) administers the National Register in cooperation with states and Tribes. Each state has established a State Historic Preservation Officer (SHPO) whose responsibilities include identifying and nominating eligible properties to the National Register. Additionally, Tribes may elect to establish a Tribal Historic Preservation Officer (THPO).
Officials from SHPO offices GAO interviewed identified a number of challenges with the National Register process, including that some key NPS guidance documents were outdated and did not have information that would help them effectively nominate properties. Because of these challenges, some of these officials noted that developing nominations required additional time and resources. While NPS officials told GAO they intend to update some guidance documents, they have not developed a plan to do so, including a plan to identify what information SHPOs and THPOs need in updated guidance. Developing such a plan will help NPS better ensure the update includes the information that SHPOs and THPOs—their primary users—need to effectively participate in the program.
Tribes GAO spoke with also identified challenges with the National Register process. Some Tribes and tribal organizations told GAO that the National Register evaluation criteria do not always accommodate historically significant tribal properties. NPS officials told GAO they have taken actions to clarify the ways in which Tribes can apply the criteria, including revising guidance on listing traditional cultural places. However, conducting outreach to Tribes to highlight relevant guidance on applying the National Register criteria could provide better assurance that the National Register includes historic properties significant to Tribes.
Some Tribes GAO interviewed also expressed concern that nominating properties to the National Register could result in unwanted visitation or looting of sites. The location of properties on the National Register can be withheld from public disclosure in certain circumstances. While NPS has taken productive steps to communicate information about this provision, some Tribes GAO spoke with were not aware of it or continued to have concerns about sharing information about properties. Conducting outreach to Tribes on the ability to withhold this information would better ensure they are informed of this provision and may mitigate continuing concerns among Tribes about sharing information about their historic properties.
Why GAO Did This Study
The National Register is a key part of federal efforts to identify and protect America's historic and archeological resources. Over 100,000 properties are listed in the National Register, including buildings, objects, and sites. However, some stakeholder groups have raised questions about whether the National Register is representative of the nation’s full story.
GAO was asked to review how NPS administers the National Register and any challenges SHPOs and THPOs may face in the listing process. This report discusses the National Register listing process and examines challenges faced by selected SHPOs and THPOs and the public.
GAO reviewed relevant laws and regulations, analyzed NPS guidance documents, and interviewed NPS officials who administer the National Register. GAO also interviewed officials from a nonrepresentative selection of nine SHPO offices and eight federally recognized Tribes. GAO selected these SHPO offices and Tribes to reflect variation in the number of sites they had listed to the National Register from 2019 through 2024 and geographic diversity, among other factors.
Why GAO Did This Study
From September 2026 through December 2026, GAO is seeking input and feedback on this exposure draft from all interested parties. Please use this link TEGuideComments@gao.gov to provide us with comments on the guide.
Federal agencies spend billions of dollars each year buying commercially available off-the-shelf (COTS) products. When agencies want to buy a COTS product, first they need to determine whether a vendor’s product is right for them. One way that agencies assess a product is by conducting testing and evaluation (T&E). Agencies can then use the results of the T&E to inform their purchasing decisions.
Prior GAO work has identified problems with how agencies conduct T&E. Also, there is no widely accepted process or organization for sharing best practices for T&E.
GAO developed this guide to provide best practices for conducting COTS T&E. GAO has developed this guide to serve multiple audiences:
The primary audience for this guide is federal agencies—specifically, T&E practitioners, program managers, and procurement officials. Agency staff can implement the best practices in this guide to improve their T&E, procure effective technologies, and reduce risks of cost and schedule overruns.
GAO and other oversight organizations can use this guide to evaluate how effectively federal agencies conduct T&E when buying a COTS product.
Vendors can use this guide to evaluate the performance of their products against agency requirements.
For more information, contact Karen Howard at HowardK@gao.gov.
What GAO Found
Federal buildings often contain special use spaces like meeting rooms and conference centers, some of which may be shared across agencies. Agencies varied in how they shared these spaces in the selected General Services Administration (GSA)-owned and -leased buildings GAO visited.
