HUD’s WCF was established in 2016 to provide a mechanism for the department to centralize and fund federal shared services used across HUD offices and agencies. According to its Committee Charter, the three goals of the WCF are to: align incentives for efficient enterprise operations through users paying for goods and services; establish accurate and timely cost estimates for goods and services; improve planning, increase visibility and transparency, and support the efficient and effective delivery of goods and services. To begin WCF operations in fiscal year 2016, HUD transferred approximately $44 million in funding from the salaries and expenses accounts of OCFO and OCHCO to the newly established WCF. In fiscal year 2017, the WCF began to bill its customers—17 HUD offices that purchase services financed through the fund—directly for their estimated use of services. HUD’s WCF is different from other intragovernmental revolving funds that we have previously reviewed in that it does not fund internally provided services at this time. The WCF is currently used as a centralized funding method to pay for the costs of four established shared services agreements—or interagency agreements—between HUD and three external shared service providers: USDA’s National Finance Center (NFC) and Treasury’s Administrative Resource Center (ARC) and Shared Services Programs. See table 1 for more information about the agencies providing shared services to HUD. According to WCF Division officials, HUD plans to expand the WCF in the future to finance both internal and additional external goods and services. For example, the WCF’s fiscal years 2019 and 2020 budget justifications requested funding to centralize and support activities such as a Data Management Initiative and the Real Estate Assessment Center’s (REAC) physical and financial assessment services, respectively. However to date, HUD did not receive budgetary authority to proceed with including either activity in the WCF. Several offices within HUD share responsibility for the management and operations of the WCF, including the WCF Division and business line offices. See figure 1 for information on the WCF’s financial operations and entities involved. HUD defines most of the roles and responsibilities for management and oversight of the WCF. According to HUD policy and guidance documents: The WCF Committee provides financial and operational oversight of the WCF, including advising and supporting the WCF’s strategic direction and providing annual approval of the WCF financial plan and budget, among other responsibilities. The Committee includes representation from OCFO leadership and all customer offices. The WCF Division within OCFO oversees the financial management of the fund, including managing day-to-day operations and establishing cost accounting for all shared services and customers that use the fund. In addition, the WCF Division supports customers with WCF-specific services, such as billing and service usage reports. OCFO and OCHCO manage the provision of the services financed through the WCF to customer offices. As the designated business line offices, OCFO and OCHCO oversee the quality and timely delivery of services, including monitoring service provider performance and serving as the liaisons between HUD customer offices and service providers concerning any issues with service quality. WCF Customers place orders with the WCF Division to receive services from the external service providers. In addition, customers reimburse the WCF for their estimated use of those services. However, HUD also performs additional actions to support the efficient and effective delivery of goods and services consistent with the goals of the WCF. Specifically, the WCF Division conducts business process analyses to identify opportunities for efficiencies across the department. Yet, there is no mention in guidance of the roles and responsibilities of the WCF Division, business line offices, or other stakeholders in identifying, monitoring, and implementing the actions recommended because of these analyses. In support of the WCF’s goal to support efficient and effective delivery of goods and services, the WCF Division provides quarterly usage reports to customers and business line offices and assists them with monitoring their consumption and associated costs of shared services. WCF Division officials told us they conduct a more detailed review of the data when they find anomalies, such as unusually high volumes of transactions. WCF Division officials told us that they will collaborate with the responsible business line office to conduct a business process analysis, which is used to identify actionable ways to address the cause of the high service volume and costs in specific circumstances. A business process analysis is generally conducted when there is an availability of resources, support from the business line office, and potential for cost savings or operational efficiencies. For example, in 2018, in response to an increase in the volume of two service areas overseen by OCFO—help desk calls and commercial purchase order accruals—the WCF Division examined data and determined that HUD could reduce its service volume and costs. See text box below. Working Capital Fund (WCF) Business Process Analysis Help desk calls: The WCF Division found that an unnecessarily high number of customer calls to help desks for password resets were contributing to higher costs to the department. For example, more than 20 percent of customer calls to Treasury ARC’s financial management help desk were from customers requesting password resets, which can be manually resolved without calling the help desk and incurring a transaction fee. In fiscal year 2019, the cost to HUD per financial management help desk call was about $128. According to the WCF Division Director, the WCF Division presented its findings to OCFO leadership and the WCF Committee, including five recommendations targeted at reducing system password reset call volume and future costs to the department. Commercial purchase order transactions: Commercial purchase order accruals are more costly because they are manually processed. Among other