2020 Census: Bureau Has Made Progress with Its Scheduling, but Further Improvement Will Help Inform Management Decisions

The Bureau is required by law to count the population as of April 1, 2020; deliver state apportionment counts to the President by December 31, 2020; and provide redistricting data to the states within 1 year of Census Day, April 1, 2021. To meet these statutory deadlines, the Bureau carries out hundreds of projects, which it manages with an integrated master schedule. Because census operations need to proceed in concert with one another, significant delays could propagate to other activities resulting in increased costs, reduced operational quality, or changes to the design of the census in order to compensate for lost time.

This report determines the extent to which the Bureau is using leading practices for scheduling key projects.

GAO selected three projects for review based on their cost and in-progress status. GAO analyzed schedules and their supporting documents against GAO's Schedule Assessment Guide. GAO also spoke with relevant Bureau officials regarding the three selected projects.

GAO provided a draft of this report to the Department of Commerce, which agreed with the findings.

The three census project schedules GAO reviewed better reflect characteristics of a reliable schedule compared to a GAO schedule assessment performed in 2013, but weaknesses remain. GAO reviewed three projects that contribute to two of the Census Bureau's (Bureau) largest field operations—address canvassing and nonresponse follow-up. The schedules for all three projects are better constructed and more credible than previously reviewed project schedules. For example, the Bureau has improved the logic of the relationship between activities, and better ensured that all schedules are linked together in a master schedule so that their interactions can be better managed.

However, the three selected schedules have some of the same weaknesses GAO identified in other Bureau schedules in 2009 and 2013. For example, none of the selected schedules contain information on resource needs and availability. GAO has reported that such information assists program offices in forecasting the likelihood that activities will be completed as scheduled. It can also help management compute total labor and equipment hours, calculate total project and per-period cost, resolve resource conflicts, and establish the reasonableness of the plan. If the schedule does not allow insight into current or projected allocation of resources, then the likelihood is significantly increased that the program may slip or need additional resources to complete on time.

In GAO's 2009 review of the Bureau's schedule, GAO recommended that the Bureau include in the 2020 master schedule estimates of the resources, such as labor, materials, and overhead costs for each activity as the 2020 schedule was built. The Department of Commerce did not respond to the recommendation at that time. Then, regarding GAO's 2013 assessment of the Bureau's schedule, Bureau officials stated that they hoped to begin identifying the resources needed for each activity in their schedules by early 2014. However, as of May 2018, the Bureau had not taken these steps. Senior Bureau officials have now stated that it would require additional staffing in order to plan for and implement this recommendation.

Additionally, the Bureau has not conducted risk assessments for the project schedules GAO assessed. Schedule risk analysis—the systematic analysis of “what if” scenarios—is an established leading practice. Risk assessments are needed to determine the likelihood of the project's completion date; how much schedule risk contingency is needed to provide an acceptable level of certainty for completion by a specific date; risks most likely to delay the project; how much contingency reserve each risk requires; and the paths or activities that are most likely to delay the project.

In 2013, GAO recommended the Bureau conduct risk assessments for its schedules. The Bureau said it had no disagreement with this recommendation. However, while Senior Bureau officials stated that a schedule risk assessment plan and process were approved by Bureau management in late May 2018, it has not yet implemented this recommendation.

GAO believes that these prior recommendations still apply and can help the Bureau improve the reliability of its 2020 schedule.

The decennial census is a crucial, constitutionally mandated activity with  immutable deadlines. The U.S. Census Bureau (Bureau) is required by  law to count the population as of April 1, 2020; deliver state  apportionment counts to the President by December 31, 2020; and  provide redistricting data to the states within 1 year of Census Day, April  1, 2021. To meet these statutory deadlines, the Bureau carries out  thousands of interrelated activities, which it manages with an integrated  master schedule. The Bureau’s schedule is essential to help manage the  risks to preparing and implementing a successful decennial census.  Because census operations need to proceed in concert with one another,  significant delays could propagate to other activities and increase costs,  reduce operational quality, or force the Bureau to change the design of  the census in order to compensate for lost time.

Over the years, we have reported on significant weaknesses in the  Bureau’s scheduling practices, leading to recommendations for the  Bureau to improve the comprehensiveness, construction, and credibility  of its schedule, and ensure that it includes estimates of the resources and  a qualitative risk assessment. The Bureau said that it had no  disagreement with these recommendations, yet these recommendations  have not been implemented. With less than 2 years until Census Day, there is little time remaining for the Bureau to deal with any unexpected  problems that may arise. Accordingly, early recognition of potential delays  is essential, and remaining activities need to begin and end on schedule  and in the proper operational sequence.

In response to your request, our objective was to determine the extent to  which the Bureau is using leading practices for scheduling key projects. In  order to meet this objective, we selected the following three projects for  review: 2018 End-to-End Census Test Address Canvassing, 2018 End-to- End Census Test Nonresponse Follow-up, and 2020 Census Geographic  Programs. These projects are critical to the Bureau’s ability to build and  maintain an accurate address list, and help ensure that households  respond to the census. We selected these projects based on their high  cost, their significance to the 2020 Census, and that they were still in  progress.

We compared the schedules for each of these projects to the leading  practices in our Schedule Assessment Guide. We spoke with relevant  Bureau officials regarding these project schedules. We scored each  scheduling leading practice on a five-point scale ranging from “not met” to  “met.” Finally, we compared these results with our prior assessments of  the Bureau’s schedule, particularly those where we made  recommendations, and we updated the status of those recommendations.

Assessing only three key projects limits possible statements about the  Bureau’s entire schedule. For example, if the Bureau is not following best  practices in creating and maintaining these three project schedules, we  can conclude that the larger integrated schedule is unreliable. This is  because an integrated master schedule consolidates lower-level project  schedules. Thus, errors and reliability issues in lower levels will be  transferred to higher-level schedules. However, if the selected lower-level  projects are deemed reliable, we cannot definitively determine the  reliability of the integrated master schedule because the other projects  that were not assessed may be unreliable. For more details on our scope  and methodology, see appendix I.