Interviewees, including officials from federal tenant agencies in those selected buildings, said that sharing these spaces can provide benefits, including:
access to useful spaces their agency might not otherwise have,
reduced costs and more efficient use of space (e.g., agencies do not need to lease or construct individual spaces), and
increased collaboration between agencies.
However, interviewees also identified challenges to sharing, such as lack of awareness of what spaces are available or how to reserve them.
Illustrative Examples of Special Use Spaces in a Federal Building
GSA, which manages federal real property for tenant agencies, publishes an online list of meeting spaces that agencies volunteered to share. The list includes information such as room descriptions and a point of contact to reserve the space. However, the list is not comprehensive—some tenant agencies have not added their space to the list, and some GSA rooms are not on the list. GSA periodically emails agencies to request that they update the list, and it relies on agencies to distribute the list to their staff. However, most agency officials GAO interviewed in selected buildings were not aware of GSA’s list. GSA officials noted that federal turnover in 2025 contributed to reduced awareness of the list. They said that starting in 2025, more of their reminder emails were undelivered. Officials said they worked with agencies to update their contacts, and that they may be able to use other mechanisms to more broadly distribute the list. Improving the comprehensiveness of the list and agency awareness of it could help agencies share special use spaces, which could in turn potentially reduce costs by supporting GSA’s efforts to ensure efficient use of federal space.
Why GAO Did This Study
In recent years, GSA and others have taken steps to reduce unneeded federal real property, particularly office space, but building utilization across the federal government remains low.
The Thomas R. Carper Water Resources Development Act of 2024 includes a provision for GAO to report on the use of special use spaces in federal buildings to determine levels of use and identify opportunities for sharing, collocating, and other efficiencies.
This report addresses 1) how agencies share special use spaces in selected GSA-owned and -leased buildings, 2) the reported benefits and challenges related to sharing special use spaces, and 3) GSA’s efforts to promote sharing of special use spaces.
GAO conducted in-person site visits at six federal buildings selected for geographic diversity and whether there were multiple tenants, among other criteria. These site visits were composed of 1) a review of data or documentation; 2) observation of special use spaces; 3) interviews with GSA officials; and 4) interviews with officials from federal tenant agencies in those buildings. GAO also reviewed available GSA documentation and assessed GSA efforts against its strategic goals and GAO leading practices for interagency collaboration.
What GAO Found
Personal protective equipment (PPE)—such as masks and gloves—helps minimize exposure to hazards, including illnesses. In response to the COVID-19 pandemic (March 2020–May 2023), the Federal Emergency Management Agency (FEMA) and the Department of Transportation (DOT) expedited the transportation of PPE by air and helped mitigate supply chain challenges.
FEMA. From March through June 2020, FEMA conducted Project Airbridge, in which FEMA paid for the air transportation of PPE from overseas to the U.S. to reduce shipment times. FEMA funded 437 flights to transport approximately 1.2 billion PPE items, primarily gloves, masks, and gowns.
DOT. DOT used selected legal authorities to help expedite the transportation of PPE by air and to provide transportation industry stakeholders with regulatory relief that could have expedited the transportation of PPE. For example, DOT’s Federal Aviation Administration issued exemptions from certain regulations during the COVID-19 pandemic to allow certain passenger air carriers to transport cargo in the passenger cabins of aircraft.
DOT and other federal agencies also coordinated with transportation industry stakeholders specifically to mitigate supply chain issues and keep goods moving during the pandemic, which may have expedited the transportation of PPE.
Boxes of Personal Protective Equipment Transported in the Passenger Cabin of an Aircraft During the COVID-19 Pandemic
Stakeholders GAO interviewed shared perspectives on methods to expedite the transportation of PPE used during the COVID-19 pandemic, and many said that an increased federal role was unnecessary or could have had negative consequences. For example, two stakeholders cited the use of “peel piles” to designate areas at ports for containers from specific shippers as a method used to expedite goods during the pandemic, including PPE. Many stakeholders said they did not think more federal involvement was needed in expediting the transportation of PPE during the pandemic, or that increased federal involvement could have had negative consequences. For example, stakeholders said that federal involvement in prioritizing a container on a ship could have caused delays at ports. Furthermore, several of these stakeholders stated that the private sector and industry partners were better suited to take the lead in expediting the transportation of goods through the supply chain.
