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entitled 'Nonprofit Sector: Significant Federal Funds Reach the Sector 
through Various Mechanisms, but More Complete and Reliable Funding Data 
Are Needed' which was released on February 26, 2009.

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Report to the Chairman, Committee on the Budget, House of 
Representatives: 

United States Government Accountability Office: 
GAO: 

February 2009: 

Nonprofit Sector: 

Significant Federal Funds Reach the Sector through Various Mechanisms, 
but More Complete and Reliable Funding Data Are Needed: 

GAO-09-193: 

GAO Highlights: 

Highlights of GAO-09-193, a report to the Chairman, Committee on the 
Budget, House of Representatives. 

Why GAO Did This Study: 

Increasingly, the federal government relies on networks and 
partnerships to achieve its goals, and many of these involve nonprofit 
organizations. GAO was asked to assess (1) the mechanisms through which 
federal dollars flow to nonprofits and (2) what is known about federal 
dollars flowing through them to nonprofit organizations in fiscal year 
2006. To address these objectives, GAO conducted a literature review of 
funding; analyzed data from several sources, including the Federal 
Procurement Data System—Next Generation (FPDS-NG) and the Federal 
Awards and Assistance Data System (FAADS); and analyzed nonprofit 
organizations’ roles in 19 federal programs. 

What GAO Found: 

The federal government uses a variety of funding mechanisms to achieve 
national priorities through partnerships with nonprofit organizations, 
and the relationships are sometimes complex and multidirectional. 
Nonprofit organizations receive federal grant and contract funds both 
directly and through other entities, such as states, for performing 
activities or providing services to particular beneficiaries. Federal 
funds paid to nonprofit organizations as fees for services follow a 
somewhat more complex path. Credit through loan and loan guarantee 
mechanisms facilitate nonprofit organizations’ access to capital. 
Similarly, some tax policies result in benefits to nonprofit 
organizations by either reducing their costs or increasing their 
revenues. With direct federal grants and contracts, and with some loans 
and loan guarantees, federal agencies generally select the nonprofit 
participant, directly control the amount of funding provided, and 
monitor nonprofit performance. With other mechanisms, such as tax 
expenditures and fee-for-service programs, the federal government sets 
criteria for acceptable recipients but does not directly select or 
monitor nonprofit performance. 

Due to limitations and reliability concerns with tracking systems’ 
data, the data presently collected provide an incomplete, unreliable 
picture of the federal government’s funds reaching the nonprofit sector 
through various mechanisms, although they suggest these funds were 
significant. No central source tracks federal funds passed through an 
initial recipient, such as a state, and the nonprofit status of 
recipients was not reliably identified in FPDS-NG or FAADS. Factors 
contributing to data limitations include the nonprofit status of 
recipients being self-reported and no consistent definition of 
nonprofit across data systems. The development of a system to report 
funding through subawards, currently underway, may enable more complete 
estimates of funding to the sector in the future. However, until the 
accuracy of nonprofit status is improved, accurately determining the 
extent of federal funds reaching the sector is not possible, leaving 
policy makers without a clear understanding of the extent of funding 
to, and importance of, key partners in delivering federal programs and 
services. Funding data sources identified the following as the 
approximate amounts of federal funds flowing to nonprofits in 2006 
under different mechanisms, although most sources did not reliably 
classify nonprofit status of recipients: 

* $135 billion in fee-for-service payments under Medicare; 

* $10 billion in other types of fee-for-service payments; 

* $25 billion in grants paid directly to nonprofits; 

* $10 billion paid directly to nonprofits for contracts; and; 

* $55 billion in federal funds paid to nonprofits by states from two 
grant programs, including Medicaid. (GAO could not assess other 
programs.) 

In addition, approximately $2.5 billion in loan guarantees and $450 
million in loans were issued to nonprofits, and approximately $50 
billion in federal tax revenues were foregone due to tax expenditures 
related to nonprofits. 