We conducted our performance audit from July 2017 to July 2018 in  accordance with generally accepted government auditing standards.

Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

A reliable schedule is critically important for a successful 2020 Census. In  February 2017, we added the 2020 Census to our High-Risk List because  operational and other issues including scheduling are threatening the  Bureau’s ability to deliver a cost-effective enumeration. We reported on  concerns about the quality of the Bureau’s schedule and cost  assessment, the Bureau’s capacity to implement innovative census-taking  methods, and uncertainties surrounding critical information technology  systems. Underlying these issues are challenges in such essential  management functions as the Bureau’s ability to  collect and use real-time indicators of schedule, cost, and  performance;  follow leading practices for scheduling, cost estimation, risk  management, and IT acquisition, development, testing, and security;  and  cost effectively deal with contingencies including, for example, fiscal  constraints, potential changes in design, and natural disasters that  could affect the enumeration.

Reliable scheduling practices are essential for managing tradeoffs  between cost, schedule, and scope. Among other things, scheduling  allows program managers to decide between possible sequences of  activities, determine the flexibility of the schedule according to available  resources, predict the consequences of managerial action or inaction in  events, and allocate contingency plans to mitigate risk. Following  changes in a program, the schedule is used to forecast the effects of  delayed, deleted, and added effort, as well as possible avenues for time  and cost recovery.

Scheduling is important because the cost of counting the nation’s  population has been escalating with each decade. The 2010 Census was  the most expensive in U.S. history at about $12.3 billion, and was about  31 percent more costly than the $9.4 billion 2000 Census (in 2020  constant dollars). According to the Bureau, the total cost of the 2020  Census is now estimated to be approximately $15.6 billion dollars, more  than $3 billion higher than previously estimated by the Bureau.

Moreover, as shown in figure 1, the average cost for counting a housing  unit increased from about $16 in 1970 to around $92 in 2010 (in 2020  constant dollars). At the same time, the return of census questionnaires  by mail (the primary mode of data collection) declined over this period  from 78 percent in 1970 to 63 percent in 2010. Declining mail response  rates have led to higher costs because the Bureau needs to send  temporary workers to each nonresponding household to obtain census  data.

The schedules we reviewed for this report—2020 Census Geographic  Programs, 2018 End-to-End Test Address Canvassing, and 2018 End-to- End Census Test Nonresponse Follow-up—relate to the key activities of  developing an accurate address list and following up with households that  did not mail back their census forms. The Bureau relies on a complete  and accurate address list to maximize the more cost-efficient self- response rate.

The three projects we selected contribute to two of the Census Bureau’s  largest field operations. The Bureau’s Geographic Programs Operation  maintains the Bureau’s master address file and mapping data used to  conduct the 2020 Census. The Bureau’s Geographic Programs Operation  provides the most current address list to the Bureau’s Address  Canvassing Operation, where Bureau staff make updates to the address  list via in-office and in-field procedures. These updates are processed on  an ongoing basis throughout the decade. The Bureau conducts its  Nonresponse Follow-up Operation after Census Day by having  enumerators go door-to-door to determine the housing unit status for  addresses that do not self-respond to the 2020 Census, and enumerate  households that are determined to be occupied.

Selected Census Schedules Better Reflect Characteristics of a Reliable Schedule Compared to Prior Assessment, though Weaknesses Remain

We have previously reported in our Schedule Assessment Guide that a  reliable schedule can provide a road map for systematic execution of a  program, and the means by which to gauge progress, identify and  address potential problems, and promote accountability. The guide  identifies four characteristics of a reliable schedule:

Comprehensive: The schedule should identify all activities and  resources necessary to accomplish the project. The schedule should  cover the scope of work to be performed so that the full picture is  available to managers.

Well-constructed: Activities should be logically sequenced and critical  activities that would affect the timelines of the schedule should be  identified.

Credible: All schedules should be linked to a complete master  schedule for managers to reference and analyzed for how risk  impacts the outcome of the schedule.

Controlled: There should be a documented process for changes to the  schedule so that the integrity of the schedule is assured.

For a schedule to be reliable, it must substantially or fully meet all criteria  for these four characteristics. These characteristics, their related leading  practices, and their criteria are described in more detail in appendix II.

In 2013, we assessed the Bureau’s 2020 Research and Testing and  Geographic Support System Initiative schedules using these criteria.  While the results exhibited some of the characteristics of a reliable  schedule, important weaknesses remained. Both schedules substantially  met one of the four characteristics (controlled) and minimally or partially  met the other three characteristics (comprehensive, well-constructed, and  credible).

For this review, we assessed the 2018 End-to-End Census Test Address  Canvassing, 2018 End-to-End Census Test Nonresponse Follow-up, and  2020 Census Geographic Programs projects’ schedules. We found that  overall the selected schedules better reflected two of the four  characteristics of a reliable schedule compared to our 2013 assessment  (see figure 2).

Examples of the extent to which these characteristics were met are  provided below. For a more detailed explanation of our assessment  results, see appendix III.

Comprehensive–Selected Schedules Partially Meet Characteristic but Do Not Identify Needed Resources

As with our 2013 schedule assessment, our 2018 analysis found that the  Bureau is partially meeting the characteristics of a comprehensive  schedule. For example, the projects we assessed reflect the work to be  accomplished for the project schedules, and each project schedule  includes estimates of the duration of each activity. Additionally, the 2018  End-to-End Census Test Address Canvassing and the 2018 End-to-End  Census Test Nonresponse Follow-up project schedules contain clear start  and finish milestones, and map to the census program work breakdown  structure—a detailed definition of the work necessary to accomplish a  program’s objectives.

This leading practice of capturing all activities was substantially met, not  fully met (see appendix III for a more detailed explanation), because while  for each project all activities and milestones are mapped to their work  breakdown structures by codes, there are no corresponding dictionaries  to define the work. The absence of such a dictionary could potentially  lead to confusion among staff in different census offices about the scope  of the work they are responsible for performing.

