GAO: General Accountability Office and General Accounting Office

Prepared for Members and Committees of Congress

On July 7, 2004, an old congressional support agency was given a new name, while keeping the
same initials (GAO): at that time, the General Accounting Office, established in 1921, was re-
designated the Government Accountability Office (P.L. 108-271). The renaming, which came at
the request of its head, the Comptroller General (CG) of the United States, was designed to reflect
the agency’s evolution and additional duties since its creation more than eight decades before.
The Government Accountability Office is the largest of three agencies that provide staff support,
research, review, and analysis for Congress. GAO operates under the control and direction of the
Comptroller General, who is appointed by the President, with the advice and consent of the
Senate, for a 15-year nonrenewable term. A unique arrangement begins the process with a special
bicameral commission of legislators from both parties making recommendations to the President.
The CG post is currently vacant, with the resignation of David Walker on March 12, 2008.
GAO was established in 1921 as an independent auditor of government agencies and activities by
the Budget and Accounting Act. The office was intended to be “independent of the executive
departments,” the entities it would audit and review. Sometimes called “Congress’s watchdog”
and its “investigative arm,” GAO now provides a variety of services to Congress that extend
beyond its original functions and duties, including oversight, investigation, review, and evaluation th
of executive programs, operations, and activities. Several proposals in the 110 Congress are seen
as augmenting GAO’s capabilities. These include clarifying its audit authority over the
Intelligence Community (H.R. 978 and S. 82) and enhancing its powers to gain access to
executive documents (H.R. 6388). In a separate matter, personnel flexibilities powers granted to
the Comptroller General in 2004 have generated some controversy in Congress and among GAO
employees. As an outgrowth of this and other considerations, GAO staff have set up a new
bargaining unit, the first union in the office’s history. Legislation has also been proposed that
would, among other things, amend GAO’s basic authority over personnel and pay matters for
employees, provide pay adjustments and reimbursements for certain employees who had not
received pay increases in 2006 and 2007, and establish an office of inspector general (H.R. 5683,
which has passed the House and Senate and been sent to the President).
Throughout much of its history, the office has experienced growth in its powers, duties, and
resources. In the mid-1990s, however, it was the subject of congressional hearings, studies, and
proposals for change, connected with its mission, roles, and capabilities; these reviews were
generated in part by criticisms of its perceived orientation. As a result, GAO’s budget and
personnel levels were reduced and certain of the “executive powers” of the Comptroller General.
In comparison to these earlier budget reductions, however, the office’s funding has since risen,
from $358 million in FY1998 to $507.2 million in FY2008. Nonetheless, GAO’s staff size (at

3,100 in FY2008) has remained lower than in earlier years.

This report will be updated as developments dictate.

Introduc tion ..................................................................................................................................... 1
Establishment and Evolution of GAO.............................................................................................3
1921 Establishment...................................................................................................................3
Expansion and Extension of Authority and Jurisdiction...........................................................4
Additional Responsibilities.................................................................................................4
Legislative Reorganization Act Changes............................................................................6
Other Duties Assigned to the Comptroller General............................................................6
Changes in Authority.................................................................................................................7
Proposed Changes for GAO in the 110th Congress.........................................................................8
Structure and Organization........................................................................................................8
Pay and Benefits.................................................................................................................8
Deputy Comptroller General’s Appointment......................................................................9
Inspector General................................................................................................................9
Reimbursement of Certain Audit Costs..............................................................................9
Access to Government Records and Information......................................................................9
Auditing of the Intelligence Community................................................................................10
GAO Resources..............................................................................................................................11
Budget Levels..........................................................................................................................12
Personnel Levels.....................................................................................................................12
Personnel System....................................................................................................................13
Antecedent Authority........................................................................................................13
Additional Authority in 2004............................................................................................14
Followup Study and Ongoing Considerations..................................................................15
Employee Representation.................................................................................................16
Appointment of the Comptroller General and Deputy..................................................................17
Current Process.......................................................................................................................18
Recent Nominations................................................................................................................19
Removal, Retirement, and Resignation.........................................................................................20
Remo va l .................................................................................................................................. 20
Retirement and Annuity..........................................................................................................20
Resignation .............................................................................................................................. 22
Concluding Summary....................................................................................................................22
Table 1. GAO Resources, FY1995-FY2009...................................................................................11
Table 2. Comptrollers General, 1921-Present...............................................................................17
Author Contact Information..........................................................................................................24

The Government Accountability Office (GAO)—with more than 3,100 staff positions and an
annual budget exceeding $507 million in FY2008—is the largest of several support agencies that
provide research, review, and analysis for Congress; and it is the only one with a nationwide field 1
structure. GAO, which had been titled the General Accounting Office until 2004, operates under
the control and direction of the Comptroller General of the United States (CG). The head is
appointed by the President—after receiving recommendations from a special bicameral
congressional commission—by and with the advice and consent of the Senate, for a 15-year
nonrenewable term. The position, which had been vacant for two years, was filled in late 1998,
when David M. Walker was sworn in and became only the seventh Comptroller General in
GAO’s history, which began more than eight decades ago. The post is now vacant with Mr. 2
Walker’s resignation on March 12, 2008.
GAO was established as an independent auditor of government agencies and activities by the
Budget and Accounting Act of 1921 (42 Stat. 23). That enactment also created the Bureau of the
Budget, the forerunner to the Office of Management and Budget, and established presidential
authority over the budget formulation process. The basic authority for the office and its head is
codified at 31 U.S.C. 701 et seq. and 3511 et seq. Numerous other statutory provisions affect the
powers and duties of both GAO and the CG.
The office was designed to be “independent of the executive departments,” which were placed
under its audit and review powers (31 U.S.C. 702(a)). Sometimes characterized as “Congress’s
watchdog” and the “investigative arm of Congress,” the GAO provides a variety of services to
Congress, largely connected to the oversight, investigation, and evaluation of executive
operations, activities, and programs.
The evolution of the office’s authority, functions, and mandates over time, along with new pay
and personnel powers for the Comptroller General, prompted him to request a change in its name:
from the General Accounting Office to the Government Accountability Office (P.L. 108-271). 3
GAO’s current activities and services include:

1 The others are the Congressional Budget Office and the Congressional Research Service, along with other entities in
the Library of Congress. A former support agency, the Office of Technology Assessment, was abolished in 1995; and
the Government Printing Office serves different types of functions.
2 U.S. Government Accountability Office,David M. Walker, U.S. Comptroller General, Announces His Early
Departure To Head New Public Interest Foundation,” press release, February 15, 2008; Elizabeth Newell, “GAO chief
announces resignation,Government Executive, available at
dailyfed/0208/021508ts1.htm; Elizabeth Williamson, “Government Accountability Chief Resigns, Washington Post,
February 16, 2008, p. A7; Stephen Barr,Comptroller General Leaving for Love of Country,” Washington Post, March
10, 2008, pp. D1 and D4; Jordy Yager, “Comptroller General vacancy intensifies Bush-Hill battle,” The Hill, available
at, March 12, 2008; and Lindsey Layton, “Hunt for GAO Chief Is Complicated by Gridlock,
Job’s Unique Demands,” Washington Post, Apr. 2, 2008, p. A17.
3 Illustrations of products and services extend from identifyinghigh risk areas in the executive, to conducting
specialized investigations of criminal matters, to auditing a narrow project, to reviewing a broad program, to the
Comptroller General making suggestions for congressional oversight topics. A summary of GAO’s activities and
services appears in CRS Report RL30240, Congressional Oversight Manual, by Frederick M. Kaiser et al. For
elaboration, see U.S. Senate Committee on Governmental Affairs, Oversight of GAO: What Lies Ahead for Congress thst
Watchdog? hearing, 108 Cong., 1 sess. (Washington: GPO, 2003); in addition to GAO publications, all of which are
available from the Government Accountability Office: Fiscal Stewardship: A Critical Challenge Facing Our Nation,
GAO-07-362SP (2007); Fiscal Year 2008 Budget Request: U.S. Government Accountability Office, GAO-07-547T

• auditing and evaluating federal programs and operations;
• conducting special investigations (through a small office) of alleged violations of
federal criminal law, particularly conflict of interest or procurement and contract
• providing various legal services to Congress, including advice on legal issues
involving government programs and activities;
• resolving bid protests that challenge government contract awards;
• prescribing accounting principles and standards for the executive branch,
advising federal agencies on fiscal and other policies and procedures, and setting
standards for auditing government programs;
• assisting the professional audit/evaluation community in improving and keeping
abreast of ongoing developments in such matters as audit methodology and
approaches; and
• detailing GAO staff to work directly for congressional committees (in these
temporary transfers, the assigned staffs represent the committees and not GAO 4
Since 1994, GAO has been the subject of congressional hearings, studies, and
proposals for change connected with its mission, roles, capabilities, and personnel
system. After a lengthy period of growth—in its powers, duties, and resources—the
office experienced reductions in these areas in the mid-1990s. In 1996, for instance,
certain of the “executive powers” of the Comptroller General were abolished or
transferred to executive branch agencies. In addition, GAO’s budget was cut by 25%
over a two-year period (FY1996 and FY1997), representing the largest reduction in a
seven-year downsizing (1992-1999). Since then, however, its budget authority has
increased, from a low of $358 million in FY1998 to a high of $507.2 million for
FY2008. Since 1995, however, full-time-equivalent employees are fewer than in each
previous year, with 3,100 currently compared to 4,324 in FY1995. In fact, in the
midst of the cutbacks during the 1990s, GAO experienced an overall staff reduction
of 39% from FY1992 to FY1998.