What GAO Recommends: 

To ensure that accurate information on federal funding provided to 
nonprofit entities is available, GAO recommends that the Office of 
Management and Budget (OMB), which is responsible for a searchable Web 
site called USAspending.gov that includes federal assistance and 
contract awards, ensure that its funding information in USAspending.gov 
is categorized with a consistent definition of nonprofit organizations. 
OMB commented that while GAO’s recommendation would likely ensure more 
consistent data, it could be burdensome for states tracking subaward 
data. As USAspending.gov is developed, GAO believes this is an 
opportune time to explore ways to improve reliability of subaward data. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/products/GAO-09-193]. For more 
information, contact Stanley J. Czerwinski at (202) 512-6806 or 
czerwinskis@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Funding Mechanisms Are Varied and Relationships Can Be Complex: 

Data Limitations Leave Decision Makers without Complete Information on 
Funding to Nonprofit Organizations, Although Data Suggest That 
Significant Federal Funds Reached Nonprofit Organizations in 2006: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Detailed Scope and Methodology: 

Appendix II: Nonprofit Identification in Key Data Systems: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Amounts and Limitations of Data on 2006 Federal Funds 
Involving Nonprofit Organizations: 

Table 2: Revenue Loss Estimates for Select Tax Expenditures Affecting 
Nonprofit Organizations Reported for Fiscal Year 2006, with Budget 
Function: 

Table 3: Summary of Targeted Programs Discussed in the Report: 

Table 4: Estimated Reliability of Nonprofit Identification in Key Data 
Systems Based on Samples of Records: 

Abbreviations: 

ACF: Administration for Children and Families: 

APPS: Automated Plan Payment System: 

CCR: Central Contractor Registration: 

CMS: Centers for Medicare & Medicaid Services: 

DHS: Department of Homeland Security: 

DOD: Department of Defense: 

DOE: Department of Energy: 

DOL: Department of Labor: 

Education: Department of Education: 

ETA: Employment and Training Administration: 

FAADS: Federal Assistance Award Data System: 

FFATA: Federal Funding Accountability and Transparency Act of 2006: 

FNS: Food and Nutrition Service: 

FPDS-NG: Federal Procurement Data System--Next Generation: 

FSA: Office of Federal Student Aid: 

GSA: General Services Administration: 

HHS: Department of Health and Human Services: 

HPMS: Health Plan Management System: 

HUD: Department of Housing and Urban Development: 

IRS: Internal Revenue Service: 

NIH: National Institutes of Health: 

OMB: Office of Management and Budget: 

POS: Provider of Service: 

SCHIP: State Children's Health Insurance Program: 

Treasury: Department of the Treasury: 

USDA: Department of Agriculture: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

February 26, 2009: 

The Honorable John M. Spratt, Jr. 
Chairman: 
Committee on the Budget: 
House of Representatives: 

Dear Mr. Chairman: 

Increasingly, the federal government relies on networks and 
partnerships to achieve its goals, and many of these involve nonprofit 
organizations. These organizations are involved in a wide array of 
missions including healthcare, education, poverty alleviation, and 
economic development, and their missions can align with or complement 
the objectives of federal programs. Federal and nonprofit entities 
often partner with one another as they work toward the same or similar 
goals. The relationships are sometimes categorized and analyzed 
according to the various policy issues they address, but another useful 
analysis involves the funding relationships, particularly as they vary 
across different federal funding tools used to accomplish agencies' 
missions. These tools dictate how the relationships between federal 
agencies and nonprofit organizations operate, the roles that these 
entities and others (including other levels of government) play, and 
the degree of control, oversight, and influence that exists between the 
federal government and nonprofit organizations. 

To examine the extent and structure of the partnering between the 
federal government and the nonprofit sector, you asked us to focus on 
the funding relationships between the two sectors. Therefore, our 
objectives in this report are to provide information on (1) the 
mechanisms through which federal dollars flow to nonprofit 
organizations (which we define as those entities that are federally tax-
exempt), and how federal involvement varies across them, and (2) what 
is known about federal dollars flowing through these mechanisms to 
nonprofit organizations in fiscal year 2006 (the most recent year for 
which we could obtain data from all sources).[Footnote 1] 