Our schedule guide states that a work breakdown structure dictionary is a  valuable communication tool between systems engineers, program  management, and other stakeholders because it provides a clear picture  of what efforts have to be accomplished. Bureau officials stated that  although their 2020 Schedule Management Plan requires each project to  have a schedule work breakdown structure dictionary, as project  schedules are updated, they have not created these required dictionaries.  As an alternative, they noted that the 2020 Census Operational Plan  includes details and definitions of the projects.

Additionally, none of the three schedules we assessed include  information about what levels of resources, such as labor and equipment,  are required to complete the planned work—including this information is  called resource loading. The Bureau’s 2020 Schedule Management Plan  states that it is the responsibility of a representative from a project team  and the schedule staff to assign resources to an individual project  schedule, and that defining and assigning resources should be done  following the testing phase of the 2020 Census Lifecycle.

The Bureau is now in its implementation phase (see figure 3 below), so  according to its management plan, resource loading should have begun.  But it has not. For example, the 2018 End-to-End Census Test Address  Canvassing project schedule did not include any resource information on  the recruiting and hiring goals for the address canvassing field work.

Instead, Bureau officials stated that they are estimating the cost of  activities using a software tool separate from the current schedule  management tool. They further stated that this Bureau-wide solution  includes all 2020 Decennial Census staff as Decennial funded resources.  However, the information in this separate tool has no effect on the  durations or forecasted start and finish dates of detailed activities within  individual projects. Furthermore, the separate tool does not always track  all activities at the lowest level in the schedule, so that Bureau managers  do not have reliable visibility with it on the efforts of the lowest level of  detailed activities.

Resource loading is important for any agency, but is particularly important  for the Census Bureau, given its statutorily mandated deadlines. Missed  deadlines or schedule slippage can easily jeopardize the quality of the  2020 Census, and there is little room for error given that census data are  used to apportion the seats of the House of Representatives, redraw  congressional districts, and allocate billions of dollars each year in federal  financial assistance. In our schedule guide, we reported that including  resources such as labor, materials, and overhead costs can make a  schedule a more useful management tool.

A resource-loaded schedule can help management with things such as  computing labor and equipment hours, calculating total project and per- period cost, resolving resource allocation conflicts, determining whether  all required resources will be available when they are needed, and  establishing the reasonableness of the plan. For example, information on  the resource needs of field operations in the 2018 End-to-End Census  Test would assist management in determining if the appropriate resource  allocations have been made for any given test activity. It would also aide  in forecasting the likelihood that those resources will be available to  complete the 2018 End-to-End Census Test Address Canvassing and  Nonresponse Follow-up activities as scheduled. If the schedule does not  allow insight into the current or projected allocation of resources for these  test activities, the Bureau’s risk of key end-to-end test milestones slipping  increases significantly.

In 2009, we reviewed the Bureau’s schedule and recommended that the  Bureau include estimates of the resources in the 2020 integrated  schedule for each activity as the schedule was built. The Department of  Commerce did not respond to the recommendation at that time. In our  2013 assessment of the Bureau’s schedule, Bureau officials stated that  they hoped to begin identifying the resources needed for each activity in  their schedules by early 2014. However, as of May 2018, the Bureau  has not yet implemented this recommendation. Senior Bureau officials  have now stated that the Bureau would require additional staffing in the  Schedule Management Branch in the Decennial Census Management  Division in order to plan for and implement resource loading. When the  Bureau has resource loaded its schedule, it will be able to use the  schedule more effectively as a management tool.

Well-Constructed–The Bureau Demonstrated Improvement in Selected Schedules Compared to Prior Assessment

Our 2013 assessment of the Bureau’s schedule reported that the Bureau  only minimally met the characteristics of a well-constructed schedule. Our  2018 assessment found that two of the selected project schedules now  substantially met this characteristic and one partially met it. In this  assessment, Bureau officials linked many of the activities clearly and in a  straightforward sequence in the schedule, which was not always the case  in prior assessments.

This improvement is important because it helps staff identify next steps as  they progress through such things as acquiring and mobilizing the staff  needed to conduct the address canvassing and nonresponse follow-up  test field work, and helps managers identify the impact of changes in one  activity on subsequent activities. For example, the schedule lays out the  sequence of activities needed, such as developing training materials,  recruiting field staff, training staff and equipping them with the tools  needed to complete the test. Our assessment also concluded that two of  the three project schedules we assessed have valid critical paths, which  is the sequence of activities in the schedule that, according to their  current status, lead to the program’s earliest completion date. A valid  critical path allows management to focus on activities that will lead to the  project’s success.

The 2020 Census Geographic Programs project schedule partially met  the well-constructed characteristic due to problems existing within the  schedule’s sequencing logic. In particular, we found a large number of  unjustified date constraints and lags. In part because of these  sequencing issues, total float calculations—that is, the amount of time a  predecessor activity can slip before its delay affects the program’s  estimated finish date—appear unreasonably high. Additionally, this  project schedule has activities on the critical path with long durations. For  example, the project schedule for Geographic Programs included several  long-duration activities on its critical path that relate to the Bureau’s  collection of community boundary data—information essential to  delineating geographic boundaries used in the tabulation of census data.  These critical long-duration activities make it difficult to measure time- critical progress on such activities in the near term.

These issues with how the schedule is constructed can also cause  schedule users to lack confidence in the forecasted dates. Bureau  officials acknowledged that the 2020 Census Geographic Programs  project schedule had logic issues at the time because it was in the middle  of a revision. Bureau officials stated that the standard process is to  update the project schedule in an offline version and then assess the  quality and impacts of changes before acceptance. According to Bureau  officials, the Geographic Programs project schedule did not follow this  process and was instead updated in the live version of the schedule  because of time constraints.

Credible–Selected Schedules Partially Meet Characteristic, but the Bureau Has Not Carried Out a Schedule Risk Analysis

Our 2013 assessment of the Bureau’s schedule found that the Bureau  minimally met the characteristics of a credible schedule. Our 2018  assessment of the Bureau’s schedule found that the Bureau’s scheduling  practices for a credible schedule have improved. We found that there is  now a clear relationship between lower-level activities and higher-level  activities and milestones, and there is generally better consistency of  dates between the project schedule and higher-level management  documents.