Why GAO Did This Study
During the COVID-19 pandemic, significant challenges, including global demand and supply chain issues, made it difficult to quickly access PPE. Delays in the transportation of PPE may have contributed to the spread of COVID-19, which killed nearly 1.2 million people in the U.S. as of June 1, 2024.
Public Law 118-159 includes a provision for GAO to review the expedited transportation of PPE during the COVID-19 pandemic. This report describes, among other things, (1) how DOT and other relevant federal agencies expedited the transportation of PPE during the pandemic, including using selected legal authorities to do so; and (2) selected industry stakeholder perspectives on methods used to expedite the transportation of PPE during the COVID-19 pandemic, including their views on whether an increased federal role was needed.
GAO reviewed documentation and interviewed officials from five federal agencies that played a role in expediting the transportation of PPE: DOT, FEMA, Health and Human Services (HHS), the Department of Defense, and the Federal Maritime Commission. GAO also reviewed relevant statutes, regulations, and executive orders and analyzed available data from FEMA and HHS that described the amount and type of PPE that these agencies transported during the COVID-19 pandemic.
GAO interviewed a nongeneralizable sample of 21 stakeholders representing three groups relevant to the transportation of PPE: transportation industries, health care distributors, and port authorities. GAO selected these stakeholders based on factors including geographic diversity, involvement in federal efforts to expedite the transportation of PPE, or market share of their respective industry.
For more information, contact Elizabeth Repko at RepkoE@gao.gov.
What GAO Found
The Federal Aviation Administration’s (FAA) Brand New Air Traffic Control System (BNATCS) has an ambitious goal to significantly accelerate the modernization of outdated air traffic control (ATC) systems. The goal is to be achieved at an unprecedented speed. The first of two phases aims to modernize communication, surveillance, weather, and training systems, among other things. For example, FAA plans to modernize voice radio systems 9 years earlier than initially planned. Phase 1 is to be fully completed by December 2028. In July 2025, Congress appropriated $12.5 billion to support BNATCS and FAA is using most of the funds for phase 1. For phase 2, FAA plans to develop new automation systems to track aircraft and optimize traffic. FAA stated that they will need approximately $10.2 billion for this phase (not including facilities). FAA does not yet have an estimated date for when phase 2 will be started or completed.
FAA has made progress in implementing portions of phase 1. For example, as of May 2026, FAA reported replacing 2,560 of 5,170 old and frail copper wires with high-speed fiber optic communications cables.
Copper Wires from the 1960s Are Being Replaced with Fiber Optic Cables
FAA has not developed a comprehensive and well-documented lifecycle cost estimate for BNATCS. In June 2026, FAA officials provided high-level estimates per program for phase 1. However, officials were unable to provide the analysis that supported these figures. In addition, officials acknowledged that the estimate does not include government costs, most of the operations costs for phase 1, or any of the costs for phase 2. In addition, FAA has not developed an integrated master schedule for phase 1. Instead, FAA has 11,389 individual project schedules that are not integrated. As a result, individual projects are scheduled for installations at the same sites, generally without optimizing the schedules to reduce impacts to controller operations. Officials stated they have plans to address this issue, however; they did not have a time frame for when the issue would be resolved.
While accelerating this modernization is critical, FAA’s lack of a reliable lifecycle cost estimate and an integrated master schedule introduce heightened risk to BNATCS. GAO’s decades-long bodies of work on acquisitions and FAA modernizations indicate that these risks increase the likelihood of FAA repeating its history of cost overruns, delays, and unmet performance targets. If these risks are realized, FAA would need to continue to rely on severely outdated systems that are prone to failure leading to more flight delays and safety incidents.