(2007); GAO: Transformation, Challenges, and Opportunities, GAO-03-116T ( 2003); GAOs Strategic Plan, 2007-th
2012, GAO-07-1SP (2007); Suggested Areas for Oversight for the 110 Congress, letter to the Congressional
Leadership, from Comptroller General David M. Walker, GAO-07-235R (2006); U.S. General Accounting Office: The
Role of GAO in Assisting Congressional Oversight, statement by J. Christopher Mihm, GAO-02-816T (2002); and
United States Government Accountability Office: Supporting the Congress through Oversight, Insight, and Foresight,
statement of David M. Walker, Comptroller General, GAO-07-644T (2007).
4 The offices criteria, standards, and procedures for responding to congressional requests are contained in U.S. General
Accounting Office, GAOs Congressional Protocols, GAO-04-310G (Washington: GAO, 2004). Its work with federal
agencies is governed by GAOs Agency Protocols, GAO-03-232SP (Washington: GAO, 2002).

The Budget and Accounting Act of 1921, which created the General Accounting Office, built
upon efforts over a considerable period of time to develop a new budget process and involved 5
trade-offs between the legislature and executive. The legislation gave the President substantial
responsibilities and authority over the federal budget formulation process. To assist in this
endeavor, the statute also created the Bureau of the Budget in the Treasury Department. (The
bureau was later moved to the Executive Office of the President and is now known as the Office
of Management and Budget.) As a counterweight to these enhancements of executive power in
the budget process, Congress established the General Accounting Office in the legislative branch,
in large part through the transfer of comptroller and auditor duties from the Treasury Department.
Congressional work on what was to become the 1921 act began two years earlier with legislative
proposals to transfer the duties and responsibilities of the comptrollers and auditors from the
Treasury Department to an entity independent of the executive departments and, indeed, located
in the legislative branch. This initial legislation was vetoed by President Woodrow Wilson, who
objected to a section allowing for the removal of the new Comptroller General by Congress alone, 6
through a concurrent resolution. This provision was later changed to allow for the removal of the
Comptroller General by adoption of a joint resolution. The joint resolution, which must be signed
by the President, is subject to presidential veto and the possibility of a veto override.
The 1921 act abolished the post of Comptroller and Assistant Comptroller of the Treasury, along
with the six auditors in the department. Their personnel, records, and resources were transferred
to the new General Accounting Office. The establishing authority also vested GAO with the
powers and responsibilities of the auditors and Comptroller of the Treasury, some of which dated
to the Treasury Act of 1789.

5 For background on the establishment and evolution of GAO and the Comptroller General, see, among others: Darrell
Hevenor Smith, The General Accounting Office: Its History, Activities, and Organization (Baltimore: Johns Hopkins
University Press, 1927); Harvey C. Mansfield, The Comptroller General (New Haven, CT: Yale University Press,
1939); Thomas D. Morgan, “The General Accounting Office: One Hope for Congress to Regain Parity of Power with
the President,North Carolina Law Review, vol. 51, October 1973, pp. 1279-1368; Frederick C. Mosher, The GAO:
The Quest for Accountability in American Government (Boulder, CO: Westview Press, 1979); A Tale of Two Agencies:
A Comparative Analysis of the General Accounting Office and the Office of Management and Budget (Baton Rouge,
LA: Louisiana State University Press, 1984); Joseph Pois, Watchdog on the Potomac: A Study of the Comptroller
General of the United States (Washington: University Press of America, 1979); Roger R. Trask, GAO History, 1921-
1991, GAO Report OP-3-HP (Washington: GAO, 1991), along with a series of historical studies produced by GAO; rdst
U.S. Joint Committee on the Organization of Congress, Support Agencies, hearing, 103 Cong., 1 sess. (Washington:
GPO, 1993), pp. 5-27, 287-375; Frederick M. Kaiser, “The Comptroller General: History and Independence, in U.S.
Senate Committee on Government Operations, Subcommittee on Reports, Accounting, and Management, GAO thst
Legislation, hearing, 94 Cong., 1 sess. (Washington: GPO, 1975); U.S. Senate Committee on Governmental Affairs,
The Roles, Mission and Operation of the U.S. General Accounting Office: A Report by the National Academy of Public rdnd
Administration, Senate Print 103-87, 103 Cong., 2 sess. (Washington: GPO, 1994); Wallace E. Walker, Changing
Organizational Culture: Strategy, Structure, and Professionalism in the U.S. General Accounting Office (Knoxville:
University of Tennessee Press, 1986); and Jonathan Walters and Charles Thompson, The Transformation of the
Government Accountability Office: Using Human Capital to Drive Change (Washington: IBM Center for The Business
of Government, 2006).
6 President Wilsons veto message and the House action, which sustained the veto by a vote of 178 to 103, are recorded
in Congressional Record, vol. 59, June 4, 1920, pp. 8609-8613.

Along with this, the originating legislation gave the Comptroller General broad authority to
“investigate, at the seat of government or elsewhere, all matters relating to the receipt,
disbursement, and application of public funds” (42 Stat. 25). To augment this, the Comptroller
General was given extensive access to information in “all departments and establishments ...
regarding the powers, duties, activities, organization, financial transactions, and methods of
business of their respective office as he may from time to time require” (42 Stat. 26).
Adding to the new position, the law authorized the Comptroller General to recommend legislation
“to facilitate the prompt and accurate rendition and settlement of accounts and concerning such
other matters relating to the receipt, disbursement, and application of public funds as he may
think advisable” (42 Stat. 25-26). The initial authority, moreover, established new requirements
for reporting to Congress and directed the Comptroller General to make special investigations and
reports when ordered by either House of Congress or by any committee with jurisdiction over
revenue, appropriations, and expenditures.
Since 1921, the scope of GAO’s powers, mandates, and jurisdiction has been expanded by public 7
laws. Its current functions, duties, and extensive jurisdiction (with a few notable exceptions)
have grown out of its powers over finances and expenditures of the federal government, the two
major legislative branch reorganizations (in 1946 and 1970), and specific additions to the
Comptroller General’s responsibilities and authority.
Additional responsibilities and authority have accrued over time.
The Government Corporation Control Act of 1945, for instance, granted GAO audit authority
over mixed-ownership government corporations (59 Stat. 600-601). And the Budget and
Accounting Procedures Act of 1950 directed the Comptroller General to prescribe principles and
standards for accounting in executive agencies (64 Stat. 835). Building on this, the Federal
Manager’s Financial Integrity Act of 1982 required each agency to establish internal accounting
and administrative controls in accordance with standards prescribed by the Comptroller General
(96 Stat. 814). In addition, the Chief Financial Officers Act of 1990 gave the Comptroller General
enhanced audit authority and the power to review financial audits conducted by an inspector
general or an external auditor (104 Stat. 2852-2854).

7 Exceptions to GAOs jurisdiction over executive branch and independent agencies are (1) the Central Intelligence
Agency, which views its own statutory authority as exempting it from GAO audits and reviews (e.g., the Central
Intelligence Agency Act of 1949, 63 Stat. 213, and the General Accounting Office Act of 1980, 94 Stat. 311); and (2)
foreign operations and money market policies of the Federal Reserve (31 U.S.C 714(b)). In addition, the President may
proscribe GAO access to certain foreign intelligence and counterintelligence information and prevent its auditing of
unvouchered funds involved in such areas (31 U.S.C. 716(b) and 3524(c)). This matter is discussed further below.

Along these same lines, GAO has a prominent role in monitoring and reviewing the development
and implementation of the Government Performance and Results Act of 1993 (GPRA) (107 Stat. 8
285). GAO has been involved not only in the training of executive personnel and congressional
staff who are to implement and oversee GPRA, but also in the evaluation of pilot programs,
strategic plans, annual performance plans and goals, and followup reports from the agencies.
In the 106th Congress, GAO was authorized to review federal agency rules and regulations, under
the Truth in Regulating Act of 2000. But the program was not implemented because of a lack of 9
In order to fulfill its mission, the Government Accountability Office has been given broad powers
to gain access to information and materials of government entities, based on its original authority
as well as later supplements (31 U.S.C. 712 and 716), with several exceptions. These powers are
designed to provide access—fully and directly in most cases—or, barring that, provide an
auxiliary means to compel recalcitrant offices to release information. To enforce this, the
Comptroller General has power, rarely used, to sue a noncomplying agency for the production of
requested records (31 U.S.C. 716). Under this authority, the CG makes a written request to the
agency head, who has 20 days to explain why the records are not being made available. At that
time, the Comptroller General may file a report with the President, the Director of the Office of
Management and Budget, the head of the relevant agency, and Congress. Twenty days after this
action, the CG may file suit in the district court for the District of Columbia to require the agency
head to produce the requested records.
An attempt to use this authority in 2001 resulted in a conflict with the executive. In this case, the
Comptroller General was denied access to records of an executive commission—the National
Energy Policy Development Group (NEPDG), established by a presidential memorandum and 10
headed by the Vice President. Still denied access after issuing a demand letter, the Comptroller