However, the Bureau has not carried out a systematic quantitative risk  analysis on its schedule. A schedule risk analysis is a statistical  simulation of the possible effects of threats, opportunities, and general  uncertainty to a program’s schedule that results in a quantifiable level of  confidence in meeting the program’s key milestone dates. While the  Bureau has identified and continues to track risks to its 2018 End-to-End  Test address canvasing and nonresponse follow-up efforts in risk  registers, a quantitative risk analysis would illustrate the impact of risks on  the project schedule, and how those risks would affect the Bureau’s ability  to meet milestones on time. Such an analysis would also provide a  measure of how much time contingency should be built in the schedule to  help manage prioritized risks, and, implicitly, provide indications of where  additional resources might be needed to stay on schedule.

In response to our 2013 schedule assessment, Bureau officials said they  were waiting for decisions about scheduling software before making  decisions about a schedule risk analysis. As of May 2018, the Bureau has  conducted three risk analyses to prove the software’s capability.  However, the Bureau still had not conducted a schedule risk assessment  on the current integrated master schedule used to manage the 2020  Census program.

Without a schedule risk analysis, the Bureau cannot determine the  likelihood of each project’s completion date; how much schedule risk  contingency is needed to provide an acceptable level of certainty for  completion by a specific date; which risks are most likely to affect the  schedule; how much contingency time each risk requires; and the  sequence of activities that are most likely to delay the project. Senior  Bureau officials stated that a schedule risk assessment plan and process  was approved by Bureau management in late May 2018 and that they  hope to implement this plan in summer 2018. They intend to conduct an  internal review over the next couple months to determine how to best use  the information this risk assessment would yield. Follow through on their  plans is critical to ensuring our recommendation is implemented.

Controlled–Selected Schedules Substantially Meet the Characteristic

As with our 2013 schedule assessment, our 2018 analysis reported that  the Bureau’s scheduling practices are substantially meeting the  characteristics of a controlled schedule. Our analysis determined that  there are no date anomalies in the project schedules, such as planned  dates in the past or actual dates in the future. We found the schedule was  current as of the date delivered to us, and according to Bureau  documents, the schedule is updated weekly following an established  schedule process.

Additionally, the Bureau reported that it has a schedule management  process in place and a method for logging changes to the schedule in  accordance with leading practices. Bureau officials reported that they  monitor schedule trends, including bi-weekly schedule reliability checks  using the Defense Contract Management Agency 14-Point assessment, a  commonly used set of schedule integrity and reliability measures. Bureau  officials also provided the May 2014 Program Change Management  Process Strategy which defines the process for initiating changes to the  integrated performance measurement baseline configuration; analyzing  the impact of changes to project cost, schedule and scope; approving or  disapproving changes; and updating project or product specifications and  baselines.

However, our assessment found that the Bureau did not fully meet this  characteristic for a controlled schedule. The Bureau lacked sound  documentation of the schedule in the form of a schedule basis document,  and changes to the current schedules in the form of a schedule narrative.  The current schedule should be documented in a schedule narrative with  each update, including changes made to the schedule during status  updates and changes that are justified along with their likely effect on  future activities. The Bureau had not prepared such narratives.  Additionally, none of the three schedules were supported by a schedule  baseline document—a single document that defines the organization of a  schedule, describes the logic of the network, describes the basic  approach to managing resources, and provides a basis for all parameters  used to calculate dates. Sound documentation helps with analyzing  changes in the program schedule and identifying the reasons why actual  schedule results vary from their estimates, thereby contributing to the  collection of data that can be useful to evaluations of schedule efforts,  and that can be used to support future estimates.

While the Bureau has made improvements to implement the  recommendations regarding the comprehensiveness and construction  characteristics of the Bureau’s scheduling practices, the Bureau’s lack of  resource loading and a risk assessment of the schedule continue to affect  the reliability of the Bureau’s schedule. The schedule would be a more  useful management tool if the Bureau increased the schedule’s reliability  by addressing these weaknesses. To address these remaining  weaknesses, we continue to believe that these recommendations are  valid in order to ensure the 2020 schedule can support key management  decisions.

We provided a draft of this report to the Department of Commerce. In its  written comments, reproduced in appendix IV the Department of  Commerce agreed with our findings.

We are sending copies of this report to the Secretary of Commerce, the  Under Secretary of Economic Affairs, the Acting Director of the U.S.  Census Bureau, and interested congressional committees. The report  also is available at no charge on GAO’s website at http://www.gao.gov.

If you have any questions about this report, please contact me at (202)  512-2757 or goldenkoffr@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff that made major contributions to this report are  listed in appendix V.

Appendix I: Objective, Scope, and Methodology

This report assesses the extent to which the Bureau is using leading  practices for scheduling key projects. We did this by focusing on three  2020 projects. We selected the three projects from the December 17,  2017, version of the 2020 Census integrated master schedule. That  schedule consists of 255 total projects, of which 134 were remaining to be  completed. We made our selections based on the cost of the projects,  their significance to the 2020 Census, and the fact that they were in  progress. The 3 projects selected for review are 2018 End-to-End Census  Test Address Canvassing, 2018 End-to-End Census Test Nonresponse  Follow-up, and 2020 Census Geographic Programs.

We reviewed the project schedules and underlying sub-schedules to  assess them against the 10 scheduling leading practices by:

Checking for specific problems that could hinder the schedule’s ability  to respond to changes. For example, we:

Examined if there are any open-ended activities (i.e., activities  with no predecessor and/or successors),

Searched for activities with poor logic:

For example, Start to Start successor only or Finish to Finish  predecessor only which represent dangling logic, or

Logic on summary tasks rather than attached to detailed tasks  (summary tasks are for organizing the schedule and should  not drive the logic).