Why GAO Did This Study
FAA air traffic controllers rely on a myriad of legacy systems to monitor weather, conduct surveillance, and manage communications for up to 45,000 flights per day. This aging and unreliable technology has contributed to an increase in flight delays and aviation incidents. FAA has attempted to modernize ATC systems since the 1980s, but has experienced challenges and delivered limited results. In September 2024, GAO reported that over 75 percent of FAA’s 138 ATC systems were unsustainable or potentially unsustainable. GAO also reported that FAA was not moving fast enough to modernize its systems. In May 2025, the Secretary of Transportation announced the latest FAA modernization effort, BNATCS.
Due to the importance of successfully implementing this latest modernization effort, GAO was asked to examine FAA’s progress. GAO’s objectives were to (1) identify the initial plans and status of BNATCS and (2) assess the extent to which FAA has established a cost estimate and schedule to support BNATCS.
GAO analyzed FAA’s planning and implementation materials. GAO also assessed available schedule and cost estimation documentation and compared them to best practices. Further, GAO interviewed FAA officials regarding BNATCS status, cost, and schedule.
What GAO Found
The U.S. Department of Agriculture (USDA) has taken few actions to enhance the resilience of farms and forests to the climate-related risks of diseases and pests, and funding and staffing supporting those actions have decreased.In late 2023, USDA officials told GAO that the risks of diseases and pests had not been fully integrated into the department’s climate resilience planning at all levels and that USDA planned to do so in the future. At that time, USDA provided limited information and technical assistance on individual diseases and pests to farmers and land managers. For example, USDA’s Climate Hubs provided some support for research on the effects of climate change on specific diseases and pests and developed models for forecasting potential outbreak risks, including the southern pine beetle. However, key programs that provide information and assistance to farmers and land managers to help manage the climate-related risks of diseases and pests—such as USDA’s Climate Hubs—have lost staff and face planned funding cuts. In April 2026, GAO requested updated information from USDA about the status and impact of these cuts, but the department did not provide the information.
Examples of Climate-Related Risks of Diseases and Pests
Development and implementation of a national strategy would help USDA enhance the resilience of farms and forests to the climate-related risks of diseases and pests, according to GAO’s analysis of relevant literature and interviews with knowledgeable stakeholders. A nationwide assessment to identify and assess these climate-related risks is a necessary first step to developing a national strategy to enhance resilience to diseases and pests. A national strategy, informed by a nationwide risk assessment, could help USDA direct its resources effectively to ensure that farmers and land managers get the information they need to enhance their resilience. It could also help limit federal fiscal exposure to climate-related risks to the federal crop insurance program and other disaster assistance appropriations. Further, a national strategy could inform congressional decision-making by identifying USDA’s capacity needs to ensure the strategy is implemented effectively.
Why GAO Did This Study
Diseases and pests have large economic impacts on U.S. natural resources—including agricultural lands and forests. From 1960 through 2020, invasive species, including diseases and pests, cost the U.S. agricultural and forestry sectors at least $550 billion.
According to experts, climate change will expand or shift the range of diseases and pests. This creates fiscal exposure—long-term costs and uncertainty regarding future spending—for federal crop insurance and disaster assistance programs. For example, the fiscal year 2024 Analytical Perspectives volume of the President’s Budget—the most recent analysis of the federal crop insurance program’s fiscal exposure to climate change—estimated the federal government could spend an additional $300 million to $2.2 billion annually on crop insurance payments because of changes in the climate.
GAO was asked to review federal efforts to enhance the resilience of farms and forests to climate-related risks of diseases and pests. This report examines (1) USDA’s efforts in this area and (2) options to enhance them.
GAO reviewed laws, regulations, and agency guidance related to diseases and pests; analyzed literature; interviewed 84 knowledgeable stakeholders including USDA, state, and local officials and academic researchers; and conducted site visits to eight states to observe the impacts of selected diseases and pests.
What GAO Found
GAO found that the Federal Emergency Management Agency (FEMA) —a component within the Department of Homeland Security (DHS)— partially followed leading practices for risk assessment and information quality during the development, operation, and maintenance of the National Risk Index (NRI). The figure below lists these practices.
FEMA took steps to define and disseminate information about the purpose and scope of the NRI and provided additional information on the methodologies and data used to inform the index. However, FEMA did not consider what information users (e.g., emergency managers) would need to tangibly apply NRI results when making decisions about how to reduce risk. Moreover, FEMA did not explain how users should apply NRI information in conjunction with other FEMA risk tools to generate effective risk insights. Lack of information about how to apply results undermines the NRI’s perceived utility.
