The Trump administration, in an 11th-hour memo, has suspended a requirement for agencies to set strategic planning goals and to share progress made with Congress and the public as part of the annual budget process.

The Office of Management and Budget memo included an update to its A-11 Circular on Dec. 23 removing an earlier section of guidance that required agencies to evaluate the performance of their programs under the Government Performance and Results Act.

OMB expects to release new guidance for agencies that will outline new statutory requirements for agencies and “to facilitate the provision of more focused and meaningful information to stakeholders.”

The 1993 Government Performance and Results Act (GPRA) requires agencies to create five year-strategic plans that set performance goals for programs outlined in their budgets. The legislation also requires agencies to send the White House and Congress an annual report with updates on progress made.

Agencies use this performance data in part to justify their annual budget requests. The incoming Biden administration is expected to submit its first budget proposal to Congress in February.

OMB Director Russ Vought said the updated memo aligns with the administration’s focus on cutting the time and effort spent on “low-value government work,” and eliminating “bureaucratic processes that do not lead to impactful change or measurable efficiencies.”

“The thousands of pages of performance data generated by agencies and posted on Performance.gov each year attract little interest,” Vought wrote in the memo.

A former OMB official told Federal News Network that the memo isn’t an indictment of agencies having strategic plans or linking expectations for performance against strategic objectives in their budget requests. Rather, he said it reflects on a recognition that OMB guidance issued so far hasn’t adequately implemented the GPRA requirements.

“In a way, it’s a pretty gutsy thing for OMB to do this — to say we have taken a look at how this guidance has actually been implemented, and from what we can tell, it’s just been an empty exercise, it’s just not getting much traction,” the official said.

“OMB sets all these rules, but a lot of these rules create an expectation that what agencies generate is actually going to be reviewed and it’s going to be part of a conversation with OMB, and then ultimately with Congress. That doesn’t happen,” the former OMB official added.

Don Moynihan, a professor of public policy at Georgetown University who has presented his research on public-sector performance to OMB policymakers, said the timing of the memo puts agency budget officials and OMB career officials in an unusual situation just before the incoming Biden administration submits its first budget request.

“In some respects, it really just feels like throwing sand in the machinery, as someone else is about to take over the process, rather than something that’s been well-thought-out, or based on any real substantive analysis. It’s hard to think of a good reason why they would do it now,” Moynihan said.

If agencies comply with OMB’s memo and leave out performance data in their budget documents, the Biden administration could still request this information from agencies, but the time spent pulling this data late in the process would likely cause some delays.

“It really increases the uncertainty and hassle factor for career staff as they’re trying to put together these budget documents. I think it does no favors either to the career staff or to the incoming administration,” Moynihan said.

Is Congress even looking at performance data?

GPRA was meant to provide agency performance metrics to Congress, federal managers and the public, but Vought said Congress has paid little attention to the volume of data that agencies produce. Congress, he added, hasn’t held a hearing focused on the issue in years.

“This lack of interest in the vast bulk of GPRA-generated performance data is not new; it has persisted throughout recent presidential administrations led by both major parties,” Vought wrote. “To be clear, OMB believes every administration should publicly identify its highest priorities, apply meaningful metrics to measure their attainment, and make that information publicly available.”

The Government Accountability Office every few years conducts a survey of federal managers to assess how much agencies are using this performance data to factor into their decision-making. GAO in its most recent report from 2017 found little improvement in managers using this information compared to its 2013 report.

But in a recent study looking at the four most recent GAO surveys — the oldest dating back to 2000 — Moynihan found that GPRA led to “more purposeful data use on aggregate” than the president management agendas of previous administrations.

“If they’re part of quarterly performance reviews, or if they play a role in setting up the agency priority goals, then they also tend to be more likely to use that data to make decisions,” Moynihan said. “There is evidence that over time that these systems have become more effective.”

Moynihan said OMB’s claim that Congress has paid little attention to performance data is unusual, given that GAO is expected to soon release its next survey of federal managers.

“It’s just sort of remarkable that OMB would unilaterally make this decision, even though the actor that Congress has delegated to analyze the implementation of these performance systems is about to release a report that updates how well these systems are doing,” he said.

The former OMB official said he recalled career federal employees were generally receptive to the performance and metrics goals their agencies would set under GPRA.

“At the career level, they’re highly professional and they really want to do a good job. And most of them don’t mind being measured against doing a good job. They think they’re going to look good, if they don’t look good, it means that they can learn something and get better,” the official said.

Building a culture of evidence-based policymaking in agencies has been gradual work. Congress passed the GPRA Modernization Act in 2010 requiring agencies to make their annual performance plans available to the public online. Congress passed the Foundations for Evidence-Based Policymaking Act last year, requiring agencies to name chief data officers and chief evaluation officers to assist in this work.

“The logic here is that you’re not going to make the federal government more results-oriented overnight. It’s a huge change in the culture of federal organizations, and so it’s going to take 30 years. And that, I think, has gradually been successful,” Moynihan said.

The Trump administration and previous administrations have made evidence-based policymaking part of their management agendas, but Moynihan said this legislative framework, built up over time, has had more of an impact on the federal workforce than policies that come and go with each president.

“If you want a long-lasting, durable reform, it has to be bipartisan, and preferably with the approval of Congress. Otherwise, you’re just sort of waiting out, if you’re a federal employee, the opportunity to simply see that reform go away,” he said.

The timing of the OMB memo also puts career OMB officials in a difficult position. Its leadership recently classified 88% of its workforce as part of the excepted service under Trump’s recent Schedule F executive order. This new categorization would strip civil service protections from former career employees.

“It’s much less likely career officials in the agency are going to speak up and say, ‘Actually, this is really a bad idea,’ even if Congress wants to contact them. This is a pretty good example of how the Schedule F-type environment generates worse policy and lower transparency about that policy than would be the case otherwise,” Moynihan said.

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