Looked for activities with constraints which keep the schedule rigid  (e.g., start no earlier than, finish no later than, etc.),  Identified any lags or leads which should only be used to show  how two tasks interact and not to represent work,

Determined if activities were resource loaded—which helps to cost  out the schedule—and examine whether resources are over  allocated or not available when needed,

Examined the length of activity durations and compared them to  the program management review cycle,

Checked for horizontal and vertical integration within the schedule,

Examined the schedule critical path to determine whether or not it  was reliable and logical,

Examined schedule float and determine if it was reasonable, and

Examined whether the schedule was baselined, its status cycle,  and what deviations there were from the original plan. We also  determined if there were any actual start or finish dates recorded  in the future and whether there was any broken logic between  planned tasks.

We also interviewed Bureau officials responsible for the 2020 schedule.  We scored each scheduling leading practice on a five-point scale ranging  from “not met” to “met.” We determined the characteristic assessment  rating by assigning each best practice rating a number and taking the  average. The numerical ratings and ranges of the resulting averages are  as follows.

We then compared these results with our prior assessments of the  Bureau’s schedule, particularly those where recommendations were  made, and we updated the status of those recommendations.

Assessing only three key projects limits possible statements about the  Bureau’s entire schedule. For example, if the Bureau is not following best  practices in creating and maintaining the three project schedules, we can  conclude that the larger integrated schedule is unreliable. This is because  an integrated master schedule consolidates lower-level project schedules;  errors and reliability issues in lower levels will be transferred to higher- level schedules. However, if the selected lower-level projects are deemed  reliable, we cannot definitively determine the reliability of the integrated  master schedule because the other projects that were not assessed may  be unreliable.

Appendix II: Description of Scheduling Leading Practices

Characteristic Comprehensive Capturing all activities

Description  A schedule should reflect all activities defined in the project’s work breakdown  structure and include all activities to be performed by the government and contractor.

The schedule should realistically reflect the resources (i.e., labor, material, and  overhead) needed to do the work, whether all required resources will be available  when needed, and whether any funding or time constraints exist.

The schedule should reflect how long each activity will take to execute.

The schedule should be planned so that all activities are logically sequenced in the  order they are to be carried out.

The schedule should identify the critical path, or those activities that, if delayed, will  negatively impact the overall project completion date. The critical path enables  analysis of the effect delays may have on the overall schedule.

The schedule should identify float—the amount of time an activity can slip in the  schedule before it affects other activities—so that flexibility in the schedule can be  determined. As a general rule, activities along the critical path have the least amount  of float.

The detailed schedule should be horizontally traceable, meaning that it should link  products and outcomes associated with other sequenced activities. The integrated  master schedule should also be vertically traceable—that is, varying levels of  activities and supporting subactivities can be traced. Such mapping or alignment of  levels enables different groups to work to the same master schedule.

The schedule should include a schedule risk analysis that uses statistical techniques  to predict the probability of meeting a completion date. A schedule risk analysis can  help management identify high priority risks and opportunities.

Progress updates and logic provide a realistic forecast of start and completion dates  for program activities. Maintaining the integrity of the schedule logic at regular  intervals is necessary to reflect the true status of the program. To ensure that the  schedule is properly updated, people responsible for updating should be trained in  critical path method scheduling.

A baseline schedule represents the original configuration of the program plan and is  the basis for managing the project scope, the time period for accomplishing it, and  the required resources. Comparing the current status of the schedule to the baseline  can help managers target areas for mitigation.

Appendix III: Assessment of the Extent to Which the Bureau Followed Scheduling Leading Practices

Appendix IV: Comments from the Department of Commerce

Appendix V: GAO Contact and Staff Acknowledgments

Other key contributors to this report include Ty Mitchell, Assistant  Director; Juaná Collymore; Rob Gebhart; Yvette Gutierrez; Jason Lee;  Kayla Robinson; Cynthia Saunders; and Timothy Wexler.

The Census Bureau is required to count the population as of April 1, 2020; deliver state counts to the President by December 31, 2020; and provide redistricting data to the states by April 1, 2021. To meet these deadlines, the Bureau manages an integrated master schedule with hundreds of projects that must proceed in concert with each other.

We looked at the reliability of the Bureau's project schedules and found ongoing issues. For example, none of the schedules we reviewed contained information on resource needs and availability. We've previously recommended that the Bureau include resource estimates in the 2020 master schedule.


Private School Choice: Requirements for Students and Donors Participating in State Tax Credit Scholarship Programs

TCS programs offer state tax credits to individuals or businesses that donate to scholarship funds for students to attend private elementary and secondary schools. Through these credits, donors may reduce the amount they owe in state taxes by the full or a partial amount of their donation, depending on each program's rules. Designing a TCS program requires that many decisions be made, such as which students will be eligible to receive scholarships and the effect donations will have on donors' state taxes. GAO was asked to review key characteristics of TCS programs.

This report examines (1) state TCS programs' policies regarding student eligibility and scholarship awards, and (2) how donating to a TCS program could affect the amount of state and federal taxes owed by donors.

For both objectives, GAO reviewed publicly-available documents about student eligibility and tax provisions for all 22 programs authorized as of January 2018 and verified the accuracy of the information with state program officials. GAO did not conduct an independent legal review of state laws and regulations. GAO also interviewed federal officials and reviewed relevant federal guidance and policy documents.

In 2018, there were 22 tax credit scholarship (TCS) programs authorized across 18 states, which provide state tax credits for individual and business donations that fund scholarships for students to attend elementary and secondary private schools (see figure).

To determine the eligibility of students for these scholarships, most TCS programs use household income and have various approaches to determine scholarship award amounts. Income limits vary widely among programs, ranging from approximately $32,000 to $136,500 per year for students from a four-person household in school year 2017-2018. Programs have different requirements for how students can use their scholarships and different methods for calculating scholarship amounts. More than half of the programs (13 of 22) allow students to use their scholarship money for costs like transportation and books in addition to tuition, whereas the remaining programs (9 of 22) require scholarships funds to be used for tuition only. Average scholarship awards in school year 2016-2017 ranged from $500 to $5,468 per student among the 16 programs that published or provided GAO with such information.