FEMA took steps to use diverse sources to design the NRI, including consulting relevant sources and subject matter experts. FEMA also followed an established process to verify and validate hazard calculations and risk scores. However, FEMA did not consistently use sensitivity analyses to verify the model’s outputs or inform significant changes to data sources and methodologies. Conducting such analyses would enhance understanding of factors that could affect NRI results, such as methodological choices that could lead to over- or under-estimation of specific aspects of hazard risk. Disclosing results of any such analyses conducted would also enhance user understanding of how those factors could affect risk scoring in their specific circumstances.
FEMA established a process to communicate and engage with subject matter experts on future updates to NRI data. However, FEMA does not have an established mechanism to systematically collect ongoing user feedback and use it for continuous NRI improvement. Without such a mechanism, FEMA does not have the information it needs to assess whether the tool provides valuable information to its users to address their hazard mitigation planning needs.
Why GAO Did This Study
Natural disasters have become more costly and frequent. Jurisdictions can use the NRI to help address disaster risk. It is the only national-level index that combines disaster loss with social vulnerability and community resilience measures to score risk, according to FEMA officials.
GAO was asked to review the extent to which FEMA has applied leading practices to the NRI. This report examines leading practices for (1) defining the purpose of risk information; (2) designing a sound model and ensuring information quality; and (3) engaging with relevant stakeholders.
GAO consulted federal sources and international standards to develop leading practices for assessing risk. GAO then analyzed FEMA’s actions against these practices. GAO analyzed technical documentation and interviewed FEMA officials to assess practices. GAO also interviewed emergency management stakeholders from select states for user perspectives.
What GAO Found
The National Nuclear Security Administration (NNSA)—a separately organized agency within the Department of Energy (DOE)—and its eight contractor-managed and -operated sites engage in Strategic Partnership Projects (SPP). These projects allow NNSA sites to perform work for other federal agencies and nonfederal entities and for those entities to benefit from the significant public investment in the specialized facilities and scientific and technical expertise of NNSA sites. DOE requires NNSA sites to recover the full cost of the SPP through reimbursement from partners.
SPP work was generally steady in fiscal years 2019 through 2024, with total reimbursed costs of almost $15 billion in constant fiscal year 2024 dollars. SPP at Sandia National Laboratories accounted for more than half of the total reimbursed costs of NNSA’s SPP, while Kansas City National Security Campus experienced the most growth in SPP during this period, both in costs and the number of SPP. The Department of Defense sponsored the most SPP, and NNSA categorized most SPP as related to national security.
Strategic Partnership Projects by Project Type, Fiscal Years 2019 Through 2024
NNSA sites conduct SPP based on capabilities or statute, providing support for mission work or additional benefits. NNSA’s capabilities provide unique opportunities, sometimes otherwise unavailable, to SPP partners. NNSA sites also conduct some SPP due to statutory authorization or the special nature of the relationship between NNSA and the partner organization. SPP can also provide benefits either directly to mission work, operations, or through research insights. Specifically, SPP can provide opportunities for technical staff to enhance their skillsets and SPP partners contribute to facilities and capabilities maintenance.
Decreases in NNSA sites’ capacity for SPP could impact NNSA’s and its partners’ ability to achieve their missions and result in NNSA paying more in indirect costs. For example, all nine SPP federal partners GAO interviewed said SPP was essential to their ability to complete their mission. They also said that, in many cases, NNSA’s sites are the only places for specific capabilities. In addition, SPP partners’ funds reduce the indirect costs NNSA must pay for its programs and related facilities. If NNSA needed to decrease its SPP work, NNSA’s costs would increase without the partners’ contributions, site representatives said, because NNSA would carry more of the costs to operate and maintain facilities and infrastructure. Representatives from some sites said they believed they have additional capacity for increases in SPP, while other sites have limited capacity.