To better understand how funds to nonprofit organizations are tracked 
and how mechanisms operate, we reviewed 19 federal programs selected to 
provide information on a variety of direct and indirect mechanisms and 
services across a variety of policy areas and sectors, and to include 
some of the more highly funded programs involving nonprofit 
organizations. The information obtained from this review is not 
generalizable to all programs involving nonprofit organizations. Our 
steps included reviewing previous related GAO reports and meeting with 
program officials. For each program, we analyzed the roles of nonprofit 
organizations and how federal involvement with and influence on these 
organizations varied across funding mechanisms. To assess federal 
funding reaching nonprofit organizations through various mechanisms, we 
conducted a literature review of funding to nonprofit organizations, 
assessed the suitability of various potential data sources, and 
analyzed data from several sources. Our data sources included the 
Federal Procurement Data System--Next Generation (FPDS-NG), Federal 
Awards and Assistance Data System (FAADS), several systems at the 
Centers for Medicare & Medicaid Services, the Department of the 
Treasury's (Treasury) estimates of the revenue loss of tax 
expenditures, and the Office of Management and Budget's (OMB) 
collection of information on federal credit programs. Although we did 
not validate all of the data provided by these sources, we took several 
steps to assess data quality. Overall, we determined that the data were 
sufficiently reliable for our engagement purposes. However, we 
identified significant reliability concerns regarding data from two 
systems, FPDS-NG and FAADS, which limit the precision of our estimates. 
We also reviewed research by others that provided perspective on the 
sector as a whole. A detailed description of our scope and methodology 
can be found in appendix I, and our findings on the reliability of 
nonprofit identification in key data systems are detailed in appendix 
II. 

We conducted this performance audit from January 2008 to February 2009 
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. 

Results in Brief: 

Federal agencies use a wide range of funding mechanisms in partnering 
with nonprofit organizations--defined in this report as federally tax- 
exempt entities--to carry out agencies' missions, and the relationships 
are sometimes complex and multidirectional. The most direct mechanisms 
are grants to, cooperative agreements with, and contracts for nonprofit 
organizations to provide particular services, such as research or 
services to particular beneficiaries. In fiscal year 2006, grants were 
provided to nonprofit organizations directly under almost 700 different 
programs. Federal grants and contracts may also reach nonprofit 
organizations by passing through levels of government as 
intermediaries, particularly with grant funds provided to states or 
other government levels that are often passed through to nonprofit 
organizations that provide services. Federal funds paid to nonprofit 
organizations as fees for services follow a somewhat more complex path, 
as exemplified by federal health insurance programs that reimburse 
nonprofit organizations for services they provide to individuals. 
Federal loans facilitate nonprofit organizations' access to capital by, 
for example, financing the construction of systems to improve electric 
service in rural areas. Further, other mechanisms, such as loan 
guarantees, while not directly providing federal funds to nonprofit 
organizations, increase access to other sources of funds for nonprofit 
organizations. For example, student loans, while provided to individual 
students, make funds available that result in revenues to nonprofit 
higher-education institutions. Similarly, some tax policies (known as 
"tax expenditures") result in benefits to some nonprofit organizations 
by either reducing their costs or increasing revenues. For example, 
they may be able to borrow funds at lower interest rates because of 
access to tax-exempt bond financing or may receive more contributions 
because the tax code provides an incentive for taxpayers to give. Each 
of these mechanisms provides the federal government with differing 
levels of influence and oversight over nonprofit selection and 
performance. With direct federal grants and contracts, and with some 
loans and loan guarantees, federal agencies generally select the 
nonprofit recipient, directly control the amount of funding provided, 
and generally monitor nonprofit performance. With other mechanisms, 
such as tax expenditures and fee-for-service programs, the federal 
government sets criteria for acceptable recipients but does not 
directly select or monitor nonprofit performance. 

Due to limitations and reliability concerns with tracking systems' 
data, the funding data presently available leave policy makers without 
a complete, accurate understanding of the amount of funding flowing to 
these key partners, although they suggest these funds were significant 
in fiscal year 2006. The federal government collects information on 
federal funding through several governmentwide and program-specific 
data systems. However, we identified significant limitations and 
reliability concerns with the data contained in these systems that led 
us to conclude that they provide an incomplete and unreliable picture 
of the federal government's funding to nonprofit organizations. For 
example, there is no central source that tracks federal funds that are 
passed through an initial recipient, such as a state, to a nonprofit 
subrecipient. In addition, the nonprofit status of recipients was not 
reliably identified in two key data systems. Several factors contribute 
to these data limitations. In particular, the nonprofit status of 
recipients is often self-reported and not always verified, and there is 
no consistent definition of a nonprofit across these systems. Some 
changes are currently underway that may enable more complete estimates 
of funding to nonprofit organizations in the future, including the 
development of USAspending.gov, a searchable Web site overseen by OMB 
that includes funding through subawards.[Footnote 2] However, until the 
accuracy of nonprofit status is improved, it will not be possible to 
accurately determine the extent of federal funds reaching the nonprofit 
sector, leaving policy makers without a precise understanding of the 
extent of funding to, and importance of, key partners in delivering 
federal programs and services. Despite these limitations, the sources 
identified the following approximate amounts of federal funds flowing 
to nonprofit organizations in fiscal year 2006 under different 
mechanisms: 

* about $145 billion in fee-for-service payments, mostly through 
Medicare; 

* approximately $25 billion in direct grants; 

* about $55 billion in grants that flow through states; and: 

* approximately $10 billion in contracts. 

