When the Biden administration issues its first budget proposal in the coming weeks, agencies will come prepared with performance data to justify how they will spend that money.

That has been the expectation for decades under the Government Performance and Results Act (GPRA), but a last-minute memo from the Trump administration created some uncertainty about this process when the Office of Management and Budget removed key guidance from its A-11 Circular.

In the final week of the Trump administration, however, OMB issued a second memo, clarifying that agencies should still measure and track program performance data as required by GPRA.

“Agencies should continue to adhere to these statutory requirements and the timelines for achieving them established in previously issued guidance from OMB,” Former OMB Director Russ Vought wrote in the Jan. 15 memo.

The memo underscored the Trump administration’s skepticism with the amount of performance data agency have been expected to produce, compared to how much Congress and federal managers actually use this information. But now it’s to the Biden administration to decide how agencies gather and use this information.

Vought wrote in the memo that implementation of GPRA has led to the “production of reams of data of little utility.”

“There is scant evidence of benefit for the time and expense that agencies annually invest in compliance with these laws under the legacy practices that have been employed to date,” Vought wrote. “Congress and the public have long turned a blind eye to the performance information produced, and senior Executive Branch officials struggle to meaningfully incorporate the information into management efforts due to the questionable quality of the data yielded…”

In response to this perceived imbalance, Vought instructed agencies to identify no more than two priority goals where they can make the biggest impact and focus on measuring progress in those areas.

Robert Shea, a principal at Grant Thornton and former OMB associate director, said that while there’s room for criticism in how administrations have implemented GPRA, narrowing the scope of the requirements doesn’t address those concerns.

“If we’re spending all these trillions of dollars and agencies can only focus a couple of priorities, then I think the taxpayers are going to be highly disappointed in their performance,” Shea said in an interview. ” We’ve got to expect these large organizations to be able to walk and chew gum at the same time. There can be too many goals, but there can also be too few — and two is too few.”

Given the timing of the memos, Shea said the Trump administration was essentially “punting to the next administration” on how to proceed with agency performance data requirements.

“Pulling up those statutory requirements by the roots left a lot of people confused about how to comply. Though I suspect if they had more time, the administration would have produced for fulsome guidance, this basically said ‘Even though we withdrew that previous guidance, all those pre-existing requirements still exist,’” he said.

OMB is also working with agencies as part of a pilot program to stand up an online inventory of all federal programs and their performance data — a task that has also proved challenging for prior administrations

The key challenge is the difficulty of coming up with a consistent way to count programs across agencies. What sounds like a simple task for the Small Business Administration, for example, can be a challenge for an agency as complex as the Defense Department.

The Biden administration, however, shouldn’t underestimate the value of standing up an inventory of agency programs.

“If we’re going to hold programs accountable for performance, we’ve got to know that they exist. Likewise, if Congress and the administration are going to create new programs to solve ongoing challenges, they ought to have a good sense of what’s already out, and whether or not what’s already out there is having an impact,” Shea said.

“It’ll take some hard work, but once it’s in place, I think it will be really useful. But it will also require some ongoing management nurturing to make sure it remains fresh, that we learn from mistakes and things that we missed,” he added.

Congress, meanwhile, has demonstrated a renewed interest in standing up this inventory. Congress in 2019 passed the Taxpayers Right-To-Know Act, which requires OMB to expand the information it publishes in its inventory of agency programs to include links to program performance data.

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