Why GAO Did This Study
NNSA’s eight national laboratories, plants, and sites perform reimbursable work for outside entities through SPP. SPP provide value to both NNSA and its partners by leveraging capabilities that can result in mission-related scientific achievements.
In recent years, NNSA’s workload for maintaining and modernizing the nation’s nuclear weapons stockpile has grown substantially, raising concerns about how much capacity NNSA has to conduct SPP.
The Senate committee report accompanying the National Defense Authorization Act for Fiscal Year 2025 includes a provision for GAO to review SPP. GAO’s report examines (1) the extent to which NNSA sites have engaged in SPP and how this work may have changed in recent years, (2) why SPP work is conducted at NNSA sites and the impact of SPP activities on the execution of NNSA’s missions, and (3) the potential effects on NNSA facilities and SPP partners should NNSA need to rebalance SPP partnerships.
GAO reviewed and analyzed NNSA and contractor data on SPP projects and documentation of SPP processes to determine the extent and nature of recent SPP. GAO conducted five site visits to understand the capabilities used by SPP at the sites. GAO also interviewed NNSA officials, contractor representatives, and SPP partners to discuss the types of SPP and the work’s connection to NNSA’s mission.
For more information, contact Allison Bawden at BawdenA@gao.gov.
What GAO Found
Based on data provided by the military services, GAO found that the services’ use of intergovernmental support agreements (IGSA) with state, local, and tribal government entities (public partners) for installation-support services increased from 45 across all DOD installations in 2018 to 316 in 2025. Officials from DOD, the Army and Navy, and selected military installations said they intend to promote future IGSA use.
However, military services’ estimates of cost savings did not reflect best practices for cost estimation, which raises questions about their completeness and reliability. Further, the military services’ guidance related to estimating costs and cost savings did not include specific guidance for prospective IGSAs that provided multiple services to one or more installations. Selected cost estimates GAO reviewed did not fully consider the scope of services that could be performed at various locations under these agreements. Further, some agreements GAO reviewed did not have associated cost estimates or cost-benefit analyses. Without guidance, the military services may incorrectly estimate IGSA costs and have limited information that would help ensure prospective IGSAs are in the best interests of the military. Further, the Navy, Marine Corps, and Air Force did not have procedures to verify installations’ cost and cost savings estimates or revise them if needed. Without complete information on actual IGSA costs and cost savings, the services cannot verify that estimates reflect actual costs, in line with best practices.
Public partners involved in nine of the 21 single-installation IGSAs that GAO reviewed used private contractors to perform some of or all the work. The McNamara-O’Hara Service Contract Act (SCA) requires employees providing services to the federal government to be paid in accordance with prevailing wage rates for such employees in their locality but does not apply to IGSAs. GAO compared minimum wages associated with a nongeneralizable sample of five positions performing work under IGSAs with the minimum wages that may be required for comparable work performed under the SCA. GAO found that the differences between the minimum wages varied.
Comparison of Minimum Hourly Wages Offered by Public Partners to Minimum Hourly Wages Required Under the McNamara-O’Hara Service Contract Act (SCA) for Selected Similar Positions
Public partner position
Public partner wage
SCA position
SCA wage
Percent difference
Paralegal
$23.92
Paralegal/legal assistant II
$28.89
-17 percent
Senior accounting/payroll specialist
$21.47
Accounting clerk III
$21.54
0 percent
Driver I
$15.36
Shuttle bus driver
$18.98
-19 percent
EMT transport crewmember
$16.37
Emergency medical technician
$18.84
-13 percent
Stormwater environmental specialist 1
$39.84
Environmental technician
$26.64
50 percent
Source: GAO analysis of wage data provided from public partners and wage determinations from SAM.gov. | GAO-26-108092
Why GAO Did This Study
In 2013, federal law authorized the military services to enter into IGSAs with state, local, and tribal government entities to receive, provide, or share installation-support services, such as utilities and waste management.
GAO was asked to examine the military’s use and oversight of IGSAs, and the labor used under these agreements. This report provides information on the military’s use of IGSAs since 2018, the services’ monitoring of IGSA benefits, public partners’ use of contractors for work under IGSAs, and how wages paid under selected IGSAs may compare with those required for comparable work under the SCA.
