OMB Guidance: What Is a Program?

This is a question to which agencies will now have to come up with an answer. And it won’t be easy!


Earlier this Spring, Senator Tom Coburn grilled an OMB witness at a hearing about why OMB had not yet implemented a provision in the GPRA Modernization Act requiring the creation of a government-wide inventory of all existing programs. He pointed to a list developed by the Department of Education and wondered why this was not done by every agency in government.

Senator Coburn has been on a campaign in recent years to identify and eliminate duplicative and overlapping programs. In fact, a couple years ago, he inserted a requirement in law that the Government Accountability Office report annually on such programs. But finding overlap is hard if there is no inventory of all of the government’s programs in the first place. Hence, his push on OMB to act.

In response to a requirement in the Modernization Act, OMB released guidance last week on defining and inventorying government programs, and how they will be included “on a single, government-wide website,”, using “an iterative approach to build a useful inventory within capacity constraints.”

How do you define “program?”

I had pondered what it would mean to define what an agency might consider to be a program. For example, if the Veterans Cemetery Administration had a customer service call center, would that be a program? And if VA consolidated all of its call centers into into a single call center that services all VA programs, would the enterprise-wide call center a new program? Or is it just a shared support service for the different VA programs? Would you then apportion the staff and budget among the different services?

GAO has defined “program” as “an organized set of activities directed toward a common purpose or goal,” which is a broad definition allowing a lot of variation.

OMB decided to punt: “. . . this guidance does not prescribe a superseding definition of ‘program’; rather, . . . agencies may identify programs consistent with the manner in which the agency uses programs to interact with key stakeholders and to execute its mission.”

Its guidance did, however, offer a series of definitions agencies might use, such as defining a program around:

  • Outcomes (such as increased exports)
  • Customers (such as women-owned small businesses)
  • Products, services, or outputs (such as the Consumer Price Index)
  • Organizational structure (such as the office of U.S. Polar Research)
  • Budget (such as the program activity line in the budget for disaster recovery).

But even after agencies define a basket of programs, they are not done. OMB notes: “Per the GPRA Modernization Act, agencies must cross-walk each program to the obligations by program activity lines (PA lines) used in the program and financing (P&F) schedules of the President’s Budget.”

(Note: this cross-walk requirement should not be confused with the recently enacted Sequester Transparency Act requirements which require a one-time inventory all potential “reductions at the program, project, and activity level” for FY 2013).

OMB also noted that agencies don’t have to be internally consistent in defining what constitutes a program, but that “Over time, OMB will work across agencies to determine the need to standardize approaches.”

When Will This Happen?

OMB says this effort will require an iterative approach. It has been working with agencies over the past year to develop several pilot models, and members of the Performance Improvement Council have been sharing best practices with each other.

OMB’s guidance says “As a first step, agencies will publish a list of programs that support Cross-Agency and Agency Priority Goals in November [2012], and a full inventory of their programs no later than May 31, 2013.”

As a second step, “following the FY 2015 President’s Budget, agencies will report four kinds of program information: General, Organizational, Financing, and Performance.” It then details a list of data fields agencies must collect in each of these four areas for publication on by May 31, 2014.

The inventory will then be updated annually by agencies. OMB promises more detailed guidance will follow!

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That’s a tough one – I’ve worked at divisions of agencies that have had problems defining what a project or program is – yet alone doing it at a macro-scale. Definitely seems useful to have but needs some definition. Sometimes a couple different projects get bundled into one program for budgeting purposes. It may easiest to do it around a $ threshold

John Kamensky

OMB used a dollar threshold when it did PART reviews a few years ago, but that didn’t really result in meaningful distinctions in many cases (e.g., all of NIH was consider one program under PART, even though it was comprised of 27 disparate and distinctly different research centers). So that might not be the best solution, either. It’s just plain tough to do!