The effect of TCS donations on donors' tax liability depends on program characteristics and donors' financial circumstances. Specifically, half of the 22 programs allow eligible donors to claim 100 percent of their donations as state tax credits, meaning that for each dollar donated, state taxes owed are reduced by a dollar, up to any maximum set by the state. The remaining 11 programs allow donors to claim from 50 to 85 percent of their donations as state tax credits. Programs often specify a maximum tax credit that may be claimed each year by a donor, by all donors combined, or both. Individual donors may also reduce their federal tax liabilities through the federal deduction for charitable contributions, depending on their financial circumstances and applicable tax provisions.

State tax credit scholarship (TCS) programs offer tax credits to individuals  or businesses that donate to scholarship funds for students to attend  private elementary and secondary schools. Through these credits, donors  may reduce the amount they owe in state taxes by the full or a partial  amount of their donation, depending on each program’s rules. In some  cases, TCS program donations may also affect the amount of federal  taxes donors owe, through the federal deduction for charitable  contributions. TCS programs are one type of private school choice  program that states have established to help fund students’ attendance at  private schools. Other types of private school choice programs include  school voucher and education savings account programs. As of January  2018, there were 22 TCS programs authorized across 18 states, with an  additional program enacted later in the year. In school year (SY) 2016- 2017 (the most recent year for which information was available), TCS  programs collectively awarded scholarships totaling more than $856  million, according to state-reported data.

Designing a TCS program requires that many decisions be made, such  as who will be eligible to receive scholarships and the effect donations will  have on the amount donors owe in state taxes. You asked us to review  key characteristics of state-administered TCS programs.

This report examines (1) state TCS programs’ policies regarding student  eligibility and scholarship awards, and (2) how donating to a TCS  program could affect the amount of state and federal taxes owed by  donors.

To complete our work for both objectives, we reviewed publicly-available  information about student eligibility, scholarship awards, and tax  provisions for the 22 TCS programs that were authorized by the  beginning of 2018. We verified the accuracy of this information with state  officials from each program. We did not conduct an independent review  of state laws and regulations. Throughout the report, we provide the most  recent and complete information available for the various types of  information. Specifically, unless otherwise noted, student eligibility  requirements are as of SY 2017-2018 and tax provisions are as of  calendar year (CY) 2018. Scholarship amount information is from SY  2016-2017 and program donations made by taxpayers are from CY 2016.

We also used economic data from the 2012-2016 American Community  Survey (ACS) 5-year estimates administered by the U.S. Census  Bureau. ACS is a national survey that collects information about social,  economic, demographic, and housing characteristics from a sample of  households. For this report, we used ACS estimates of the state level  median income for a four-person household to provide context for TCS  program income eligibility requirements in relation to state income  distributions. For the TCS programs with income eligibility requirements,  we calculated program income limits for a four-person household based  on each TCS program’s income eligibility requirements for SY 2016-2017  and 2017-2018. We then compared these limits to 2012-2016 5-year ACS  estimates of state median household income for four-person households.  In addition to verifying the program data we collected with state officials,  we reviewed ACS documentation on survey design and methodology  used to produce the estimates of state median household income. We  concluded that the data presented in this report were sufficiently reliable  for the purposes of our reporting objectives.

In addition, we spoke with officials at the U.S. Department of Education to  obtain their observations about the state programs, and identify whether  the department had conducted research related to TCS programs. We  also spoke with other stakeholders such as TCS program researchers to  understand current research and emerging issues regarding these  programs.

For the second objective, in addition to reviewing program documents  and verifying the information with state officials, we developed illustrative examples of how TCS donations may affect state and federal tax liabilities  for donors with varying tax circumstances—including examples that  assume different percentages of a donation that donors are allowed to  claim as a state tax credit (referred to in this report as tax credit  percentages). Specifically we developed examples that assume a 50  percent TCS program tax credit and examples that assume a 100 percent  TCS program tax credit, which represent the smallest and largest tax  credit percentages offered by existing TCS programs. In August 2018, the  Internal Revenue Service (IRS) and Treasury published proposed  regulations that, if finalized without modification, would change the extent  to which individuals who make TCS program donations can reduce their  federal tax liability. We did not address the proposed regulations in our  analysis because they were not final at the time this report was published  and are therefore subject to change. We also reviewed relevant federal  laws, regulations, and other documents related to federal tax policy and  spoke with the IRS regarding federal deductions for charitable  contributions and state and local taxes.

We conducted this performance audit from January 2018 to September  2018 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

As of January 2018, there were 22 TCS programs authorized across 18  states (see fig. 1). All TCS programs are state programs; there are no  federal TCS programs. Decisions about whether to develop and operate a  TCS program (and how to structure the program) are completely at the  discretion of each state; there is no federal role in establishing these  programs. Most TCS programs began within the last 10 years; the first  TCS program awarded scholarships in Arizona in 1998 and Florida  created the newest program in 2018, according to state program  documents and officials.

Scholarships are funded through donations from private individuals and  businesses, and the financial impact to states from TCS programs  primarily occurs through forgone revenue resulting from the associated  tax credits. In all 22 programs, state agencies and nonprofit  organizations both play a role in administering the programs, with the  specific responsibilities varying by program:

State departments or agencies responsible for tax administration,  education, or both, generally administer these programs. For  example, they may approve schools or nonprofit scholarship granting  organizations or disseminate program information or guidance to  potential donors, scholarship students, or the public.

Nonprofit scholarship granting organizations (SGO) are generally  responsible for managing some aspects of the donation process— such as collecting donations—as well as awarding scholarships to  students.

Most Programs Use Income to Determine Student Eligibility and Consider Various Factors When Setting Scholarship Award Amounts

States’ TCS programs often determine student eligibility for scholarships  based on household income and use a range of factors to determine  scholarship award amounts.

Income requirements: Seventeen of the 22 TCS programs have income  limits (i.e., the maximum amount of household income a student can have  and still be eligible for a scholarship). As shown in figure 2, income  limits varied widely among programs, ranging from just under $32,000 to  about $136,500 per year for students from a four-person household in SY  2017-2018. For context, we compared these income limits to the 2012- 2016 5-year ACS estimates of state median household income for four- person households. Six of the 17 programs had household income limits  in SY 2017-2018 above their state’s median income. This included two  programs each in Arizona and Pennsylvania which collectively accounted  for about one-third of all TCS scholarships awarded to students in SY  2016-2017, according to state-reported data. Of the 17 programs that  have household income limits, 6 also require SGOs to further consider  income when selecting scholarship recipients among eligible students.