8 For an overview of and further citations to GPRA and GAOs involvement, see U.S. General Accounting Office,
Executive Guide: Effectively Implementing the Government Performance and Results Act, GAO Report GGD-96-118
(Washington: GAO, 1996); Managing for Results: Using GPRA to Assist Congressional and Executive Branch
Decisionmaking, T-GGD-97-43 (Washington: GAO, 1997); and Mihm, The Role of GAO in Assisting Congressional
9 P.L. 106-312 established a three-year pilot program, whereby the Comptroller General would review any
economically significant rule (e.g., a rule having an annual impact of $100 million on the economy or other specified
economic effects), at the request of a chairman or ranking member of any committee of jurisdiction, and report his
findings to Congress. Background information and debate on these proposals are included in: U.S. Congress, Senate
Committee on Governmental Affairs, Congressional Accountability for Regulatory Information Act of 1999; Report to
Accompany S. 1198, S.Rept. 106-225 (Washington: GPO, 1999); and Congressional Record, vol. 146, pp. S3782-S
3785 and H6851-H6855.
10 Walker v. Cheney, 230 F.Supp.2nd 51 (D.D.C., 2002). For further coverage, see Louis Fisher, “Congressional Access
to Information: Using Legislative Will and Leverage,” Duke Law Journal, vol. 52, 2002;CRS Report RL31397, Walker
v. Cheney: Statutory and Constitutional Issues Arising From the General Accounting Offices Suit Against the Vice
President, by T. J. Halstead; and T. J. Halstead, “Walker v. Cheney: Legal Insulation of the Vice President from GAO
Investigations,” Presidential Studies Quarterly, vol. 33, September 2003. The principals’ statements are available at

General sued. In 2002, however, the District Court for the District of Columbia held in Walker v.
Cheney that GAO lacked standing to sue the Vice President to compel the release of information
pertaining to NEPDG. The decision has not been appealed. Legislation (H.R. 6388) has been th
introduced in the 110 Congress—by Representative Henry Waxman, chairman of the House
Committee on Oversight and Government Reform, for himself and 18 other House chairs—that
would, in effect, override Walker v. Cheney, by augmenting the CG’s authority to gain access to 11
such records. The bill would also affirm GAO’s right to obtain records from three specified
agencies (i.e., Centers for Medicare and Medicaid Services, Federal Trade Commission, and Food
and Drug Administration). Furthermore, H.R. 6388 would expand GAO’s authority to administer
oaths and give it express powers to interview federal employees when conducting evaluations and
Major legislative reorganization efforts have also augmented GAO’s powers and independence.
The Legislative Reorganization Act (LRA) of 1946 specifically directed the Comptroller General
“to make an expenditure analysis of each agency in the executive branch of Government
(including Government corporations), which, in the opinion of the Comptroller General, will
enable Congress to determine whether public funds have been economically and efficiently
administered and expended” (60 Stat. 837). In the 1970 LRA, Congress significantly expanded
GAO’s assistance to congressional committees and strengthened its program evaluation
responsibilities (84 Stat. 1167-1171).
In addition to the office’s assignments and powers, the Comptroller General himself has been
given a variety of specific responsibilities in public law, some of which are temporary while
others are permanent. Over the years, these have included the power to bring suit to require the
release of impounded funds (2 U.S.C. 687); a duty to impose civil penalties under the Energy
Policy and Conservation Act of 1975 (42 U.S.C. 6385(a)); the assignments to serve as a member
of the Chrysler Corporation Loan Guarantee Board (15 U.S.C. 1862) and of the Board of
Directors of the United States Railway Association (45 U.S.C. 711(d)); and the authority to
consider bid protests under the Competition in Contracting Act of 1984 (31 U.S.C. 3551-3556).

(...continued); Richard Cheney, U.S. Vice President, “Letter to the House of
Representatives,” August. 2, 2001; and U.S. General Accounting Office, “Statement on the NEPDG, 2001,Letter to
Vice President Cheney, July 18, 2001, “Report to the House of Representatives, August 17, 2001, and “Decision of
the Comptroller General Concerning NEPDG Litigation,” January 30, 2002, available at
11 Government Accountability Act of 2008, H.R. 6388, 110th Cong., 2nd sess. U.S. Congress, House Committee on
Oversight and Government Reform, “Statement of Rep. Henry A. Waxman on the Introduction of the Government
Accountability Act,” June 26, 2008; “Committee Chairs Introduce Bill to Strengthen GAO, Press release, June 27, thnd
2008; and Government Accountability Act of 2008, H.Rept. 110-771, 110 Cong., 2 sess. See also, Dan Friedman,
Panel approves bill allowing GAO to sue agencies,” Government Executive, July 16, 2008, available at; Ralph Lindeman, “House Approves Measure
to Give GAO Additional Investigative Powers,” Daily Report for Executives, BNA, Inc., July 30, 2008, p. A-1; and
House bill would give GAO more clout,” Federal Times, Aug. 4, 2008, p. 4.

The Comptroller General, along with the Secretary of the Treasury and Director of OMB, serves
as a principal on the Federal Accounting Standards Advisory Board. It considers and recommends
issuance of accounting standards and principles and provides interpretations of existing ones.
Previously, the CG had co-chaired the Cost Accounting Standards Review Panel, consisting of
public officials and defense industry representatives. It had examined operations and activities of
the Cost Accounting Standards Board (CASB), an executive agency in OMB (41 U.S.C. 422).
In the aftermath of the devastating Gulf Coast hurricanes of 2005, the Comptroller General joined
inspectors general from appropriate agencies in a new Hurricane Katrina Contract Audit Task
Force. It serves as a means of coordinating the efforts of federal organizations auditing the Gulf
Coast Recovery Program. Besides GAO, these include offices of inspector general in the
Departments of Defense, Homeland Security, Housing and Urban Development, Health and
Human Services, and Transportation, as well as the Environmental Protection Agency and
General Services Administration.
The Comptroller General also chaired the Commercial Activities Panel (CAP), a now-defunct
interagency group consisting of representatives from executive departments (i.e., the Office of
Personnel Management and Department of Defense), as well as from private organizations and
public sector unions. The congressionally mandated panel, which completed its mission in 2002,
studied and made recommendations for improving the policies and procedures governing the 12
transfer of commercial activities from the government to contractor personnel.
Several different types of changes in the authority of GAO and the CG have occurred since the
In 1985, a constitutional conflict arose over powers delegated to the Comptroller General, when
Congress gave him specific budget-reduction authority under the Balanced Budget and Deficit 13
Control Act. The CG was to review recommendations about such reductions and report his
findings to the President, who, in turn, was to issue a sequestration order mandating spending
reductions specified by the CG. Additional legislative mechanisms (or “fallback” provisions) to
cut spending were also included in the statute. The Supreme Court held, however, that the
delegation of authority to the CG was unconstitutional, concluding that “the powers vested in the
Comptroller General under section 251 violate the command of the Constitution that the Congress 14
play no direct role in the execution of the laws.”
In contrast to GAO’s long-term expansion over decades, the mid-1990s witnessed a cutback in its
authority and, perhaps more importantly, its resources (discussed below). The 1996 General
Accounting Office Act abolished or transferred—to the Director of the Office of Management and
Budget or the head of an executive department or agency—certain specific “executive” powers of
the Comptroller General (110 Stat. 3826 and 3838-3840). These related to his authority to make
certain determinations about executive assistance and services, resolve disputes over certain

12 David M. Walker, Commercial Activities Panel: Improving Sourcing Decisions of the Federal Government, GAO-
02-866T, June 26, 2002; and U.S. Commercial Activities Panel, Improving Sourcing Decisions of the Government:
Final Report (Washington: CAP, 2002).
13 Sec. 251, P.L. 99-177, 99 Stat. 1038 (1985).
14 Bowsher v. Synar, 478 U.S. 714, at 734 (1986).

purchases made by executive agencies, conduct identified audits of executive accounts, or
prescribe regulations for specified executive operations.

A number of proposals in the 110th Congress would affect GAO’s organization, structure, and
In July 2007, the Comptroller General called for changes in a number of areas, changes that have th
been included, as requested or modified, in legislative proposals in the 110 Congress. The initial
version of the Government Accountability Office Act, H.R. 3268, was introduced at the request of
the CG; and an amended version, H.R. 5683, has passed the House and Senate and has been sent 15
to the White House. The various transformations would affect GAO’s pay and personnel system,
retirement pay, voluntary separation incentive payments, the CG’s annuity level, reimbursement
of audit costs, administering oaths, appointment of the deputy, and the office of inspector general.
If signed into law, H.R. 5683 would modify the CG’s authority over pay rates for GAO officers
and employees. One provision, for instance, would allow them to rise to level III of the Executive
Schedule (EX), instead of the current GS-15 ceiling, while another would grant more discretion to
the Comptroller General in determining pay for several high-ranking positions now paid by
reference to the EX Schedule; these posts are the Comptroller General, deputy, general counsel,
and up to 20 experts and consultants. The legislation would also set new requirements for future
annual pay adjustments and respond to past pay discrepancies. With regard to the latter, a
proposal would grant pay adjustments for certain employees and officers, including a lump-sum
payment for officers and employees who failed to receive certain pay increases in 2006 and 2007.
Another modification, in H.R. 3268 but not H.R. 5638, would set the Comptroller General’s
annuity at EX level II. (Discussed further below.)