These data suggest that federal funds represented a sizable portion of 
nonprofit organizations' total annual revenues, reported to be $1.6 
trillion.[Footnote 3] Additional funding was available related to other 
federal policies. Nonprofit organizations received about $450 million 
in outstanding direct loans and $2.5 billion in loans guaranteed by the 
federal government. Additionally, nonprofit organizations benefited 
from about $50 billion in tax expenditures. 

We are recommending that OMB take action to ensure that a consistent 
definition to categorize nonprofit organizations is identified and used 
in USAspending.gov. In commenting by e-mail on a draft of this report, 
OMB wrote that using the Central Contractor Registration (a database 
used to support agency procurement) would likely offer a consistent way 
to validate IRS tax-exempt status. It noted, however, the increased 
resource burden on states to ensure compliance of those receiving 
subawards with any requirement to register in such a system. We 
recognize this additional responsibility, but believe that this is the 
appropriate time for OMB to consider approaches that could be effective 
in improving the reliability of this information, given that the 
development of the subaward data portion of USAspending.gov is now 
underway. The Department of Housing and Urban Development concurred, by 
e-mail, with our findings and conclusions. The Departments of 
Agriculture, Education, Health and Human Services, and Labor did not 
provide formal comments. 

Background: 

The Nonprofit Sector: 

The nonprofit sector is diverse and has a significant presence in the 
U.S. economy.[Footnote 4] Of the estimated 1.8 million tax-exempt 
organizations in fiscal year 2007, about 63 percent were public 
charities or foundations that benefited the broad public interest, and 
were referred to as 501(c)(3) organizations,[Footnote 5] and about 8 
percent were social welfare organizations. Nonprofit organizations 
provide services in a wide variety of sectors, including policy areas 
such as health care, education, and human services. Approximately three-
quarters of the revenues of 501(c)(3) entities that filed IRS Form 990 
in 2005 were from entities within two subsectors. Public charities 
within the health subsector reported about $672.1 billion, or 
approximately 59 percent of the revenues reported, and nonprofit 
organizations within the education subsector reported about $188.2 
billion, or approximately 16 percent.[Footnote 6] 

While the majority of nonprofit organizations individually have 
relatively small operating budgets, as a whole the nonprofit sector has 
a significant presence in the U.S. economy, according to researchers of 
the nonprofit sector. In 2005, nonprofit organizations that submitted 
Form 990[Footnote 7] to the Internal Revenue Service (IRS) held an 
estimated $3.4 trillion in total assets and received $1.6 trillion in 
revenues.[Footnote 8] As we reported in 2007, in addition to 
representing a significant portion of the U.S. economy, the sector grew 
substantially from May 2000 to May 2006.[Footnote 9] Specifically, 
researchers indicated that the number of registered public charities, a 
large subset of all nonprofit organizations, grew over 30 percent from 
about 646,000 to about 851,000, although organizations that have gone 
out of existence may have been included in those numbers. In 2005, we 
reported that the nonprofit sector accounted for over 9.6 million 
employees in 2002, which was about 9 percent of the civilian 
workforce.[Footnote 10] 

As we have previously reported, the federal government is increasingly 
partnering with nonprofit organizations because nonprofits bring many 
strengths, such as flexibility to respond to needs and access to those 
needing services.[Footnote 11] Federal agency officials we spoke with 
reported that they may target nonprofit organizations when authorized 
by program regulations or when nonprofit organizations are the best 
source of a particular service, but they generally do not focus on the 
profit-making status of partners when distributing funding. For 
example, the Department of Labor is authorized by law to provide grants 
to public and nonprofit private organizations as part of its Senior 
Community Service Employment Program. Further, while the Department of 
Housing and Urban Development does not specifically target Emergency 
Shelter Grant Program funding to nonprofit organizations, a large 
portion of this funding reaches nonprofits because these organizations 
play a prominent role in delivering emergency shelter services for the 
homeless. 