Such requirements include giving preference to scholarship applicants  from lower-income households or ensuring that a certain percentage of  scholarship recipients come from lower-income households.

Of the remaining five TCS programs that do not use income to determine  eligibility, three use one or more other types of eligibility criteria, such as  whether the student has a disability, and two—Montana’s TCS program  and Arizona’s Original Individual Income Tax Credit program—are open  to all school-aged residents.

TCS programs collected limited information on the household incomes of  scholarship recipients. The 11 programs that had income information on  recipient families collected and reported it in different ways. For example,  the Alabama program requires SGOs to report the total number and  amount of scholarships awarded to students qualifying for the federal free  and reduced-price lunch program and makes the information publicly  available. Arizona makes an annual report publicly available on the  state’s four TCS programs, including breakdowns of the number of  students receiving scholarships from various income levels.

Other eligibility requirements: Some TCS programs’ eligibility criteria  for student scholarship recipients include other factors, such as students’  disability status or previous schooling. Specifically, 7 of 22 programs are  limited to students with disabilities or allow students with disabilities to  qualify for a scholarship even if they do not meet some requirements for  students without disabilities. For example, to be eligible for Virginia’s  program, all students must have a household income below a certain  amount, but that amount is higher for students with disabilities. South  Carolina’s program is limited to students with disabilities. In addition,  some programs may require students to have previously attended a  public school (9 of 22) or live in the attendance area of a public school  with performance challenges (5 of 22). See appendix II for more  information on the eligibility criteria of TCS programs.

TCS programs have different requirements for how students can use their  scholarships and different methods for calculating scholarship amounts.  More than half of the programs (13 of 22) allow students to use their  scholarship money for costs like transportation and books in addition to  tuition, whereas the remaining programs (9 of 22) require scholarships  funds to be used for tuition only. Four programs allow donors to  recommend that their donations fund scholarships for specific students.  Average scholarship awards in SY 2016-2017 ranged from $500 to  $5,468 per student among the 16 programs that published such  information or provided it to us. (See appendix II for more information).

Most programs require SGOs to consider one or more factors related to  student or school characteristics when determining scholarship award  amounts. As shown in table 1, these factors may include the cost of  private school tuition or the state funding amounts for public school  students, among other factors.

See appendix II for more information on program requirements related to  scholarship amounts.

Effect of TCS Donations on Taxes Owed Depends on Factors Such as Tax Credit Percentages and Individual Circumstances

The extent to which TCS program donations affect the amount that  donors owe in state and federal taxes depends on program  characteristics—such as the percentage of the donation that the rules of  the program allow donors to claim as a state tax credit (referred to in this  report as “tax credit percentages”) and limits on donation amounts—along  with donors’ financial circumstances. Almost all of the TCS programs  (20 of 22) offer tax credits to businesses for income or other types of  taxes, while more than half offer tax credits to individuals for their income  taxes (13 of 22). More than half of programs (13 of 22) offer tax credits  for cash donations only, while the remaining 9 programs also allow for at  least one type of “in kind” donation, such as a property donation.

Eleven of the 22 programs allow eligible donors (either individuals,  businesses, or both) to claim 100 percent of their donations as state tax  credits, meaning that, for each dollar donated, the amount of state taxes  owed (i.e., the donor’s tax liability) is reduced by a dollar, up to any  maximum donation limits set by the program. The other 11 programs offer  tax credits of 50 percent to 85 percent of donations (see table 2). For  example, Indiana and Oklahoma offer tax credits of 50 percent of the  donation value, meaning that donors can reduce their state tax liability by  50 cents for every dollar donated. All but one of the programs prohibit  donors from receiving a tax credit greater than their tax liability in a given  year, although two thirds of the programs allow donors to carry forward  portions of the credits to use in future years.

Sixteen of the 22 programs limit the amount of tax credits each donor  may claim per year and programs vary in how they structure these  limits. The programs that set annual limits for donors generally do so in  one or both of the following ways:

Dollar amount limits: Thirteen programs limit the dollar amount of  TCS program tax credits that donors can claim in a given year. These  limits ranged from a maximum tax credit of $150 for either individuals  or businesses in Montana’s program, to a maximum tax credit of $1  million for either individuals or businesses in Illinois’ program in CY  2018.

Limits based on percentage of tax liability: Four programs limit the  amount of the TCS program tax credits a donor can claim to a  percentage of the donor’s total income tax liability. These limits  ranged from 50 to 90 percent of a donor’s income tax liability in CY  2018. For example, in South Carolina donors could receive a tax  credit up to 60 percent of their total income tax liability for the year of  the donation.

All but three programs specify a maximum total amount, or cap, of TCS  program tax credits that may be claimed each year for the program as a  whole (see table 3). Programs’ procedures vary if the cap is reached in  a given year. For example, in Rhode Island, potential donors may apply  for credits on a “first come, first served” basis once the application period  starts until all credits are taken. In 2018, all of the credits were claimed on  the first day of the application period and a drawing was held to determine  who would receive credits among those who applied on that first day.

Georgia’s TCS program offers a maximum tax credit percentage of 100  percent when total donations do not exceed the donation cap. However, if  total donations exceed the program cap, the allowable tax credit  percentage is prorated among donors who apply on the day the program- wide cap on tax credits is reached.

Twenty programs published or provided us with information on donation  amounts, such as total donations and average donations. Among these  programs, total program-wide donation amounts in CY 2016 ranged from  $43,865 to $553 million. (See appendix III for more information about  donation amounts.)

TCS Donations and Federal Taxes for Individual Donors

In addition to reducing their state tax liabilities, some individuals who  make TCS program donations may also be able to reduce their federal  income tax liabilities through the federal tax deduction for charitable  contributions. In August 2018, IRS and Treasury published proposed  regulations that, if finalized without modification, would change the extent  to which individuals who make TCS program donations can reduce their  federal tax liability. However, the proposed regulations were not final at  the time this report was published and are therefore subject to change. As  a result, the information we present below does not address the proposed  regulations.