15 U.S. Congress, House Committee on Oversight and Government Reform, Subcommittee on Federal Workforce,
Postal Service, and the District of Columbia, GAO Personnel Reform, hearings, 110th Cong., 1st sess., May 22, 2007; thnd
Government Accountability Act of 2007, hearings, 110 Cong., 2 sess., March 13, 2008, and Government thnd
Accountability Office Act of 2008: Report to Accompany H.R. 5683, H.Rept. 110-671, 110 Cong., 2 sess., both
available at; and “Government Accountability Act of
2008,” Congressional Record, daily ed., June 9, 2008, vol. 154, pp. H5080-H5084, and Congressional Record, daily
ed., Aug. 1, 2008, vol 154, pp S8070-S8073. See also Dan Friedman, “Panel targets GAO pay system,” March 13,
2008, and “Houses passes GAO pay bill, minus investigative provisions,” June 10, 2008, and Brittany R. Ballenstedt,
“Lawmakers seek remedy for GAO pay reform,” March 14, 2008, “Panel approves bill to restore back raises to GAO
employees,” May 23, 2008; “Senate passes bill to restore back pay to GAO employees,” Aug. 4, 2008; and “House
sends GAO pay bill to President Bush,” Sept. 9, 2008; all in Government Executive, available at; and Nancy Ognanovich, “After Senate Vote, Conference Likely
on Legislation to Reform, Strengthen GAO, Daily Report for Executives, BNA, Inc., Aug. 5, 2008, p. A-7.

The appointment process for the Deputy Comptroller General would be transformed—under H.R.
3268 but not H.R. 5683—allowing the Comptroller General to appoint the deputy, after
consultation with a special congressional commission. The new process would end the current
arrangement in which the deputy, whose post has been vacant for nearly 30 years, is a presidential
nominee subject to Senate confirmation.
The establishment of a statutory inspector general (IG), also contained in H.R. 5683, would
replace the current administrative construct. The new office would mirror but not duplicate its
counterparts in “designated federal entities”—usually the smaller agencies, boards, commissions,
foundations, and government corporations, where the IG is appointed by and can be removed by 16
the agency head—now operating under the Inspector General Act of 1978, as amended. The
new statutory inspector general at GAO, to be selected without regard to political affiliation,
would be appointed by and removable by the Comptroller General, who could not, however,
prevent the IG from carrying out his or her duties. The inspector general would be responsible for
combating waste, fraud, and abuse in GAO and keeping the Comptroller General and Congress
currently and fully informed concerning such matters, by way of semi-annual reports and
otherwise. Statutory offices of inspector general, incidently, have previously been established in
four other legislative branch entities: the Architect of the Capitol Office, Government Printing
Office, Library of Congress, and U.S. Capitol Police, all of which allow for the agency head (or a
board) to appoint and remove the inspector general.
Another provision in H.R. 5683 calls for the reimbursement of certain audit costs by executive
agencies (or components thereof), beginning in FY2009. They would have to reimburse GAO for
its costs associated with auditing their annual financial statements or related schedules prepared
under 31 U.S.C. 3515—which covers all accounts and associated activities—under certain
conditions. The revenue from the reimbursements would be deposited in a special account in the
Treasury, to be made available to GAO as specified in its annual appropriations acts.
A conflict with the executive arose in 2001 over GAO’s independent access to certain executive
branch records, in this case, those of the National Energy Policy Development Group, headed by
the Vice President. In 2002, as noted above, a federal district court in Cheney v. Walker held that 17
GAO lacked access to the records. In response, Representative Henry Waxman, for himself and
18 other chairs, introduced the Government Accountability Act of 2008 (H.R. 6388) that would
augment the CG’s power to gain access to such records as well as those from three specified
agencies (Centers for Medicare and Medicaid Services, Food and Drug Administration, and

16 5 U.S.C. Appendix. For background, see CRS Report 98-379, Statutory Offices of Inspector General: Past and
Present, by Frederick M. Kaiser.
17 Citations in footnote 10 above.

Federal Trade Commission).18 The legislation, which has been approved by the House, would
also expand GAO’s authority to administer oaths and give it express powers to interview federal
employees when conducting evaluations and investigations. Another provision in the bill creates a
reporting mechanism, so that Congress would be informed when federal agencies fail to
cooperate with the office.
As noted above, the Government Accountability Office possess nearly unfettered jurisdiction to
audit and investigate the federal government. GAO’s access, however, may be precluded in
certain situations: by the President, if it involves sensitive or classified records, such as foreign
intelligence and counterintelligence activities; in instances where the records are statutorily
exempted from disclosure (31 U.S.C. 716(d)); or in cases where an executive agency holds 19
competing powers which prevent GAO access.
The last of these proscriptions has led to conflicts between the Government Accountability Office 20
and the Intelligence Community (IC), particularly the Central Intelligence Agency (CIA). th
Legislation has been introduced in the 110 Congress to clarify GAO’s auditing the IC, with 21
hearings held in 2008.
The CIA views its own statutory authority as keeping it off-limits to independent GAO audits and
investigations. Under its interpretation, the CIA has declined to participate in GAO reviews (as
well as in some congressional oversight hearings held by panels other than the Select Committees
on Intelligence). Other IC components, however, have not asserted the same proscription to GAO
audits. In contrast to the CIA’s stand, for instance, the Department of Defense has issued the
following instructions:
It is DoD policy that the Department of Defense cooperate fully with the GAO and respond
constructively to, and take appropriate corrective action on the basis of, GAO reports .... [But
DoD is also to] be alert to identify errors of fact or erroneous interpretation in GAO reports, 22
and to articulate the DoD position in such matters, as appropriate.
GAO has taken exception to the CIA’s position, emphasizing that the Office has authority to audit 23
the Agency independently but lacks enforcement power. If enacted, the Intelligence Community

18 Citations in footnote 11 above.
19 See footnote 7 for statutory citations.
20 Background to the conflict is covered in Frederick M. Kaiser, “GAO Versus the CIA: Uphill Battles Against an
Overpowering Force,International Journal of Intelligence and Counterintelligence, vol. 15, Summer 2003, pp. 330-
21 The Intelligence Community Audit Act, H.R. 978 and S. 82, 110th Cong. U.S. Congress, Senate Subcommittee on
Oversight of Government Management, the Federal Workforce, and the District of Columbia, Government-wide thnd
Intelligence Community Management Reforms, hearings, 110 Cong., 2 sess., Feb. 29, 2008, available at
22 Department of Defense Instruction 7650.02, November 20, 2006.
23 Elaboration of GAOs support for such new authority and the DNI’s (and the previous DCI’s) opposition appears in:
letter from David M. Walker, Comptroller General, to Hon. John D. Rockefeller, Chairman, and Hon. Christopher S.
Bond, Vice Chairman, Senate Select Committee on Intelligence, March 1, 2007; and letter from J. M. McConnell,
Director of National Intelligence, to Hon. John D. Rockefeller, Chairman, and Christopher S. Bond, Vice Chairman,
Senate Select Committee on Intelligence, Mar. 7, 2007. See M.Z. Hemingway,GAO wants more muscle, Federal
Times, March 26, 2007, p. 1; and “GAO Seeks Greater Role in Oversight of Intelligence,” Secrecy News, Oct. 3, 2007,

Audit Act would change this situation. These and similar proposals, which were first raised in the
mid-1970s, are designed to “reaffirm the authority of the Comptroller General to audit and 24
evaluate the programs, activities, and financial transactions of the intelligence community.”

GAO’s budget and staffing levels have varied since the mid-1990s, experiencing both downs and
ups, with a current leveling off as continuing resolutions have tended to stabilize both figures.
The Government Accountability Office, like the other congressional support agencies, operates
under a permanent authorization and an annual appropriation. A proposal in 1994, based on the
recommendations of the Joint Committee on the Organization of Congress, would have mandated
an eight-year authorization period for all congressional support agencies to replace their 25
permanent authorizations. No action, however, was taken on the recommendation.
Table 1 provides statistics on total new budget authority (gross) and on full-time equivalent
employees (FTEs) for GAO from FY1995 through FY2009 (requested).
Table 1. GAO Resources, FY1995-FY2009
Fiscal Year Total New Budget Authority (gross) (in millions of dollars) FTEsb
2009a 545.5 3,251
2008 507.2c 3,100b
2007 488.6 3,152
2006 488 3,194
2005 475 3,215

available at For the competing views of the disputes over independent GAO access, which date to
the earliest days of the CIA, see U.S. Central Intelligence Agency, DCI Affirmation of Policy for Dealing with the
General Accounting Office (GAO), Memorandum for the Director of Central Intelligence, from Stanley L. Moskowitz,
Director of Congressional Affairs, 7 July 1994; U.S. General Accounting Office, Central Intelligence Agency:
Observations on GAO Access to Information on CIA Programs and Activities, statement of Henry J. Hinton, GAO-01-
975T (2001); letters from the Comptroller General to the Director of National Intelligence (DNI), April 27, 2006, and
to the Chairman and Ranking Minority Member of the Senate Committee on Homeland Security and Governmental
Affairs, May 15, 2006, disagreeing with the DNI’s position that thereview of intelligence activities is beyond the
GAO’s purview, as stated in Information Sharing, GAO-06-385 (2006), pp. 6 and 71.
24 H.R. 978 and S. 82, 110th Congress. See U.S. Congress, Senate Subcommittee on Oversight of Government
Management, the Federal Workforce, and the District of Columbia, Government-wide Intelligence Community Reform, thnd
hearings, 110 Cong., 2 sess., February 29, 2009, available at;
and “Panel witnesses press for GAO audits of intelligence agencies,” Government Executive, available at, February 29, 2008.
25 Legislative Reorganization Act of 1994, S. 1824, 103rd Congress. The House and Senate Members of the Joint
Committee issued separate reports, but both agreed to the specific recommendation of ending the permanent
authorization status for congressional support agencies. U.S. Congress, Joint Committee on the Organization of the rdst
Congress, Organization of the Congress: Final Report of the House Members, H.Rept. 103-413, vol. I, 103 Cong., 1 rdst
sess., p. 20, and Organization of the Congress: Final Report of the Senate Members, S.Rept. 103-215, 103 Cong., 1
sess. (Washington: GPO, 1993), p. 17.