findings, the WCF Division’s analysis determined that changing OCFO’s current business process for obligations below a certain threshold could reduce the volume of transactions processed. The OCFO official told us that OCFO plans to implement one of the recommendations with a new process for recording those accruals in the first quarter of fiscal year 2020 to reduce the volume of transactions. According to the WCF Division’s analyses, the implementation of this recommendation could achieve potential annual costs savings of nearly $600,000. However, OCFO has not taken actions to address seven remaining recommendations, which the WCF Division found could produce additional benefits, including potential cost savings of more than $400,000 annually. The OCFO official told us that OCFO plans to examine HUD’s fiscal year 2019 service usage to determine the effectiveness of the actions it has already taken to reduce the help desk call and commercial purchase order transaction volume. The estimated help desk call volume and associated cost to HUD for a given year, as agreed upon in HUD’s agreement with Treasury ARC, is generally based on the average of the previous 2 years’ call volume. As such, changes in usage in 1 year will not necessarily result in lower service costs in the next year, but HUD may realize cost savings over time if usage is consistently lower. While they have a process for identifying opportunities for efficiencies through the business process analyses, WCF Division officials acknowledged that they have not defined and documented the WCF Division’s own roles and responsibilities with regard to the analyses. WCF Division officials told us they are focused on other priorities, such as new business line proposals. However, they told us that they are open to defining these roles in the future. There are additional reasons why the WCF Division has not defined and documented roles and responsibilities for these activities. For example, Division officials told us that the Division faces organizational challenges which may limit its own ability to monitor and implement actions. First, as previously discussed, the business line offices are responsible for managing and overseeing the service lines. According to WCF Division officials, the business line offices are primarily responsible for identifying opportunities to achieve efficiencies with service usage, such as through conducting business process analyses. As such, WCF Division officials told us that they can support those offices by monitoring their usage and helping to identify actions to reduce high service volume and costs, but it is ultimately the business line offices’ responsibility to implement any changes to their own processes to improve service usage. In addition, given its location within OCFO, Division officials stated that the WCF Division has more leverage with OCFO to work with those officials to identify business process improvements. WCF Division officials told us that they have not collaborated with OCHCO or made recommendations for actions OCHCO could take to promote efficient and effective usage of the service lines it oversees. While the Division hopes to work with OCHCO to perform the same types of analyses, the WCF Division Director told us that making recommendations to OCHCO would be viewed as outside of its area of authority. According to Division officials, it is the role of the WCF Committee to provide oversight over the business line offices and ensure that such actions are implemented. However, officials acknowledged that these roles and responsibilities related to the business process analyses should be more clearly delineated in the WCF Handbook. Key operating principles for effective management of WCFs state that agencies should clearly delineate roles and responsibilities by defining key areas of authority and responsibility. In addition, federal standards for internal control state that management should establish an organizational structure, assign responsibility, and delegate authority to achieve the agency’s objectives. As part of this, management should develop an organizational structure with an understanding of the overall responsibilities and assign those responsibilities to discrete units to enable the organization to operate in an efficient and effective manner. Without clearly defining and documenting these roles and responsibilities, it is unclear who is responsible for identifying, monitoring, and implementing actions through the business process analyses to address inefficiencies with service usage across HUD. As a result, opportunities to more efficiently and effectively deliver goods and services may not be fully and consistently implemented across the department. HUD established eight total performance metrics which, according to WCF Division officials, are intended to align with one or more of the WCF’s three goals (see table 2). In fiscal year 2018, the WCF Division developed a draft performance scorecard to measure and track WCF performance in areas such as data and analysis, financial management, and stakeholder engagement. Division officials told us that they use 2019 data as their performance baseline for the scorecard and will continue to review and further develop the fund’s metrics and targets. Part of one of the WCF’s goals is to support the efficient delivery of goods and services. Some of the WCF’s metrics, such as those targeting timeliness, will help the WCF Division improve its efficiency with respect to managing the fund. For example, usage report timeliness measures the number of weeks it takes for the WCF Division to share usage reports with customers. As previously discussed, the WCF Division conducts other activities, such as its business process analyses, that are also intended to support efficient service delivery. However, HUD does not assess the results of the WCF Division’s business process analyses to better understand how they contribute to the WCF’s goal. We previously reported that high- performing agencies continuously assess their efforts to improve performance. As part of this, agencies use fact-based understandings of how their activities contribute to accomplishing