Currently, the extent to which individuals may reduce their federal income  tax liabilities as a result of their TCS donation depends on their specific  circumstances, such as whether they itemize their deductions (versus  taking the standard deduction), the federal rates at which their income is  taxed, and the amount of federal deductions they take for state and local  taxes. More specifically, the effect of a TCS donation on an individual  donor’s federal tax liability depends on the following:  Itemizing federal deductions and taking the deduction for  charitable contributions: Taxpayers benefit from itemizing  deductions—such as those for state and local taxes, mortgage  interest, and charitable contributions—if they exceed the standard  deduction. Taxpayers, including TCS donors, may only claim a  federal deduction for charitable contributions if they itemize.

Federal tax rate: The reduction in federal taxes owed as a result of  the federal deduction for charitable contributions depends on the  donor’s applicable federal tax rate. Given the same deduction amount,  taxpayers subject to higher tax rates will generally reduce their tax  liabilities by larger amounts than taxpayers subject to lower tax rates.

Deduction for state and local taxes: When filing federal taxes,  taxpayers who itemize may take a deduction for state and local taxes  they have paid during the tax year. Beginning in tax year 2018,  individual taxpayers may deduct no more than $10,000 in state and  local taxes on their federal tax returns. Taxpayers who claim state  tax credits for TCS program donations reduce their state tax liability,  which may in turn reduce the amount they may deduct on their federal  tax return for state and local taxes paid.

Interaction between the federal deduction for charitable  contributions and the federal deduction for state and local  taxes: Generally, if a donor pays $10,000 or less in state and local  taxes, the amount of the deduction for charitable contributions may be  fully or partially offset (i.e., canceled out) by a decrease in the  deduction for state and local taxes paid as a result of the TCS  program tax credit. Conversely, taxpayers who pay more than  $10,000 in state and local taxes cannot deduct the full amount of state  and local taxes they paid. Therefore, the reduced state and local  taxes paid as a result of the tax credit generally may not offset the  amount of the deduction for charitable contributions for these  taxpayers.

See figure 3 for a description of how individuals’ TCS program donations  could affect their federal tax liabilities.

Combined Reduction in State and Federal Tax Liability

TCS program donations can lead to a range of possible changes to an  individual’s state and federal income tax liabilities, including some  scenarios where donors could reduce their combined state and federal  tax liability by an amount that is greater than the amount of their donation  (see for example, Donor A in figure 4). Figure 4 shows four examples of  how state and federal income taxes may be reduced for hypothetical  individual donors in states with 100 percent and 50 percent tax credit  scholarship programs.

We provided a draft of this report to Education and IRS for review and  comment. While the draft was under review at these agencies, IRS and  Treasury issued proposed regulations related to state tax credits and the  federal deduction for charitable contributions. We updated the report to  include information about these proposed regulations but did not alter our  analysis to reflect the proposed regulations because they were not final at  the time this report was published and are therefore subject to change.  We provided a revised draft to IRS as the revisions directly relate to IRS’s  areas of responsibility, and informed Education about our approach to  addressing the proposed regulations.

IRS did not provide formal comments on the draft report.

Education’s comments are reproduced in appendix I. Education also  provided technical comments, which we incorporated as appropriate. In  its comments, Education noted that it has no role in developing,  operating, or overseeing TCS programs, and provided a variety of  comments and observations on the draft report. For example, Education  suggested that we add additional details about certain TCS program  requirements, such as more information about state tax rules and  permissible uses of scholarship funds. We incorporated these comments  as appropriate.

Education also suggested that we delay publication of this report until the  IRS regulations are finalized, as Education thought that the report could  be more helpful at that time. GAO policy is to communicate audit and  evaluation results in a timely manner to decision makers and others who  either requested the work or may need the information to bring about  needed changes. Therefore, we are issuing the report as planned.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of Education, and the Commissioner of  Internal Revenue. In addition, the report is available at no charge on the  GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (617) 788-0580 or nowickij@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix IV.

Appendix I: Comments from the Department of Education

Appendix II: State Tax Credit Scholarship Program Eligibility and Scholarship Award Characteristics

Appendix III: Information About Tax Credit Scholarship Program Tax Provisions

Program name  Programs available for both individual and business donors  Alabama Educational  Scholarship Program  $50,000 or 50% of tax  liability, whichever is lower  (individual)  50% of business tax liability  $1,000 (individual)  75% of business tax liability   $1 million (individual and  business) $350,000 (Individual and  business)  $150 (Individual and  business)  $1,000 (individual)  $100,000 (business)   60% of tax liability (Individual  and business)

Virginia Education  Improvement  Scholarships Tax Credits  Program  Programs available for individual donors only  Arizona Original  Individual Income Tax  Credit Program  $81,250 (individual)  No limit for business donors  $555 (individual)  $552 (individual)

Percent of donation that may be claimed as a credit

Maximum donation amounts  vary from 50% to 100% of  tax liability  $510,000 or no more than  10% of program credits  2 percent of wages paid  no  In Oklahoma, Pennsylvania, and Rhode Island, the percentage of donations that can be claimed as a  tax credit increases if donors commit to donating for 2 years. In Oklahoma, that percentage increases  from 50 percent to 75 percent. In the two Pennsylvania programs and the Rhode Island program, the  percentage increases from 75 percent to 90 percent.

Appendix IV: GAO Contact and Staff Acknowledgments

In addition to the individual named above, Nagla’a El-Hodiri (Assistant  Director), Barbara Steel-Lowney (Analyst-in-Charge), Jeff Arkin, and  Jessica L. Yutzy made key contributions to this report. Also contributing to  this report were Deborah Bland, Lilia Chaidez, Sarah Cornetto, Caitlin  Cusati, Paulissa Earl, Alison Grantham, Kirsten Lauber, Sheila R. McCoy,  Mimi Nguyen, Jessica Orr, Michelle Philpott, Paul Schearf, and Andrew J.  Stephens.