The CFPB Has Established Effective GPRA Processes, but Opportunities Exist for Further Enhancement

Finding 1: The CFPB Developed an Effective Strategic Planning Process and Generally Complies With Associated GPRA Requirements

We found that the CFPB implemented an effective strategic planning process. Further, the CFPB developed additional processes that support strategic planning activities as well as a practice that GAO highlighted as effective for implementing GPRA. We also found that the CFPB is fully complying with 11 of the 12 applicable GPRA strategic planning requirements. The CFPB partially satisfies the remaining requirement, which directs agencies to describe the program evaluations used in strategic planning and identify a schedule for future program evaluations. The CFPB believes, however, that it is fulfilling this requirement through its robust QPR process and regular discussions of program effectiveness. Additionally, officials noted that they did not have a formal schedule for program evaluations, but that the CFPB's QPRs serve that purpose on a quarterly basis. We acknowledge that the CFPB's efforts are consistent with GPRA's intent of promoting greater efficiency, effectiveness, and accountability in its agency programs through its effective strategic planning process. Program evaluations that provide a more in-depth analysis of aspects of CFPB's programs could provide a valuable supplement to the CFPB's ongoing QPR process. As GAO has noted, "An evaluation study can provide a valuable supplement to ongoing performance reporting by measuring results that are too difficult or expensive to assess annually, explaining the reasons why performance goals were not met, or assessing whether one approach is more effective than the other."¹⁰

The CFPB's Strategic Planning Process Is Robust

GPRA requires that agency-level strategic plans be developed and published at least once every four years. In developing its first strategic plan, issued as part of the Strategic Plan, Budget, and Performance Plan and Report in April 2013, the OCSO conducted a strategic planning process for the CFPB that included the following elements:

• Benchmarking. The OCSO met with other federal regulatory agencies and reviewed their strategic planning documents. An OCSO official stated that this information guided development of the CFPB's Strategic Plan, Budget, and Performance Plan and Report.
• Task force. The OCSO created a task force with representatives from each of the CFPB's divisions and offices to develop agency-level strategic goals and objectives. Division Associate Directors approved the final goals.
• Division participation. Although the OCSO led the strategic planning effort, the performance measures were developed by the division responsible for the program areas' work and corresponding performance information.
• Public comment and congressional consultation. The OCSO published the draft strategic plan for public comment in September 2012, with comments due in October 2012. During this period, the CFPB briefed representatives from the U.S. Senate Committee on Banking, Housing, and Urban Affairs and the U.S. House of Representatives Committee on Financial Services and provided both committees with the opportunity to comment.

Further, the CFPB exceeded GPRA strategic planning requirements by implementing a division-level strategic planning process. Because the CFPB's strategic goals through 2017 are broad in nature, OCSO officials stated that they recognized a need to create more specific performance goals and measures for each division. As such, the divisions created annual strategic plans, with goals specific to their program areas, that align with the higher-level CFPB strategic goals. One division representative stated that the division-level strategic plan is a useful management tool that goes beyond GPRA requirements and helps the divisions address internal, long-term goals. Another division representative stated that division-level strategic planning helps ensure that offices within that division complement one another rather than overlap.

In addition, the CFPB established accountability for achieving results, which GAO identified as a practice for effective implementation of GPRA. Specifically, the CFPB delegated responsibility to Division Associate Directors for achieving specific performance goals and measures in the Strategic Plan, Budget, and Performance Plan and Report.

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The CFPB Demonstrates Commitment at the Highest Levels of Senior Leadership
In its May 2011 report, Managing for Results: GPRA Modernization Act Implementation Provides Important Opportunities to Address Government Challenges, GAO reported that the single most important element of successful management improvement initiatives is the demonstrated commitment of top leaders. The CFPB's top leaders have demonstrated their commitment to GPRA activities. Specifically, the Director of the CFPB and his Chief of Staff attend each division-level QPR session. Further, Division Associate Directors sometimes voluntarily attend other divisions' QPR sessions in addition to their own. One Division Associate Director has assumed an active role in preparing for the QPR session and views the QPR process as an opportunity to review his division's progress in meeting performance goals. A high-level official in another division stated that her division generates monthly operational data that inform her division's QPR session. She uses the monthly operational data to look for red flags related to core activities as well as to examine the need to adjust her division's activities.

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The CFPB Fully Complies With 11 of 12 GPRA Strategic Planning Requirements

We found that the CFPB fully satisfies 11 of the 12 applicable GPRA strategic planning requirements and partially satisfies the remaining requirement (table 2).