the mission and broader results. The WCF Division Director told us they have considered metrics to assess broader results of WCF Division activities such as efficiencies, but noted that it is difficult to quantify cost savings attributable to the WCF. This is due, in part, to the fact that HUD’s service agreements are firm- fixed price contracts, meaning that a change in the volume of services HUD consumes in a given year will not result in direct cost savings that same year. However, HUD could assess the results of the WCF Division’s business process analyses, which identified measurable operational and cost efficiencies that HUD could achieve through implementing the division’s recommendations. For example, as previously discussed, in its analysis of help desk calls, the WCF Division identified potential efficiencies that it could track that would contribute to cost savings over time. While some of the recommendations may not directly result in cost savings, the Division identified other efficiencies such as process improvements that could improve the quality of services that it is capable of tracking. For example, the WCF Division determined that changes to HUD’s processes could improve the accuracy of purchase order accrual estimates. Assessing the results of the WCF Division’s business process analyses would help HUD better understand how the Division’s efforts contribute to its goal of supporting the efficient delivery of goods and services. Without doing so, HUD risks not fully realizing more than $1 million in total potential annual savings identified by the WCF Division’s analyses and freeing up resources that could be realigned for other departmental priorities. In addition to tracking progress towards its own goal, assessing these results would allow HUD to demonstrate how the WCF Division contributes to a 2018 cross-agency priority goal of improving the use, quality, and availability of administrative shared services, as well as the department’s related strategic objective to organize and deliver services more efficiently. In response to our review, HUD updated the WCF Handbook—the primary reference guide for customers and stakeholders on WCF operations—to include more current and complete information on WCF policies and procedures. For example, prior to February 2020, we found that the Handbook was not reconciled with more recently developed draft WCF procedures for contract and budget execution, and invoicing and payments. The WCF Handbook now includes these procedures, which contain detailed information about administrative and funds control responsibilities. For example, the procedures describe the WCF Division Director’s cash management responsibilities and designation as the WCF’s Funds Control Officer, as well as roles of WCF customer program and budget officers. In addition, during the course of our review, the WCF Division updated its Handbook to include current information on other policies and procedures. For example, the Handbook now reflects the WCF’s performance metrics, which we previously discussed were initially developed by the WCF Division in 2018, and changes to other key policies, such as the implementation of the WCF’s full cost recovery model in 2019. HUD now has reasonable assurance that its primary reference guide, the WCF Handbook, provides a current and complete understanding of existing WCF policies, consistent with federal standards for internal controls. The WCF’s price and cost allocation methodology is designed to equitably and transparently recover HUD’s annual costs for externally provided shared services financed through the fund. According to HUD officials, the WCF has roughly recovered its costs of financing HUD’s annual shared service agreements since its establishment in 2016. To recover its costs, the WCF Division has a process to divide HUD’s total cost of shared services among the 17 customer offices based on their estimated service usage. For fiscal years 2016 through 2018, the WCF reported a negative accumulated operating result of $400,372, meaning that it reported it recovered nearly all of its costs since its inception. During this time period, the WCF reported years of positive and negative net operating results. Revolving funds such as the HUD WCF are designed to break even over the long term; therefore, year-to-year fluctuations are to be expected. Table 3 provides a detailed breakdown of HUD’s reported cost recovery. According to WCF Division officials, its shared service providers set annual prices for each service line at the outset of the fiscal year using their own pricing methodologies. The service providers then bill HUD in aggregate for an agreed-upon price under annual interagency agreements at firm-fixed prices. As illustrated in figure 2, the WCF Division determines how much each customer office will pay into the WCF for its respective share of HUD’s total shared service costs using internally developed cost drivers and customers’ expected service usage. The cost drivers were selected by the WCF Committee, and are subject to annual review. According to WCF Division officials, the cost drivers are generally similar to those established by the external providers to maintain a clear connection between customer usage and provider charges. In some cases, however, the provider uses a nonunit based cost driver, such as “level of effort.” In those instances the WCF Division uses cost drivers which vary from the providers. According to HUD documentation, “employee count” is a common alternative driver used to fairly and equitably distribute costs among customers. In addition to the direct costs of HUD’s shared services, HUD officials told us that the WCF received authority to collect reimbursement from HUD customers for the WCF Division’s overhead costs in fiscal year 2019. The WCF’s overhead covers operational expenses, including: WCF Division staff salaries and benefits, travel, support contracts, supplies and materials, and training. Customers are billed for a percentage of the overhead based on their share of HUD’s total shared service costs. This charge is included as an individual line item in customers’ WCF billing statements. The WCF