Federal Funding Mechanisms: 

The federal government uses a variety of funding mechanisms to achieve 
national priorities through partnerships with nonfederal parties such 
as nonprofit organizations. Federal grants and cooperative agreements 
are forms of assistance authorized by statute in which a federal agency 
transfers something of value, such as money or property, to a party for 
a purpose, undertaking, or activity of the grantee that the government 
has chosen to assist.[Footnote 12] Federal contracts are mutually 
binding legal relationships obligating the seller, in this case the 
nonprofit entity, to furnish the supplies or services, and the buyer, 
in this case the government, to pay for them. The federal government 
typically uses contracts (rather than grants) as a mechanism when the 
principle purpose of the funded activity is to provide something for 
the direct benefit of the federal government. For example, contracts 
can be used to procure independent evaluations of programs, to conduct 
research for agency missions, or to buy information technology services 
for an agency. Federal credit and insurance programs, which include 
direct loans and loan guarantees, provide an alternative to direct 
spending and can fill market gaps when private lending and insurance 
companies cannot meet economic demands. Tax expenditures are reductions 
in tax liabilities that result from preferential provisions, such as 
exclusions, credits, and deductions. They result in revenue forgone by 
the federal government and create incentives for certain behaviors, 
such as making charitable donations to nonprofit organizations. Fee- 
for-service, or voucher-type, mechanisms provide funding to 
organizations through the ultimate recipient of services. For example, 
under a fee-for-service mechanism, physicians may receive payments for 
each service provided (such as an office visit). 

Several cross-governmental databases provide information on federal 
funding through the mechanisms described above. The Federal Assistance 
Award Data System (FAADS) provides financial data on grants and other 
forms of assistance that are made by the federal government, whereas 
the Federal Procurement Data System--Next Generation (FPDS-NG) collects 
federal procurement data. OMB is responsible for USAspending.gov, a Web 
site mandated by the Federal Funding Accountability and Transparency 
Act of 2006[Footnote 13] (FFATA) that establishes a single searchable 
location for financial information on grants, contracts, credit, and 
fee-for-service payments. Also, the IRS Form 990 provides detailed 
financial information on tax-exempt entities with annual gross receipts 
greater than $25,000. In addition, the Federal Audit Clearinghouse 
provides information on nonprofit organizations and other nonfederal 
entities that spend more than $500,000 a year in federal awards. 
[Footnote 14] Treasury's Office of Tax Analysis lists tax expenditures 
and estimates their cost, as reported by OMB in the President's Budget 
submission. 

Funding Mechanisms Are Varied and Relationships Can Be Complex: 

Federal agencies partnering with nonprofit organizations use several 
different funding mechanisms, and relationships between nonprofit 
organizations and federal agencies vary. The type of funding mechanism 
used determines the level of federal influence over nonprofit selection 
and oversight of performance. 

Grants and Contracts Provide Both Direct and Indirect Funds to 
Nonprofit Organizations: 

Nonprofit organizations sometimes work directly with federal agencies 
as grantees and contractors, in a relatively straightforward 
relationship. Our analysis of the 2006 data on federal funding to 
nonprofit organizations indicated that grants were provided to 
nonprofits directly under about 700 different programs. Types of 
activities funded through direct grants to nonprofit organizations 
included social services and research. For example: 

* The National Institutes of Health provide grants for extramural 
research to accomplish its mission related to public health needs. 
About 84 percent of its budget in fiscal year 2007 supported extramural 
research by researchers at various entities, including nonprofit higher-
education institutions, research institutes, and hospitals.[Footnote 
15] 

* The Administration for Children and Families in the Department of 
Health and Human Services provides Head Start grants to nonprofit as 
well as for-profit entities. Public and private nonprofit and for- 
profit agencies can receive direct grants to provide educational, 
health, nutritional, and other services to low-income children and 
families. 

* The Senior Community Service Employment Program, funded by the 
Department of Labor's Employment and Training Administration, provides 
grants to nonprofit organizations to provide subsidized, part-time work-
based training to older workers through employment in the community 
service sector. Under this program, nonprofit organizations can also be 
the beneficiary of this subsidized labor. 

