Why It Matters
A Government Accountability Office (GAO) report, published June 23, found that several federal agencies have not fully implemented new requirements under the Federal Agency Performance Act of 2024 (FAPA), and that the Office of Management and Budget's (OMB) guidance to those agencies is incomplete.
The FAPA requires agencies to track their progress on improving coordination and publicly report results, and the OMB established those goals in December 2025, meeting that deadline. However, its August 2025 guidance to agencies does not address all statutory requirements for strategic reviews. Specifically, it fails to fully address four requirements related to involving agency leaders and stakeholders, and does not fully address the requirement for agencies to annually report on results.
Broader Context
FAPA includes a statutory provision requiring GAO to review its implementation. The law, signed Dec. 23, 2024, directs the Comptroller General to report findings to the Senate Committee on Homeland Security and Governmental Affairs and the House Committee on Oversight and Accountability within 18 months of enactment.
GAO selected four agencies from a pool of 13 that had been included in its prior work on strategic reviews; they were chosen to represent a range of agency sizes and mission types. The Department of Homeland Security and the Treasury had existing policies, procedures, and guidance for their strategic review processes, though those documents addressed only most, not all, statutory requirements. The Department of State and the General Services Administration (GSA) had not developed such documents at all.
The seven recommendations are directed to specific agency heads. The Director of OMB received two: revise guidance to fully address statutory requirements related to senior leaders and stakeholders, and revise guidance to address the annual reporting requirement. The Secretary of State received two: ensure State conducts a strategic review in 2026, and develop process documentation covering all statutory requirements. The Secretary of Homeland Security received one: revise process documentation to identify roles and responsibilities for specific officials and to coordinate with relevant external personnel. The Secretary of the Treasury received one: revise process documentation to address coordination with external personnel and reporting results in an annual performance report. The Administrator of GSA received one: develop process documentation to ensure annual strategic reviews address all statutory requirements.
The Bottom Line
OMB set crosscutting goals on time, but its guidance left agencies without complete instructions. Three of the four agencies reviewed have plans to conduct strategic reviews in 2026; State does not. Until OMB revises its guidance and agencies develop compliant process documentation, FAPA's performance management framework will remain partially built, and the coordination problems the law was designed to fix will persist.
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