Fiscal Year Total New Budget Authority (gross) (in millions of dollars) FTEsb
2004 468 3,224
2003 458 3,269
2002 436 3,210
2001 405 3,11
2000 380 3,275
1999 368 3,27
1998 358 3,24
1997 359 3,341
1996 379 3,677
1995 448 4,342
a. The FY2009 amounts are GAO’s requests in its budget submission to Congress: GAO, Fiscal Year 2009
Budget Request: U.S. Government Accountability Office, GAO-08-616T, April 10, 2008, pp. 1 and 5. An earlier
request of $549 million was included in the President’s budget submission: U.S. Office of Management and
Budget (OMB), Budget of the United States Government for Fiscal Year 2009, Appendix, (Washington: GPO,
2008), p. 47. For additional information on annual appropriations for GAO and the Legislative Branch, see
CRS Report RL34490, Legislative Branch: FY2009 Appropriations, by Ida A. Brudnick.
b. Full-time equivalent employees (FTEs) are the maximum number of such positions authorized. The number
of actual on-duty employees at any one time may be larger than the FTEs, because of part-time employment
of some. Alternatively, the total of on-duty staff may be fewer than the FTEs, because of pre-hiring
requirements, retirements, resignations, and/or insufficient funding to reach the authorized level. The
FY2008 figure of 3,100 is the number GAO has estimated. OMB, FY 2009 Budget, Appendix, p. 47.
c. P.L. 110-161, Consolidated Appropriations Act for FY2008, Division H, provides $501 million in direct
appropriations plus $7.5 million in transfers, for a total of $508.5 million. An across-the-board rescission of
0.25% reduces this amount by $1.27 million, leaving $507.2 million for FY2008. See GAO, Fiscal Year 2009
Budget Request, p. 5.
GAO’s budget authority and personnel levels have fluctuated since the mid-1990s. At that time,
the office experienced a substantial cut in its funding, with a combined 25% reduction in total
new budget authority for fiscal years 1996 and 1997, by comparison to its FY1995 total. This
continued a downward trend that had begun in FY1992 and ebbed in FY1998. Since then, GAO’s
budget level has risen each year. And over the past decade, it has increased nearly 30%, from
$358 million in FY1998 to $507.2 million in FY2008 and $545.5 million requested for FY2009.
In the mid-1990s, GAO also experienced a significant reduction in its personnel levels, as a result
of the budget cuts. Because employee compensation constitutes about 80% of GAO’s budget, its
cost-saving actions resulted in a sizable staff downsizing at the time. According to 1997
testimony by the Acting Comptroller General, the cutbacks “have necessitated a loss of people.

Today, as a result of those reductions, GAO staffing is at its lowest level since before World War 26
In 1999, Comptroller General David Walker elaborated on the effects of the seven-year
downsizing of GAO (from FY1992 through FY1998). One result was a 39% reduction in its
workforce during that span, from 5,325 in FY1992 to 3,245 in FY1998. In 1999 testimony, the
CG recounted that the office also
instituted a reduction-in-force; closed regional offices; imposed a 5-year hiring freeze;
eliminated performance rewards; curtailed technology investments; and reduced travel,
training, supplies, and other support costs to achieve the overall mandated reduction in
spending. GAO is now facing a number of critical human capital, information technology, 27
and work process challenges that it needs to address.
GAO’s budget and personnel requests dealt with some of these areas since then. But the office
has not seen its staff size exceed the 3,275 FTEs in FY1999 and FY2000; and it witnessed smaller
numbers in the two following years (with 3,110 in FY2001 and 3,210 in FY2002). By comparison
to these low figures, however, personnel levels rose to 3,269 FTEs in FY2003. Nonetheless,
recent final FTE statistics show a continuing downsizing each year since FY2003—from 3,269 in 28
that year to 3,100 in FY2008, the lowest total of the past 13 years (see Table 1). If approved, the
requested number of positions for FY2009—3,251—would reverse this trend.
Legislation enacted in 2004 granted the Comptroller General certain personnel flexibilities over
the GAO workforce. This augmented authority from 1980, 1988, and 2000, which provided the
basis for the personnel system at GAO.
The General Accounting Office Personnel Act of 1980 was designed to construct an “independent
personnel system” (P.L. 96-191, 94 Stat. 27). The new structure replaced GAO’s reliance on
requirements from several executive branch entities, especially the Office of Personnel
Management (OPM) and the Merit System Protection Board. According to the Senate Committee
on Governmental Affairs, which reported the proposal favorably, “this independence from 29
regulation by executive branch entities is the principal objective of the legislation.” The change,
requested by the Comptroller General, was seen as necessary to remove even the appearance of a
conflict of interest, as GAO had increased oversight of these agencies and the federal personnel

26 James F. Hinchman, Acting Comptroller General, U.S. General Accounting Office, Fiscal Year 1998 Budget
Estimates for the U.S. General Accounting Office, GAO T-OCG-97-01 (Washington: GAO, 1997), p. 4. See also
GAO’s Downsizing Efforts, GAO T-OCG-96-4 (Washington: GAO, 1996).
27 U.S. Congress, House Subcommittee on Legislative Appropriations, Legislative Branch Appropriations for 2000,
hearings, 106th Cong., 1st sess. (Washington: GPO, 1999), part 2, pp. 203-204. Also, see GAO testimonies on this
matter: T-OCG-99-22 and T-OCG-99-24 (Washington: GAO, 1999), pp. 8-10 and 19.
28 In fact, GAOs FY2009 budget submission asserted that(o)ur FTE level in fiscal year 2008 is 3,100—the lowest
level ever for GAO.GAO, Fiscal Year 2009 Budget Request, GAO-08-616, p. 4.
29 U.S. Senate Committee on Governmental Affairs, General Accounting Office Personnel Act of 1979, S.Rept. 96-540,
96th Cong., 1st sess. (Washington: GPO, 1979), p. 2.

system.30 This first installment gave the CG authority to “appoint, pay, assign, and direct such
personnel as the Comptroller General determines necessary to discharge the duties and functions
of the General Accounting Office” (94 Stat. 27). Accompanying this general grant were
requirements to meet specified provisions of Title 5 of the U.S. Code, which set merit system
principles and prohibit certain personnel practices, among other matters (94 Stat. 27).
Amendments to the personnel act were approved in 1988 (P.L. 100-426, 102 Stat. 1598-1602).
These revised provisions concerned GAO’s personnel appeals board membership and judicial
review of its decisions. The amendments also changed the retirement qualifications for the
Comptroller General and Deputy, allowing them to remain in office past the otherwise mandatory
retirement age of 70; and the statutory changes brought the CG’s survivor benefits into
conformity with those available to federal judges.
In 2000, the CG’s powers over personnel were enhanced through a three-year pilot program 31
allowing for specific personnel flexibilities (P.L. 106-303, 114 Stat. 1063-1070). This legislation
gave qualified authority to the Comptroller General to offer certain voluntary separation
incentives, along with early retirements, and to implement a reduction in force.
The GAO Human Capital Reform Act of 2004 (P.L. 108-271) granted the Comptroller General
additional authority over pay and personnel. The enactment allows the Comptroller General to
offer early retirement and buy-out incentives; establish an exchange program with the private 32
sector; and make employee relocation benefits more flexible. Another far-reaching provision
permits him to set annual pay raises tied more closely with performance appraisal ratings (as
opposed to granting automatic yearly increases). In so doing, the CG could also use factors other
than the Consumer Price Index, Employment Cost Index, and locality pay surveys to determine 33
the amounts. Other sections, emerging after congressional committee deliberations, are designed
to meet several objectives: protect the merit principle of “equal pay for work of equal value,”
keep the pay rates of employees who have been demoted because of workforce restructuring or

30 Ibid.
31 An article on changes at GAO at the time is by Susannah Zak Figura, “The Human Touch,Government Executive,
September 2000, pp. 22-27.
32 See U.S. Congress, Senate Committee on Governmental Affairs, GAO Human Capital Reform Act of 2003, S.Rept.
108-216, 108th Cong., 1st sess. (Washington: GPO, 2003); U.S. Congress, House Committee on Government Reform,
GAO Human Capital Reform Act of 2003, H.Rept. 108-380 (Washington: GPO, 2003); U.S. Congress, House
Committee on Government Reform and Senate Committee on Governmental Affairs, hearings on H.R. 2751 and S. thst
1522, 108 Cong., 1 sess., respectively; U.S. General Accounting Office, GAO: Additional Human Capital
Flexibilities Are Needed, Statement by David M. Walker, Comptroller General, Report GAO-03-1024T (Washington:
GAO, 2003); and U.S. General Accounting Office, GAOs Proposed Human Capital Legislation: View of the Employee
Advisory Council, Statement by Christopher A. Keisling, Council Member, Report GAO-03-1020T (Washington:
GAO, 2003); and GAO, Fiscal Year 2004 Budget Request (2003). A summary of GAO’s implementation appears in
GAO, 2006 Report on GAOs Use of the Provisions in the GAO Personnel Flexibilities Act of 2000 and the GAO
Human Capital Reform Act of 2004, Report GAO-07-289SP (2007). See also Mollie Ziegler, “GAO shifts to market
wages, Federal Times, January 28, 2005, p. 1; and Stephen Barr,GAO Chief Aims to Raise the Bar on Pay Raises,
Washington Post, July 6, 2003, p. C2, and “Other Agencies May Learn from GAO’s Pay, Classification Review,
Washington Post, May 13, 2004, p. B2.
33 GAO contracted with Watson Wyatt to assist in developing a new market-based compensation system for the
agencys employees. “Contract Awarded to Develop Market-Based Pay Scales for Analysts, Attorneys, and
Specialists,” GAO Management News, vol. 31, July 26-30, 2004.