Federal agencies also contract directly with nonprofit organizations to 
provide goods or services for the direct benefit of the federal 
government. Contracts are tracked in FPDS-NG, which we found to be 
somewhat unreliable in categorizing entities as nonprofit, although 
suitable for providing some order of magnitude. (See results of our 
reliability analysis in appendix II.) It showed that of the federal 
contracts provided to nonprofit organizations in fiscal year 2006, 
about two-thirds were awarded by the Department of Energy and the 
Department of Defense and about one-tenth by the Department of Health 
and Human Services. Even so, the percentage of dollars contracted to 
nonprofit organizations within these agencies is relatively small. For 
example, nonprofit contracts constituted only 1 percent of the 
Department of Defense's total 2006 contract dollars, while about 10 
percent of the Department of Health and Human Services' contract 
dollars were awarded to nonprofit organizations. Some programs contract 
with nonprofit organizations to help administer programs. For example, 
the Centers for Medicare & Medicaid Services contract with quality- 
improvement organizations, which can be nonprofit organizations, to 
monitor provider performance. 

Nonprofit organizations also receive grants indirectly through other 
levels of government, or as subgrantees of other grantees, and are 
sometimes subcontractors to other federal contractors. Some federal 
programs are set up as large grants to states, with the expectation 
that they will then be further disbursed for local program 
implementation, and nonprofit organizations are sometimes used for 
further service delivery. For example: 

* The Department of Health and Human Services' Administration for 
Children and Families oversees the Social Services Block Grant, 
providing funds to states to furnish social services to residents. 
Depending on the state, nonprofit organizations compete with other 
organizations for these funds to provide a wide range of social 
services, which can include daycare, protective services, adoption, 
case management, health-related services, and transportation. 

* Similarly, the U.S. Department of Agriculture's Food and Nutrition 
Service provides grants to state agencies under its Child and Adult 
Care Food Program. States reimburse institutions and organizations that 
provide nutritious meals and snacks to eligible children and adults 
enrolled for care at participating child and adult day care homes and 
centers, emergency shelters, and after-school care programs. Both the 
sites providing the nutrition service and the organizations that manage 
site operations, keep records, and submit claims are sometimes 
nonprofit organizations. 

Nonprofit organizations can also be subcontractors to other federal 
contractors. For example, a nonprofit university performing research 
under a federal contract could subcontract with another nonprofit 
university to complete a portion of the research where its researchers 
have a particular specialty. 

Nonprofit Organizations Obtain Federal Funds through Fees and Direct 
Payments for Services: 

Federal funds also reach nonprofit organizations through other more 
complex routes, such as through reimbursement for fees that they charge 
their clients. The Medicare program is a significant example of such a 
program. Individuals aged 65 and older as well as certain disabled 
individuals seek health care at various facilities, some of which are 
nonprofit hospitals, nursing facilities, and managed care 
organizations. The facility is then paid by the Medicare program. 

Other programs involving direct payments for services in which 
nonprofit organizations can be recipients include voucher programs. 
These allow the beneficiary of a program to choose the source of 
services, while the services are paid by the program. The Pell Grant 
program, for example, operates under this principle. It provides need- 
based grants to low-income students to promote access to postsecondary 
education. Students may use their grants at any of about 5,400 
participating postsecondary institutions, many of which are nonprofit. 
In these cases, the nonprofit institution acts as an intermediary 
between the student and the Department of Education. 

Nonprofit Organizations Provided Access to Additional Funds through 
Federal Loans and Loan Guarantees: 

Nonprofit organizations are involved in credit relationships with the 
federal government, in some cases as the recipient of funds loaned or 
guaranteed by federal agencies, and in some cases as the guaranty 
agency. In general, the federal government loans money and guarantees 
others' loans as a way of increasing the availability of funding for 
borrowers or activities it considers important. The Rural Development 
Electric Program, operated by the U.S. Department of Agriculture's 
Rural Development, Utilities Programs, is an example of a program where 
loans and loan guarantees are provided directly, in this case to 
electric utilities to serve customers in rural areas.[Footnote 16] The 
loans and loan guarantees help finance the construction of electric 
distribution, transmission, and generation facilities; system 
improvements; and other activities, including energy conservation 
programs. In this program, nonprofit organizations can also be 
intermediaries, issuing loans that are guaranteed by the federal 
government. 