Division shares information on pricing and its cost allocation process with customers in several ways. The WCF Handbook includes the billing process, which describes the method for allocating costs among customers. The WCF Division provides customer offices with a billing model which illustrates how costs are allocated across customers by service line. Customer invoices are broken out to show how customers are charged for each service. In addition, the WCF Division provides quarterly usage reports to customers to help them understand their service consumption. According to WCF Division officials, the WCF Division holds meetings and meets with customer offices one-on-one to explain the information provided. Participants in two of our three focus groups said that the WCF cost allocation model increases accountability and is a more equitable and fair distribution of service costs. Participants in all three focus groups said the WCF improved transparency over the old service model because they can see and consider the costs of their shared service usage. For example, one participant told us that, before the WCF, customers did not directly pay for their shared services and, as a result, did not think about costs. The WCF Division has processes to estimate and manage the WCF’s unexpended balance, including establishing an operating reserve requirement. Properly managing unexpended balances is essential for ensuring self-sufficiency of the fund. Part of the unobligated balance includes an operating reserve which, according to WCF Division officials, is needed to finance ongoing revolving activities, facilitate payments, cover discrepancies between actual and projected shared service costs, and ensure continuity in case of funding disruptions. Evaluating Unexpended Balances: A Framework for Understanding In 2013, we identified the following questions for agencies and decision makers to consider when evaluating unexpended balances in federal budget accounts. Findings based on these questions can provide managers with important information about financial challenges and opportunities which may exist; in turn, this information may help guide more effective account and program management. In fiscal year 2017, the size of the WCF’s unexpended balance increased by 60 percent from $10 million to $16 million, and it was relatively stable from fiscal years 2017 to 2018, as shown in table 4. While the WCF Division does not actually provide the shared services that it finances, nor manage dispute resolution between customers and service providers, it does communicate with customers on fund-related issues—such as shared service billing and usage reports. Key operating principles for effective management of working capital funds state that to be flexible to customer input and needs, agencies should communicate with customers regularly and in a timely manner, and develop a process to assess whether customer demands are met. The WCF Division communicates and interacts directly with customers through a variety of channels. For example, WCF Division officials told us that they: organize quarterly WCF Committee meetings, hold meetings to provide information and answer questions about interpreting usage reports, and use an email inbox for communication between Division staff and customers. The WCF Division will also contact customers directly when issues, such as anomalies in shared service usage, are identified. Customers in all three focus groups reported that they turn to the WCF Division when issues or questions about WCF-related issues arise, and are generally satisfied with the Division’s communication and responsiveness. HUD’s business line offices—those offices that oversee HUD’s agreements for externally provided shared services—have mechanisms to communicate with customers and obtain feedback on shared service quality. For example, an official from OCFO—the office that oversees financial management, procurement, and travel services—told us that OCFO has an email inbox dedicated to questions and concerns regarding services. Officials from OCHCO—which oversees human resource (HR)- related services—told us that OCHCO holds recurring meetings with customer offices and reviews feedback from government-wide employee surveys. That feedback is then used to inform HUD’s annual negotiations for HR-related shared services and improve service delivery. According to the WCF Division Director, the WCF Committee quarterly meetings provide an additional opportunity for customer offices to provide feedback to business line offices on shared services. Business line office officials also told us they monitor data on service provider performance and go directly to the provider when discrepancies between the provider’s actual performance and agreed-upon performance metrics are identified. However, while participants in all three of our focus groups acknowledged that OCFO and OCHCO are the designated points of contact for day-to- day issues, participants in two of our three focus groups mentioned that they have not been given opportunities to provide feedback on overall shared service quality. In addition, all three customer focus groups expressed some level of dissatisfaction with the quality of HR services, particularly with hiring. For example, participants in at least one of our focus groups identified the following issues with HR services: complications and excessive time consumption associated with resolving inquiries; HR service providers operating without specialized skills and knowledge relevant to HUD offices and programs; and inadequate adaption to spikes in service demand. The WCF Division Director told us that the WCF Committee has not conducted periodic reviews of WCF business lines since HUD transitioned to shared services. According to the WCF Committee Charter, the WCF Committee is responsible for conducting and overseeing periodic reviews of WCF business lines, as appropriate, to ensure effective management, strong performance, and customer satisfaction. In addition, federal standards for internal control call for periodic reviews of policies, procedures, and related control activities for continued relevance and effectiveness