job reclassification at their current levels, and set qualifications on exchanges with the private
As described by the Comptroller General, the overall transformation is intended to “further
GAO’s ability to enhance our performance, assure our accountability, and ensure that we can
attract, retain, motivate, and reward a quality and high-performing workforce currently and in 34
future years.” Changes in this realm and their source—coming from Congress’s largest support
agency and its chief examiner of executive personnel systems—attracted widespread attention
and considerations of a number of matters connected with it, both favorable and not.
A followup report—issued in mid-2005 under the auspices of the IBM Center for the Business of
Government—provides initial responses to these questions, based on an examination of the 35
changes under GAO’s new personnel system.
The report concluded that GAO successfully used human capital management, broadly defined, to 36
drive its organizational transformation. The authors extended this notion, recommending that
“other agencies would do well to heed the lessons of the federal government’s chief
accountability office as they go about the critical work of reinventing their own personnel
systems.... In particular, GAO has five basic lessons to teach the rest of the federal 37
government.” These are the need to move cautiously when pushing major change; the need for
strong workforce planning; the need to emphasize more targeted recruitment, hiring, and retention
policies; the need to beef up investments in systems for the selection and training of managers; 38
and the need for a fair, unbiased, and transparent system for employee appeals.

34 Walker, GAO: Additional Human Capital Flexibilities Are Needed, p. 5. For elaboration, see also David M. Walker,
“GAO: A Case Study in Human Capital Reform, The Federal Manager, Spring 2008, pp. 3-7; and GAO, U.S.
Government Accountability Office: Human Capital Initiatives and Additional Legislative Authorities, GAO-08-573T,
statement of Gene L. Dodaro, Acting Comptroller General of the United States (Washington: GAO, 2008).
35 Walters and Thompson, The Transformation of GAO.
36 Ibid., p. 4. In terms of its review of GAO’s experience, however, the IBM report has certain limitations. Importantly,
it does not provide details about the methodology used to analyze and assess the offices new personnel system, the
changes it generated, and their perceived impact, raising some questions about its reliability. The study, for instance,
neglects to spell out the interview schedule, questions asked, and characteristics of the participants (e.g., upper versus
lower grade levels, organization officials versus employee association leaders, and management versus staff). The
review also reports data from a GAO employee feedback survey supporting its findings about perceived improvements
in the organizational climate, staff development, staff utilization, and leadership. The survey lists the percent of
employees responding favorably to particular statements, including differences between staff and upper level
management. Ibid., pp. 25-26. But the perceived improvements from 2003 to 2004 increase from only 1% to 3% for the
average in each category. Perhaps because the levels were in the 60 and 70 percentage range, the increases do not
appear to be statistically significant. Furthermore, the report neither discusses how the survey was developed and
administered nor provides data on several workforce characteristics which could put the responses into a comparative
perspective: missing, for example, are the number of respondents (in totality and in each area) as well as their
representativeness of the GAO workforce in terms of staff, management positions, grade level, and seniority as well as
gender and race.
37 Ibid., p. 6.
38 Ibid. Other organizational transformations—based on the “best practices” from the public and private sector,
regarding open communications between employees and management, centralized authority and accountability, and
senior management open support for new policies and programsare also contained in the report. Ibid., pp. 20 and 24.

Despite this endorsement, the IBM study recognized that some executive agencies—the majority
of whose personnel have moved out from under the traditional civil service—may be reluctant or
limited in adopting the GAO model, in light of the important differences between GAO (a
legislative branch support agency) and executive agencies that carry out public policy directly 39
and immediately. By comparison to GAO, these policy-implementing organizations are usually
much larger; experience different levels of autonomy for entities within the agency or department;
are more organizationally varied; and exhibit more functional diversity and mission multiplicity,
resulting in cross-cutting and shared jurisdictions with other executive entities.
The GAO pay-for-performance implementation, along with similar efforts in executive agencies, th
have raised concerns over several matters in congressional hearings in the 110 Congress and 40
other forums, and have led to legislative proposals to modify the Comptroller General’s powers 41
in this regard (discussed above). The issues include: whether the changes are implemented fairly
and impartially across the board, whether the plan’s criteria and standards are clear and
appropriate, whether the measurements used to compare personnel in GAO and elsewhere lead to
valid and reliable conclusions, whether the changes produce the desired results, whether they
have an adverse effect on employee morale, and whether they prompt (or endorse) requests for
similar authority in other government entities. Earlier, the office’s pay-ban determinations had 42
been challenged by 308 employees, resulting in a favorable settlement for 12.
As an outgrowth of the pay-for-performance dispute and other matters, eligible GAO analysts
voted on September 19, 2007, to establish a local affiliate of the International Federation of
Professional and Technical Employees (IFPTE), which will represent all bargaining unit

39 Ibid., pp. 5-6 and 22. The inability or piecemeal approach to a similar transformation could arise because of
differences between a policy-implementing executive agency and a legislative support agency (in terms of missions,
functions, authority, organization, and procedures). It could also arise because of concerns from some stakeholders,
such as federal employee unions, about several matters: whether certain executive agencies could meet the GAO
standards (due to different organizational cultures and conditions, for instance); what unintended consequences might
occur; how the new managerial powers might be manipulated or misused; and what the full cost of implementation
would be.
40 See citations in notes 15 and 32, above, along with U.S. House Subcommittee on the Federal Workforce, Postal
Service, and District of Columbia, Status of Federal Personnel Reform, hearing, 110th Cong., 1st sess., March 8, 2007, thnd
and Government Accountability Act of 2007, hearing, 110 Cong., 2 sess., March 13, 2008; and jointly with the
Senate Subcommittee on Government Management, the Federal Workforce, and the District of Columbia, GAO’s thst
Personnel Reform Efforts, joint hearing, 110 Cong., 1 sess., May 22, 2007. Press coverage appears in: Brittany R.
Ballenstedt, “Lawmakers probe GAO decision on pay adjustments, March 7, 2007, “Lawmakers grill GAO chief over
pay decisions,” May 22, 2007,GAO to challenge eligibility of employees to unionize, June 1, 2007, “Lawmakers
seek remedy for GAO pay reform,” March 14, 2008, andGAO to seek input from employees on changes to new pay
system,” April 10, 2008, all in Government Executive, available at; Dan Friedman, “Panel
targets GAO pay system, Government Executive, March 13, 2008, available at; Kelly
McCormack,Subcommittee hears testimony on GAO pay system, The Hill, March 13, 2007, p. 6; M. Z. Hemingway,
“Comptroller general pans CRS study of GAO pay,Federal Times, March 12, 2007, p. 1; and Stephen Barr,
Congress Questions Pay Restructuring at GAO,” Washington Post, May 23, 2007, p. D4.
41 H.R. 5683, which passed the House, and S. 2564, 110th Cong., 2nd sess. See also citations in note 15 above.
42 In early 2007, 12 of the 308 employees reached a settlement with GAO, receiving compensation benefits as if they
had been promoted a year before. The employees had filed an appeal before the GAO Appeals Board (U.S.
Government Accountability Office, Personnel Appeals Board, Petitioner v. Government Accountability Office,
Respondent, February 2006). The settlement was reached, however, before a hearing was held; and the claims were not
adjudicated by the Board. Press coverage by Britanny R. Ballenstedt, “GAO settles pay dispute with 12 of 308 senior
analysis, April 27, 2007, Government Executive at

employees on all matters that are subject to collective bargaining.43 The new unit, supported by a
two-to-one margin of the voting employees (among the 1,813 eligible), marks the first such 44
employee organization in GAO history.

Since its inception in 1921 as the General Accounting Office, the Government Accountability 45
Office has been headed by only seven Comptrollers General. Table 2 lists them in chronological
Table 2. Comptrollers General, 1921-Present
Comptroller General Dates of Service
John Raymond McCarl 1921-1936
Fred Herbert Brown 1939-1940
Lindsay C. Warren 1940-1954
Joseph Campbell 1955-1965
Elmer B. Staats 1966-1981
Charles A. Bowsher 1981-1996
David M. Walker 1998-2008
When the Comptroller General post is vacant, GAO has been headed by an acting Comptroller
General, as it is now. The longest absence of a confirmed Comptroller General was three years,
1936-1939. The second longest was the two-year vacancy from September 30, 1996, when
Charles Bowsher ended his term, until November 9, 1998, when David Walker began his.