Similarly, the Hospital Mortgage Insurance Program, implemented by the 
Department of Housing and Urban Development's Federal Housing 
Administration, operates a loan guaranty program that insures loans. 
These federally guaranteed loans finance the construction, 
modernization, equipping, or refinancing of acute-care hospitals. The 
program facilitates affordable financing of nonprofit, for-profit, and 
government-owned hospitals by protecting lenders against losses they 
might incur if hospitals fail to make their mortgage payments. The 
program generally targets hospitals deemed too risky to obtain private 
bond insurance but able to pass certain agency underwriting tests. In 
addition, the program serves as a credit enhancement and improves the 
credit rating of the hospital, resulting in a lower interest rate for 
the loan. 

Finally, some federal programs use loans and loan guarantees to 
encourage activities that indirectly result in increased revenues to 
nonprofit organizations. For example, within student loan programs, the 
federal government both guarantees loans and provides loans directly to 
students for postsecondary education, often at nonprofit institutions. 
The various loans available within the Federal Family Education Loan 
Program are set up to provide incentives to lenders (such as banks, 
credit unions, and savings and loan associations) to make loans to 
students enrolled at eligible postsecondary institutions. Guaranty 
agencies, which are state or nonprofit organizations, administer 
several portions of the program by providing technical assistance and 
training to schools and lenders on procedures, providing counseling to 
borrowers, reimbursing lenders with federal funds when borrowers 
default on their loans, and initiating collections. Conversely, with 
the Federal Direct Student Loan program, the federal government 
provides loans directly to vocational, undergraduate, and graduate 
postsecondary school students and their parents, rather than through 
private lenders. In both cases, nonprofit higher-education institutions 
benefit from the availability of funds. 

Nonprofit Organizations Benefit from Federal Tax Policies: 

Federal tax policies provide significant financial benefits to 
nonprofit organizations while resulting in revenue forgone by the 
federal government. Unlike some of the other mechanisms discussed 
above, they do not provide federal funds but rather either reduce taxes 
needing to be paid, reduce other costs, or increase revenues. 
Classification as section 501(c) type organizations provides these 
entities exemption from paying federal income tax.[Footnote 17] 
Further, certain types of organizations are specifically exempted from 
paying income taxes; for example, credit union income is exempt from 
income taxes. 

Nonprofit organizations also benefit indirectly from tax expenditures 
that are aimed at encouraging certain kinds of behavior by taxpayers 
when those behaviors involve nonprofits.[Footnote 18] For example, tax 
expenditures encourage charitable giving, stimulate economic 
development in disadvantaged areas, finance postsecondary education, 
and encourage adequate healthcare coverage. In some cases, these 
behaviors primarily involve nonprofit organizations, such as with 
charitable contributions.[Footnote 19] In other cases, nonprofit 
organizations are significant providers of services being targeted, 
although these services are also provided by for-profit and government- 
operated entities. For example, individuals deducting education and 
health care expenses could incur those expenses at all three types of 
entities. 

Some tax expenditures have more complex interrelationships between 
nonprofit organizations and governmental units. For example, tax-exempt 
bonds are used to finance the construction of facilities used by 
501(c)(3) organizations. These bonds are issued by state and local 
governments. Interest income from these bonds is exempt from federal 
income tax, the alternative minimum tax, and, in general, state income 
taxes. The tax exemption lowers the bond issuer's borrowing costs as 
investors require lower returns than they otherwise would. In addition, 
state and local governments can create other entities, including 
nonprofit entities to issue bonds on behalf of a governmental unit. 
Similarly, the low-income housing tax credit also involves multiple 
parties. Nonprofit and other types of developers of low-income rental 
housing receive the federal tax credits from state agencies to develop 
or rehabilitate low-income housing. Developers then sell these credits 
to investors to raise capital (or equity) for their projects, which 
reduces the debt that the developer would otherwise have to borrow. In 
addition, a few large nonprofit organizations also provide technical 
assistance to nonprofit developers and serve as intermediaries for 
facilitating the sale of tax credits to investors. 