GAO reviewed IGSA-related guidance and analyzed data on IGSA use as of December 2025. Further, GAO reviewed documentation related to 21 IGSAs held by five installations selected based on factors such as military service involved and the number of IGSAs held. GAO also reviewed the cost-benefit analyses associated with 10 IGSAs for multiple services at one or more installations and compared these analyses to best practices for cost estimation. Further, GAO interviewed DOD and local government officials and compared wage information for selected positions under IGSAs to those wages that may be required for other types of agreements under the SCA.
What GAO Found
In 2014, the Financial Crimes Enforcement Network (FinCEN)—a federal agency that helps combat financial crimes—issued guidance on how financial institutions can serve cannabis-related businesses (CRB) while complying with Bank Secrecy Act (BSA) requirements. This guidance instructs institutions to gather thorough information on CRB customers and file suspicious activity reports for certain transactions involving CRBs. Federal banking regulators help oversee institutions’ compliance with these requirements through BSA examinations.
Financial institutions consider various factors when deciding whether to serve CRBs, according to GAO’s focus groups and interviews. Factors dissuading institutions from serving CRBs include potential legal and regulatory sanctions and the costs of complying with BSA requirements. Conversely, some institutions decide to serve CRBs to meet community needs or as a business opportunity.
According to FinCEN data, the number of financial institutions that reported providing services to CRBs increased from 2015 to 2019 and then remained relatively steady through 2024. FinCEN requires institutions to include specific terms when filing suspicious activity reports on transactions involving CRBs. FinCEN data indicate that about 1,000 banks and credit unions filed such reports in 2024. These data do not identify how many institutions accept CRBs as ongoing customers as institutions may not report or may not know they are providing services to CRBs, or they may report providing services to a CRB in an occasional transaction but not accept CRBs as ongoing customers. In addition, some institutions filing these reports may only serve ancillary businesses, not plant-touching businesses that directly grow, manufacture, or sell cannabis.
FinCEN Analysis of Numbers of Banks and Credit Unions Filing Selected Suspicious Activity Reports, Fiscal Years 2015–2024
Obtaining and maintaining financial services remain difficult for CRBs, according to CRB owners and managers. For example, CRBs may experience bank account closures, high fees for bank accounts, and high interest rates for business loans. Further, accepting customer payments is difficult largely because two major credit card companies prohibit cannabis purchases. In addition, CRB owners and managers reported that they and their employees face challenges accessing personal financial services due to their work in the cannabis industry.
Why GAO Did This Study
CRBs include state-licensed businesses that grow, manufacture, or sell cannabis products (plant-touching businesses), as well as businesses that support those operations, such as suppliers of growing equipment or providers of legal services (ancillary businesses). Financial institutions may be reluctant to serve CRBs because, with certain exceptions, cannabis is a controlled substance under federal law. As a result, serving these businesses poses legal risks and triggers ongoing BSA compliance obligations.
GAO was asked to review issues related to financial institutions serving CRBs. This report examines (1) the guidance and oversight federal agencies provide to financial institutions on serving state-sanctioned CRBs, (2) factors that affect financial institutions’ decisions about serving CRBs, and (3) challenges CRBs and their employees face in accessing financial services.
GAO reviewed relevant agency guidance and documents, obtained FinCEN’s analysis of data on suspicious activity reports for CRB-related transactions filed from 2015 through 2024, and reviewed literature on CRBs’ access to banking. GAO also conducted nine focus groups and 11 interviews involving a total of 74 financial institutions (selected to represent different asset sizes, institution types, and policies on serving CRBs). Participants were the BSA officer or cannabis banking program manager for each institution. GAO also conducted eight focus groups with owners and managers from 51 CRBs (selected to represent different business sizes and types). Finally, GAO interviewed agency officials, financial and cannabis industry associations, and other interest groups (selected for their expertise or public comments on banking CRBs).
For more information, contact Courtney LaFountain at lafountainc@gao.gov.