in achieving the entity’s objectives or addressing related risks. According to the WCF Division Director, at this time the committee does not have plans to conduct such reviews. OCHCO officials told us that they are aware of customer complaints with the quality of HR services. According to officials, HUD has a new Chief Human Capital Officer as of May of 2019 who is taking action to obtain feedback on services by engaging directly with HUD customers through listening sessions. OCHCO officials told us they will introduce action plans in fiscal year 2020 to address recurring issues and customer complaints. In addition to these plans and the feedback OCHCO already obtains, OCHCO officials acknowledged that periodic reviews of the service line, as called for in the committee charter, would be valuable. Without conducting periodic reviews of shared services, HUD may not have a comprehensive understanding of whether customer needs are being met and could be missing out on opportunities to identify potential areas for improvement with the performance and management of services for which it is paying. Given the concerns customers in our focus groups told us about HR service lines, HUD should consider making it the first service line that is subject to a review. WCFs provide agencies with an opportunity to operate more efficiently by consolidating services and creating incentives for customers to exercise cost control. HUD could maximize the potential of these opportunities by ensuring that it has a solid framework in place for managing the WCF before it expands to include additional shared services. During the course of our review, HUD took important steps to ensure that the WCF Handbook—the primary reference guide for WCF operations— includes up-to-date and complete information on WCF policies and procedures. Providing access to current and complete information on the management of the WCF promotes an understanding of who should be held accountable, and helps ensure that funds are effectively managed. HUD also took steps to fully document its processes to effectively manage the operating reserves. This will be particularly important as HUD continues to consider expanding the services provided through the WCF. By documenting its existing operating reserve policies, HUD is better positioned to address potential risk and to identify opportunities to achieve budgetary savings or redirect resources to other priorities. However, there are additional opportunities for improvement. Defining roles and responsibilities promotes a clear understanding of who will be held accountable for specific tasks or duties. Most of HUD’s WCF roles and responsibilities are defined in guidance. However, while the WCF Division performs important business process analyses that identity opportunities to improve the efficiency of services, consistent with the goals of the WCF, HUD has not defined roles and responsibilities for the business process analyses, including who is responsible for identifying, monitoring, and implementing actions to achieve the efficiencies. This makes it difficult to hold offices accountable. By clearly defining the responsibilities of the WCF Division, business line offices, and other stakeholders, such as the WCF Committee, HUD could better ensure the business process improvements are being implemented fully and consistently across the department. Moreover, assessing the results of the WCF Division’s business process analyses would help HUD better understand how the Division’s efforts contribute to its goal of supporting the efficient delivery of goods and services. This would better position HUD to achieve the more than $1 million in potential annual savings identified by the WCF Division’s analyses. Finally, opportunities for customers to provide input about services in a timely manner enables agencies to regularly assess whether customer needs are being met. WCF customers have several ways that they can communicate day-to-day concerns about shared services to the business line offices. However, they raised larger concerns during our focus groups, particularly about the quality of the externally provided human resource related services that deserve attention. Periodic assessments of WCF business lines would provide a more comprehensive understanding of customers’ overall satisfaction and would help HUD identify potential areas for improvement with the services for which they pay. We are making a total of three recommendations to HUD. The Secretary of HUD should define and document roles and responsibilities for identifying opportunities to promote more efficient shared service usage through business process analyses, including defining roles for monitoring and implementing actions recommended because of these analyses. (Recommendation 1) The Secretary of HUD, in conjunction with OCFO, should ensure that the results of the WCF Division’s business process analyses are assessed to better understand how these analyses contribute to the WCF’s established goal to support the efficient delivery of enterprise goods and services. (Recommendation 2) The Secretary of HUD should ensure that the WCF Committee conducts periodic reviews of WCF business lines, as authorized in the WCF Committee Charter, to ensure effective management, strong performance, and customer satisfaction. (Recommendation 3) We provided a draft of this report for comment to the Departments of Agriculture (USDA), Housing and Urban Development (HUD), and the Treasury. In our draft report, we made five recommendations to HUD. HUD provided written comments, which are reproduced in appendix II. HUD officials agreed with four of the recommendations and described some steps they have taken or plan to take to address them. HUD sought additional clarification on one of the recommendations. One draft recommendation was that HUD ensure that existing WCF policies and procedures are current and complete, consolidated in the WCF Handbook, and made easily accessible to customers and stakeholders. HUD officials agreed with this recommendation, and during their review of the draft report, they provided documentation to show that they had updated the WCF Handbook in