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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
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:
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.
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.
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||
|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||
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.
We recommend that the Chief Strategy Officer
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.
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.