Table 2: The CFPB's Compliance With Applicable GPRA Strategic Plan Requirements in Its Strategic Plan, Budget, and Performance Plan and Report

GPRA strategic plan requirements applicable to the CFPB	Fully satisfies	Partially satisfies	Does not satisfy
The agency should:
Develop a strategic plan
Make the strategic plan available on public website and notify Congress of its availability
Ensure the agency's performance plan is consistent with the agency's current strategic plan
Develop the strategic plan in consultation with Congress and in consideration of the views of potentially affected or interested parties
The strategic plan should:
Contain a comprehensive mission statement covering the major functions and operations of an agency
Contain general goals and objectives
Describe how the goals and objectives are to be achieved
Describe how the goals and objectives incorporate the views and suggestions obtained through congressional consultations	a
Describe key external factors that could significantly affect the achievement of the general goals and objectives
Describe program evaluations used in establishing or revising general goals and objectives, with a schedule for future program evaluations
Cover at least four years following the fiscal year in which the plan is submitted
Be drafted by federal employees

• Source: OIG analysis of the CFPB's Strategic Plan, Budget, and Performance Plan and Report, April 2013; 5 U.S.C. § 306.
• Note: See appendix B for further description of GPRA strategic planning requirements.
• ^aAccording to CFPB officials, the CFPB presented its draft strategic plan to representatives from Congress and solicited comments, but did not receive any comments. Return to text

As indicated earlier, the CFPB's use of program evaluations partially satisfies the GPRA requirement. Specifically, GPRA requires that agencies include in strategic plans a description of the program evaluations used in establishing or revising general goals and objectives, with a schedule for future program evaluations to be conducted.¹¹ In its Strategic Plan, Budget, and Performance Plan and Report, the CFPB identified GAO studies, Office of Inspector General (OIG) reports, an annual audit of the CFPB's operations and budget, and QPRs as its program evaluations. However, the agency did not provide a schedule for future program evaluations to be conducted. In our discussions with CFPB officials, the officials emphasized that the agency satisfies the program evaluation requirement through its robust QPR process and through regular discussions between the Director of the CFPB and division officials concerning overall program effectiveness. Further, officials noted that while the CFPB did not have a formal schedule for conducting program evaluations, the agency's QPRs serve that purpose on a quarterly basis.

GAO has reported on the use of program evaluations across the federal government.¹² In its reports, GAO defined program evaluations as systematic studies that use research methods to address specific questions about program performance and can be used to determine whether a program has had or is having unintended outcomes. Further, a program evaluation can assess an entire program or an initiative within a program and provides a valuable supplement to ongoing performance reporting. Evaluation results may be used to assess a program's effectiveness, identify ways to improve performance, guide resource allocation, or provide a more in-depth analysis of unmet performance goals. While we concur that the activities the CFPB considers to be program evaluations are good management practices, we believe that more formal program evaluations could further enhance the agency by helping program managers, among other things, to (1) improve the design or management of an existing program, (2) support or change resource allocations within or across programs, or (3) share favorable practices with other program stakeholders.

Recommendations

We recommend that the Chief Strategy Officer

1. Identify areas in which formal program evaluations, as described by GAO, could assist the CFPB in meeting its goals.
2. Establish a schedule for program evaluations and incorporate the schedule into future strategic plans to fully satisfy the strategic planning requirements of GPRA.

Management's Response

The CFPB's Chief of Staff noted that since the conclusion of our fieldwork, the CFPB has engaged third parties to conduct evaluations of some of its programmatic areas. He also stated that the agency will continue to use its QPR process and meetings with the Director of the CFPB to identify additional areas for formal program evaluations. The CFPB plans to conduct program evaluations to further improve program designs and to share favorable practices. In addition, the CFPB plans to develop and update a multiyear schedule for program evaluations and incorporate the schedule into its future strategic plans. Management's full response is included as appendix C.

OIG Comment

In our opinion, the actions described by the Chief of Staff are responsive to our recommendations. We plan to follow up on actions taken by the CFPB to ensure that our recommendations are fully addressed.

• 10. U.S. Government Accountability Office, Strategies to Facilitate Agencies' Use of Evaluation in Program Management and Policy Making, GAO-13-570, June 26, 2013. Return to text
• 11. 5 U.S.C. § 306-(a)(8). Return to text
• 12. U.S. Government Accountability Office, Designing Evaluations 2012 Revision, GAO-12-208G, January 2012; and U.S. Government Accountability Office, Program Evaluation: Strategies to Facilitate Agencies' Use of Evaluation in Program Management and Policy Making, GAO-13-570, June 2013. Return to text