43CG Discusses Immediate Impact of Union Election on GAO Operations,” GAO Management News, vol. 35,
October 15, 2007, p. 1; and Joint Statement of the Government Accountability Office and the International Federation
of Professional and Technical Engineers, July 18, 2007. For background and press coverage, see U.S. House thst
Committee on Appropriations, Legislative Branch Appropriations Bill, 2008, H.Rept. 110-198, 110 Cong., 1 sess., p.
33; Britanny R. Ballenstedt, “Union to file for first-ever election at GAO,” May 7, 2007, “More than 200 GAO
employees to petition for back pay, May 15, 2007, “GAO to challenge eligibility of employees to unionize, June 1,
2007, “Union files unfair labor practice charge against GAO chief,” June 22, 2007, “GAO, union reach agreement to
hold election,” July 19, 2007, “GAO analysts vote for union representation, Sept. 20, 2007, andRising
Expectations,” November 7, 2007; Karen Rutzick,GAO employees move toward vote on union representation,”
January 23, 2007, all in Government Executive; M.Z. Hemingway, “Labor strife hits GAO,”
Federal Times, May 14, 2007, p. 4, and “GAO chief fights to keep union out,” Federal Times, June 11, 2007, p. 1;
Richard W. Walker, “GAO analysts vote for union representation, at; and Stephen Barr, “In a
First, GAO Analysts Vote to Join a Union, Washington Post, September 21, 2007, p. D4.
44 In early 2008, the union and GAO reached a tentative contract agreement, which affects employee pay scales,
including those based on performance ratings, as well as eligibility for annual pay increases. Brittany Ballenstedt,
“GAO, union reach agreement on 2008 pay raises, Government Executive, available at
story_page.cfm?filepath=/dailyfed/0208/021108b1.htm, February 11, 2008; and Stephen Barr, “GAO and Its New
Union Reach Agreement on Raises, Washington Post, February 12, 2008, p. D4.
45 See footnote 2, above; and Trask, GAO History, pp. 7-20, 22, 25-38, 43-57, and 59-94.

Under GAO’s current statutory charter, the Comptroller General and Deputy Comptroller General
are nominated by the President, following recommendations from a special congressional
commission, and are confirmed by the Senate.
When a vacancy occurs in the office of the Comptroller General or the Deputy, a special
congressional commission, consisting of members of both chambers and both parties, is 46
established to recommend individuals to the President for appointment. Added by the General
Accounting Office Act of 1980 (94 Stat. 314-315), this process became operational the following
year. Under the arrangement, the recommending commission consists of the Speaker of the
House, the President pro tempore of the Senate, the majority and minority leaders of the House
and Senate, the chairmen and ranking minority members of the Senate Committee on Homeland
Security and Governmental Affairs and the House Committee on Oversight and Government
Reform, and, when the Deputy’s post is vacant, the Comptroller General. The commission
determines the criteria and standards for its nominees.
The current process includes examination of the backgrounds and future plans of potential
nominees, including, of course, their credentials, accomplishments, and relevant work experience
in the private sector and public office. These examinations are conducted by the commission
members and staff through interviews and meetings with the candidates, as well as with interested
and knowledgeable parties, and a review of relevant materials and documents. Later examinations
are held by the Senate Committee on Homeland Security and Governmental Affairs, which 47
reports the nomination to the full Senate.
The commission must recommend at least three individuals but the President may ask for
additional names for consideration (or nominate someone else). The original bill called for five
names to be submitted. However, the number was reduced, according to the report of the Senate
Committee on Governmental Affairs, because “three names is a more realistic figure. Considering
the high qualifications for the Office of Comptroller and Deputy Comptroller General, a 48
requirement to generate five names might be extremely difficult to satisfy.”
The reporting panel also recognized that the President could still nominate an individual not
recommended by the commission, in light of “the President’s authority under the Appointments
Clause .... However, it is expected that the President would give great weight to the Commission’s 49
recommendations.” This expectation has been met. On the two occasions since the 1980
enactment when a vacancy in the office of Comptroller General arose, Presidents Reagan in 1981
and Clinton in 1998 each selected a nominee from the initial congressional list.

46 A proposal from GAO would change the process for the deputy, by allowing the CG to appoint the deputy, after
consultation with the congressional commission (H.R. 3268, 110th Congress, described above).
47 For the most recent illustration, see U.S. Congress, Senate Committee on Governmental Affairs, Nominations of
Edward J. Gleiman, Dana B. Covington, and David M. Walker, hearings, 105th Cong., 2nd sess. (Washington: GPO,
1998), pp. 17-18 and 70-130.
48 U.S. Congress, Senate Committee on Governmental Affairs, General Accounting Office Act of 1980, S.Rept. 96-570,
96th Cong., 2nd sess. (Washington: GPO, 1980), p. 10. Despite the scaling back to three recommendations, eight names
were submitted the first time the new procedure was used, in 1981.
49 Ibid.

The provision for a bicameral commission gives both chambers of Congress a formal and direct
role in selecting the head of this legislative branch agency. The Senate Committee on
Governmental Affairs endorsed the new arrangement:
In view of the relationship between the Comptroller General and the Congress, the
Committee believes it is appropriate that both Houses be given a role in the selection
process.... [The new provision] reflects the special interests of both Houses in the choice of 50
an individual whose primary function is to provide assistance to Congress.
The current unique nomination process has not been used for the post of Deputy Comptroller
General, which has remained vacant since the 1980 enactment. Instead of a confirmed Deputy,
the Comptroller General has relied upon his own appointee(s) in one or two posts over the past
several decades. Early in this period, a single special assistant to the Comptroller General served
as second in command. Currently, two officials—the chief operating officer and the chief mission
support officer—carry out the appropriate duties and functions.
The new nomination process went into effect in 1981, resulting in the appointment of Charles A. 51
Bowsher, whose 15-year term expired in September, 1996.
A second congressional commission met afterwards, to recommend a successor. On January 22,
1998, the commission sent the names of three individuals who “had received majority support
from the members of the Commission” to President Clinton for his consideration, as provided in 52
the 1980 statute. Independently, six days later, Democratic members of the commission 53
submitted four additional names. On October 5, 1998, President Clinton nominated David M.
Walker, one of the three original recommendations of the commission majority. He was
confirmed by the Senate on October 21, following hearings by the Governmental Affairs 54
Committee on October 7, and its favorable report on October 9. Walker began his term of office
on November 9, 1998.
The two-year interregnum marked the second longest period without a confirmed Comptroller
General. And the nearly 10 months before the President submitted a nomination based on the

50 Ibid., p. 9.
51 U.S. Congress, Senate Committee on Governmental Affairs, Nomination of Charles A. Bowsher, hearing, 97th Cong.,
1st sess. (Washington: GPO, 1981);Nomination of Charles A. Bowsher to Be Comptroller General of the United
States, Congressional Record, vol. 127, September 29, 1981; and U.S. President Ronald Reagan, “Remarks
Announcing Intention to Nominate Charles A. Bowsher (July 9, 1981), Public Papers of the Presidents: Ronald
Reagan, 1981 (Washington: GPO, 1982), pp. 612-614. Bowsher was one of eight persons recommended by the
commission, which had an equal number of Democrats and Republicans. See Trask, GAO History, p. 97;Accountant
Bowsher Named New GAO Head, Congressional Quarterly, July 18, 1981, p. 1301; and Greg Rushford, “Veteran of
Capital Hardball Chosen for Top GAO Post, Federal Times, July 20, 1981, p. 6.
52 Letter from Senate Majority Leader Trent Lott and Speaker of the House Newt Gingrich, to President William
Clinton, January 22, 1998, regarding recommendations for Comptroller General. See also Stephen Barr,GOP Leaders
Offer Three to Head GAO,Washington Post, January 27, 1998, p. A15.
53Democrats, Objecting to Republican Move, Send 7 Names to Clinton for GAO,” Washington Post, February 2,
1998, p. A17.
54 Congressional Record, vol. 144, October 21, 1998, p. S12980. See also Robert Pear, “A C.P.A. at Center Stage:
David Michael Walker, New York Times, October 23, 1998, p. A14; and Senate Committee on Governmental Affairs,
Nomination of ... David M. Walker.

congressional commission’s recommendation prompted interest in making the Comptroller 55
General position exclusively a legislative branch officer. But this was not acted on. By so doing,
Congress would have made the appointment itself, as it does, for instance, with the Director of 56
the Congressional Budget Office. (By comparison, other legislative branch offices—the
Librarian of Congress, Architect of the Capitol, and Public Printer, who heads the Government
Printing Office—are filled by presidential nominees who are confirmed by the Senate.)

The Comptroller General is limited to a single 15-year term, a statutory provision57 designed to
protect the officer’s independence, professional integrity, and objectivity. Of the seven
Comptrollers General, three served the full term. (See Table 2.) The four with shorter tenures
include David Walker, who will have served for nine years and four months when his resignation
takes effect (November 9, 1998, to March 12, 2008). The remaining three who left early,
coincidentally in succession, were Brown, one year, resignation; Warren, 14 years, retirement;
and Campbell, 10½ years, retirement. All three cited ill health as the reason for leaving.
The Comptroller General or Deputy may be removed by impeachment or by adoption of a joint
resolution of Congress. Removal by joint resolution can occur only after notice and an
opportunity for a hearing and only for certain specified reasons: permanent disability,
inefficiency, neglect of duty, malfeasance, felony conviction, or conduct involving moral
turpitude. No Comptroller General or Deputy has been subject to either impeachment or removal
by a joint resolution.
The current requirement creates an unequaled retirement system for the Comptroller General, by
comparison with other government officials and employees. It provides that a CG who retires
after at least 10 years in office “is entitled to receive an annuity for life equal to the pay the
Comptroller General is receiving on completion of the term or at the time of retirement” (31 58
U.S.C. 772(a)). In addition to this benefit, an annuity for a retired CG “shall be increased at the