line with our draft recommendation. Another draft recommendation was that HUD fully document all existing processes related to the management of the WCF’s unexpended balances and operating reserve. HUD officials also agreed with this recommendation, and provided documentation to show that they had established written processes in line with our draft recommendation. As such, we revised our final report to include both actions taken by HUD in February 2020 and to remove these two recommendations. In its written comments, HUD sought clarification on recommendation 1. On February 26, 2020, we spoke with HUD officials and clarified that the recommendation is more specifically targeted to the roles and responsibilities for identifying, monitoring, and implementing actions related to the business process analysis and efficiency efforts than the general guidance that HUD identified in its written comments. We added additional clarification to the report where appropriate. In addition to the written comments we received, USDA, HUD, and Treasury provided technical comments, which we incorporated as appropriate. We are sending copies of this report to the appropriate congressional committees; the Secretaries of USDA, HUD, and Treasury; and other interested parties. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov. If you or your staffs have questions about this report, please contact Tranchau (Kris) T. Nguyen at (202) 512-6806 or nguyentt@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 III. In addition to the above contact, Thomas J. McCabe (Assistant Director), Mackenzie D. Verniero (Analyst-in-Charge), Michael Alleyne, Jacqueline Chapin, Andrew J. Howard, Jason Marshall, Steven Putansu, and Alicia White made major contributions to this report. Ronald La Due Lake also contributed to this report.
Moving to shared services is one way agencies can operate more efficiently. WCFs provide a way to centralize and simplify the funding of shared services. HUD's WCF was established in 2016 to provide HUD offices services on a cost-reimbursable basis. The fund currently finances services from external federal shared service providers—the Departments of the Treasury (Treasury) and Agriculture (USDA). Congress included a provision for GAO to evaluate HUD's WCF. This report examines the extent to which HUD (1) delineated WCF roles and responsibilities and established performance measures, (2) established a transparent and equitable process to recover WCF costs, and (3) developed processes to obtain WCF customer feedback. GAO analyzed agency documentation of WCF management and financial and budget data, using its work on effective WCF management and unexpended balances as criteria. GAO interviewed HUD, Treasury, and USDA officials and conducted three focus groups with WCF customer offices. The Department of Housing and Urban Development's (HUD) Working Capital Fund (WCF) is a self-sustaining fund that collects fees from HUD customers to pay for services needed across the department. HUD's WCF finances human resource (HR) and financial management related services provided by external federal shared service providers. HUD defines most roles and responsibilities in its WCF handbook—the primary reference guide for WCF operations—and has established performance metrics. In addition, in response to GAO's review, HUD updated its handbook in February 2020 to include more current and complete information on existing WCF policies and procedures. However: HUD has not defined who is responsible for identifying and implementing opportunities for achieving efficiencies with service usage, including roles for the business process analyses it periodically conducts. HUD has not assessed the results of the business process analyses, or how those results could contribute to supporting efficient service delivery. Clearly defining WCF roles and assessing the results of its analyses can help HUD better manage the WCF and improve its ability to identify, monitor, and potentially realize cost savings and other efficiencies. GAO found that HUD has a process designed to equitably and transparently recover the WCF's costs for externally provided federal shared services. Prior to February 2020, it had not fully documented existing policies for managing the WCF's unexpended balances and operating reserves. However, HUD has since established its operating reserve policy that reflects all of the ways that the operating reserve can be used, such as to provide pricing stability to customers and ensure continuity of WCF activities in case of funding disruptions. Written documentation of such policies is essential to ensure that funds are managed appropriately and consistently over time. Finally, the WCF Committee has not conducted periodic reviews of shared services to help ensure effective management, strong performance, and customer satisfaction. Officials from both business line offices—the Office of the Chief Human Capital Officer (OCHCO) and Office of the Chief Financial Officer —stated that they use a variety of mechanisms to obtain customer feedback on services. However, WCF customers in two of three focus groups GAO held said that they have not been given opportunities to provide feedback on the overall quality of services they receive, and some participants shared specific concerns with HR services. Officials from OCHCO—the office that oversees HR services—told GAO they are aware of customer concerns, plan to take additional actions to obtain customer feedback, and acknowledged the need for periodic reviews called for in the WCF Committee Charter. Until such reviews are conducted to regularly assess customer satisfaction, HUD will likely lack a comprehensive understanding of the extent to which customer needs are being met and could be missing out on opportunities to improve the performance and management of services for which it pays. GAO is making three recommendations to HUD on its WCF: define roles for achieving efficiencies; assess results of its analyses; and conduct periodic reviews of business lines. HUD agreed with two and sought additional clarification on one. GAO clarified the recommendation based on further discussion with HUD.