What GAO Found
The Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) is the sector risk management agency (SRMA) for the U.S. chemical sector, responsible for implementing programs to assist facility owners and operators in identifying and mitigating security risks. In 2007, DHS established a regulatory program to mitigate security risks for high-risk chemical facilities. As part of this program, CISA required facilities to vet their personnel and certain unescorted visitors for terrorist ties against the U.S. government’s terrorist watchlist. Vetting against the U.S. terrorist watchlist is an inherently governmental function that the private sector cannot perform on its own; therefore, CISA set up a process with options facilities could use for such vetting. Authorization for the regulatory program lapsed in July 2023. The program, including personnel vetting, was discontinued. High-risk chemical facilities are now responsible for identifying and mitigating their own security risks.
According to CISA officials and selected private sector stakeholders GAO interviewed, losing access to the terrorist vetting process is the most significant challenge high-risk facility owners and operators have faced since the discontinuation of CISA’s regulatory program and it has left a gap in chemical facility security that poses substantial risks. The statutory authority that establishes SRMA responsibilities specifies that SRMAs are to implement security programs to assist stakeholders in identifying and mitigating risks to their assets and systems. As of May 2026, CISA said it was exploring whether the agency’s SRMA authority could be used to set up a vetting process. Without federal options for the terrorist vetting of personnel, facility owners and operators lack a critical tool to protect their facilities from an insider terrorist attack and from potential disruptions to critical national supply chains.
From fiscal years 2024 to 2025, the number of CISA active personnel dedicated to chemical sector activities declined from 214 (96 percent of authorized positions) to 52 (25 percent of authorized positions). The active personnel did not include full-time personnel scheduled to separate from CISA by the end of calendar year 2025 through deferred resignations programs. CISA said the reductions have necessitated reducing or eliminating services, such as most on-site facility assessments, but also said the agency continues to offer other services, such as security training and cybersecurity guidance. Selected private sector stakeholders told GAO that CISA’s personnel reductions and the loss of experienced staff have reduced their contact with CISA regarding facility security vulnerabilities.
Chemical Facility Warehouse and Operations
Why GAO Did This Study
According to DHS, as of 2025, more than 89 million people lived or worked within 2 miles of a U.S. facility using high-risk chemicals. DHS estimates that should high-risk chemicals be weaponized, it could cause significant harm to surrounding populations, from fatalities within the facility to the equivalent impact of a nuclear explosion.
GAO was asked to examine DHS’s efforts to mitigate security risks to the U.S. chemical sector. This report addresses, among other issues, CISA and sector stakeholder assessments of sector security following the discontinuation of a facility regulatory program, effects of the lack of a federal terrorist vetting process for chemical facility personnel, and effects of fiscal year 2025 reductions in CISA personnel on sector support services.
GAO reviewed relevant statutes, CISA guidelines and procedures, and CISA data on full-time authorized positions and active agency personnel for fiscal years 2024 and 2025. GAO interviewed CISA officials; conducted site visits to five chemical facilities; and interviewed private sector stakeholders, including representatives from the private sector coordinating council, three industry associations, and six chemical companies.
What GAO Found
In April 2025, GAO identified 13 priority recommendations for the Department of State. Since then, State has implemented six of those recommendations, and GAO removed the priority status from two recommendations.
In September 2026, GAO identified an additional four priority recommendations, bringing the total to nine. GAO is highlighting the following two areas that warrant timely and focused attention:
Managing fraud risks, and
Strengthening oversight of U.S. security assistance.
Addressing GAO’s recommendations in these areas would help determine whether Ukraine used direct budget support funding as intended and support Congressional oversight of U.S. security assistance. Taking action to implement all of GAO’s open priority recommendations would help enhance the efficiency and effectiveness of operations across State.
Why GAO Did This Study
Priority open recommendations are the GAO recommendations that warrant priority attention from heads of key departments or agencies because their implementation could save large amounts of money; improve congressional or executive branch decision-making on major issues; eliminate mismanagement, fraud, and abuse; or make progress toward addressing a high risk or duplication issue, among other benefits.
Since 2015, GAO has sent letters to selected agencies to highlight the importance of implementing such recommendations.
For more information, contact Kimberly Gianopoulos at gianopoulosk@gao.gov.
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