55 “GOP May Seek to Strip Clinton of Power to Name GAO Head, CQ Daily Monitor, July 29, 1998, p. 5.
56 Earlier proposals along this line, incidentally, were raised in the mid-1970s, prior to the change setting up the
congressional commission to make recommendations to the President. See Mosher, The GAO, p. 288. The bills thstthst
introduced in 1975 were H.R. 8616, 94 Cong., 1 sess., sponsored by Rep. Jack Brooks, and S. 2206, 94 Cong., 1
sess., sponsored by Sen. Lee Metcalf, with hearings on the latter. U.S. Congress, Senate Committee on Government thst
Operations, Subcommittee on Reports, Accounting, and Management, GAO Legislation, hearing, part 1, 94 Cong., 1
sess. (Washington: GPO, 1975).
57 31 U.S.C. 43.
58 A Comptroller General separated from office before becoming entitled to receive an annuity under this section is
entitled to lump-sum refund of the amount deducted from pay or deposited as a contribution under section 772, plus 3
percent interest on the amount compounded every December 31” (31 U.S.C. 775(a). A Comptroller General has
another option available with regard to a retirement program, if he or she is already a federal employee. A CG who,
when appointed, is under the Civil Service Retirement System (CSRS) or the Federal Employee Retirement System
(FERS) remains subject to it, unless the Comptroller General elects in writing to receive the special life-time annuity.

same time that, and by the same percent as the percentage by which, annuities are increased under
section 8340(b) of Title 5” (31 U.S.C. 777(a)). As a qualification, this annuity “may not be more
than the basic pay of the Comptroller General” (31 U.S.C. 777(b)).
This special retirement system was added in 1953.59 In considering the legislation, the Senate
Committee on Government Operations received the views of both the Civil Service Commission
(CSC) and the Comptroller General. The Committee stated that the new retirement system for the
Comptroller General was
designed to conform to the particular nature of the office, which witnesses testified was
similar in character, tenure and independence to the office of a Federal judge, and that its 60
provisions are designed to conform to retirement benefits provided for Federal judges.
The post was regarded as “unique,” in a statement on behalf of the Chairman of the Civil Service
Commission, who favored the retirement provision for several reasons.
The Comptroller General is unique in that he is (a) independent of Executive control, (b)
cannot be removed except by the Congress, and (c) is not eligible for reappointment after 61
serving a 15-year term.
A letter to the Committee from the CSC elaborated on these and other rationales. It noted that the
Comptroller General’s duties were “important and complex,” demanding “the appointment of a
mature man,” who would not necessarily have had previous government experience and might 62
not after leaving the post. The resulting condition is that “upon completion of his term, the
Comptroller General will normally be of such advanced age as to deter, if not prohibit, his 63
acceptance of employment in other pursuits.”
Lindsay Warren, the Comptroller General at the time, echoed these sentiments. The fixed 15-year
term, without the possibility of reappointment,
is too long for such an officer to retain other ties, and too short to provide lifetime security or
sufficient longevity to buy an annuity under the Civil Service Retirement System....
Important and complex duties of the position dictate the appointment of a mature man, who,
upon completion of his term, would normally be beyond the age when he might seek new
fields of activity.... the Office is a part of the legislative branch of the Government, and is of 64
a semijudicial nature.

Such an election is irrevocable and must be made within 10 years and 60 days after the start of service as Comptroller
General. A CG electing the special life-time annuity instead of remaining under CSRS or FERS is entitled to a refund
of the lump-sum credit to the account of the Comptroller General in the Civil Service Retirement and Disability Fund.
(31 U.S.C. 772(c).
59 P.L. 83-161, Comptroller General—Retirement.
60 U.S. Congress, Senate Committee on Government Operations, Comptroller General, Retirement, S.Rept. 594, 83rd
Cong., 1st sess. (Washington: GPO, 1953), p. 1.
61 Ibid., pp. 1-2.
62 Letter from the Acting Assistant Executive Director, Civil Service Commission, July 15, 1953, to Hon. Joseph R.
McCarthy, Chairman, Senate Committee on Government Operations. Ibid. pp. 3-4
63 Ibid., p. 4.
64 Letter from Lindsay Warren, Comptroller General, ibid.

An attempt to transform the CG’s retirement system was advanced by the House Appropriations th
Committee in the 110 Congress. The panel included a proviso
that repeals the unique Comptroller General Retirement system for any individual appointed
Comptroller General after the enactment of this Act. Future appointments to this position 65
will be covered under the standard Federal Employees Retirement System (FERS).
Of the seven Comptrollers General, two—Lindsay Warren and Joseph Campbell—retired after 66
going beyond the 10-year threshold (which was made available in 1954).
Throughout GAO’s history, only two of the seven Comptrollers General have resigned from
office. Fred Herbert Brown served a little over one year (April 11, 1939, to June 19, 1940), 67
leaving office after suffering a stroke. David M. Walker resigned in order to head a newly 68
established public interest foundation. He had served as Comptroller General for nine years and
four months (November 9, 1998, to March 12, 2008), thus, falling short of the 10-year threshold
to be eligible for the CG’s retirement annuity.

Created in 1921, the General Accounting Office, now the Government Accountability Office, is
Congress’s largest support agency, with a budget of more than $507 million and an authorized
staff of 3,100 for FY2008. The office has been headed by only seven comptrollers general over its
eight-decade history; with a vacancy currently, it operates under an acting CG. GAO has been
granted broad jurisdiction over the executive and substantial independence from it as well as
extensive authority to gain access to its records and to investigate, audit, and evaluate its 69
operations. These attributes support a wide variety of services and activities, most connected

65 U.S. House Committee on Appropriations, Legislative Branch Appropriations Act, 2008, H.Rept. 110-198, 110th
Cong., 1st sess., p. 34. The proposal was eliminated in conference.
66 Trask, History of GAO, pp. 38 and 57.
67 Ibid., p. 22.
68 See footnote 2 above.
69 GAO is one of a number of comparable organizations worldwidecollectively known as Supreme Audit Institutions
(SAIs)—that audit, investigate, and/or review government activities, operations, and programs. These counterparts
have similar but not identical responsibilities, functions, powers, and degrees of independence (from the entities they
audit and investigate), reflected to a degree in their different titles: e.g., the Supreme Chamber of Control (Poland),
Court of Audit (Belgium), Office of the Comptroller and Auditor General (Ireland), National Audit Office and
Northern Ireland Audit Office (United Kingdom), Tribunal of Contras (Portugal), and Cour des Comptes (France).
Descriptions of these and other similar offices are found in: International Organization of Supreme Audit Institutions,
Survey and Description of Selective National Audit Offices (loose-leaf collection) (Vienna: INTOSAI, 1996); National
Audit Office, State Audit in the European Union (London: NAO, 1996); S. N. Swaroop, Supreme Audit Institutions in
Different Countries (New Delhi: Ashish Publishing House, 1991). Although there is no current, broad-scale, systematic
comparison of SAIs internationally, GAO probably ranks highest across such key criteria as independence, authority,
jurisdiction, functions, and resources. Along these lines, a comparison between GAO and its UK counterpart concluded
thatthe powers, duties, and self-perception of the National Audit Office [UK] are significantly weaker and more
mutable than those of the Government Accountability Office.” Simon D. Norton and L. Murphy Smith, “Contrast and
Foundation of the Public Oversight Roles of the U.S. Government Accountability Office and the U.K. National Audit
Office, Public Administration Review, Sept./Oct. 2008, p. 921.

with legislative oversight of the executive, that GAO can initiative on its own or, more usually, at
the request of Congress, its Members, and panels.
Over the past decade, questions have arisen over several matters affecting GAO’s structure,
organization, and powers: the process (and resulting delay) for selecting the Comptroller General;
the absence of a confirmed Deputy for more than twenty-five years; the unsuccessful attempt to
gain access to information from a presidentially established panel, headed by the Vice President;
problems in securing independent access to the records of certain agencies; and limitations on
GAO auditing of all components of the intelligence community. As a result, bills have been th
introduced in the 110 Congress which would enhance GAO access to executive branch
information, clarify the office’s jurisdiction over the intelligence community, provide
reimbursement for certain audit costs, and establish a statutory inspector general in GAO.
In the mid-1990s, GAO underwent a substantial downsizing—in funding and staffing—in part
because of congressional criticism of its perceived orientation towards the previous two
administrations and concerns about its missions and roles. In the meantime, the office has
experienced a paradox between its budget and personnel levels. Its annual budget has increased
regularly over the past 10 years—reaching its highest level in FY2008—while its staff has been
downsized, falling to its smallest level at the same time.
In 2004, the Comptroller General garnered new authority over pay and personnel in the newly-
designated Government Accountability Office. A followup study a year later, under the auspices
of the IBM Center for the Business of Government, found benefits in GAO’s use of human
capital management to drive its organizational transformation. The authors recommended that
executive agencies—notwithstanding their differences with a legislative branch support agency—
”heed the lessons of the government’s chief accountability office as they go about the critical
work of reinventing their own personnel systems.” Despite this endorsement, the changes in GAO
(as well as parallel ones in executive agencies) prompted concerns over the implementation and
impact of the new personnel flexibilities authority and pay. These developments contributed, in
2007, to the establishment of an employee union with collective bargaining rights; in 2008, to a
new contract for eligible employees; and in the same year, to legislative proposals to modify the
CG’s powers over such personnel matters and provide reimbursements for certain staff who did
not receive pay increases in 2006 and 2007.
In sum, the Government Accountability Office appears to be going through a transition period.
Changes—in progress or proposed—have been prompted by a vacancy in the office of the
Comptroller General; the nearly 30-year absence of an official Deputy CG; conflicts over a new
personnel system and its implementation; the perceived need for certain new arrangements and
organizations within GAO, such as a statutory inspector general; and restrictions on its
independent access to executive branch information and its auditing of the intelligence

Frederick M. Kaiser
Specialist in American National Government, 7-8682