Type of Funding Mechanism Generally Determines the Level of Oversight 
and Influence That Federal Agencies Have over Nonprofit Organizations: 

The amount of federal involvement in selecting and overseeing nonprofit 
performance varies across funding mechanisms. With some funding 
mechanisms, federal agencies generally select nonprofit recipients, 
determine how much funding nonprofit organizations will receive, and 
monitor nonprofit performance. With direct contracts and grants, 
agencies select nonprofit organizations by soliciting requests for 
proposals and holding open competitions. The National Institutes of 
Health, for example, competitively awards grants by using a system of 
peer review that assesses applications on scientific merit and agency 
funding priorities. Also, with direct contracts and grants, federal 
agencies evaluate nonprofit performance and can under certain 
circumstances choose to terminate contracts or may choose not to renew 
contracts and grants when nonprofit organizations perform poorly. For 
example, in the Head Start Program, the Administration for Children and 
Families conducts on-site monitoring reviews of grantee programs every 
3 years and administers an extensive annual survey of grantees to 
evaluate performance. If a nonprofit grantee is not meeting program 
requirements, the agency has authority to remove the grantee from the 
program. With some credit programs, federal agencies also select 
nonprofit organizations and monitor performance, but their opportunity 
to evaluate performance occurs before they provide funding to the 
nonprofit. The Department of Housing and Urban Development, for 
example, uses a variety of financial criteria to determine nonprofit 
organizations' future performance before providing hospital mortgage 
insurance to hospitals. After it has awarded insurance to a hospital, 
the department monitors a hospital's performance while using the loan 
and can require poorly performing hospitals to hire consultants to 
improve performance. 

In programs using other funding mechanisms, the federal agency sets 
eligibility standards for nonprofit recipients but relies on other 
government entities to select nonprofit organizations and monitor 
performance. For example, with indirect grant programs such as the 
Social Services Block Grant, the federal government provides funding to 
states, which have broad discretion to determine the services provided, 
define individual beneficiary requirements, and allocate funding to 
recipients.[Footnote 20] While the federal agency does not monitor the 
performance of individual nonprofit and other recipients receiving this 
grant funding, states are required to monitor the performance of 
nonprofit recipients. With fee-for-service programs such as Medicare, 
states determine service provider eligibility, but individuals choose 
their providers. While the federal agency has overall responsibility 
for administering Medicare, state agencies--typically state health 
departments--monitor, survey, and inspect health care service 
providers.[Footnote 21] Additionally, some tax expenditure programs, 
such as the low-income housing tax credit, leverage state or local 
governments to select or monitor nonprofit performance, or both. With 
the low-income housing tax credit, nonprofit developers compete for the 
credits, and states allocate them based on broad federal guidelines. 
While the IRS issues regulations for the program, it relies on state 
authorities to monitor and certify which projects remain eligible to 
receive tax credits. The IRS may then recapture taken credits or deny 
issuance of further credits for reported noncompliance with low-income 
housing tax credit laws. 

In other programs, individuals select nonprofit organizations, and 
federal oversight of nonprofit performance is limited. With student 
loan programs, for example, the Department of Education determines 
institutions' eligibility to participate in the programs, while the 
institutions' funding is dependent on the number of students that 
choose to matriculate and the financial need of those students. The 
Department of Education monitors the performance of nonprofit 
postsecondary institutions through reviewing their default rates, which 
measures the extent students are defaulting on their loans, and 
performing periodic program reviews. Further, with charitable 
deductions, agencies do not select nonprofit organizations or monitor 
nonprofits' performance. Instead, individuals providing contributions 
determine which nonprofit will receive funding, and the IRS's role is 
limited to determining 501(c)(3) eligibility, monitoring certain filing 
requirements, and revoking section 501(c)(3) status. While the IRS may 
revoke the 501(c)(3) status of nonprofit organizations in certain 
circumstances, it does not assess whether nonprofit organizations use 
the revenues from charitable contributions to meet the goals of the 
contribution, although some information is publicly available to 
individuals. 

Data Limitations Leave Decision Makers without Complete Information on 
Funding to Nonprofit Organizations, Although Data Suggest That 
Significant Federal Funds Reached Nonprofit Organizations in 2006: 

The federal government tracks and provides information on funding in 
order to provide decision makers and the public with accurate 
information on the sources and uses of federal funds, among other 
reasons. The Federal Managers' Financial Integrity Act of 1982 requires 
that agencies establish controls to ensure that expenditures applicable 
to agency operations are properly recorded and accounted for to permit 
the preparation of accounts and reliable financial and statistical 
reports.[Footnote 22] In fulfilling this responsibility, federal 
agencies collect a range of information on funding mechanisms and 
recipients, and this information is consolidated and reported to a few 
governmentwide data systems that consolidate data across most of the 
federal government. With the development of USAspending.gov--a publicly 
available Web site of federal spending, mandated by the FFATA, that 
provides information on entities awarded federal grants, loans, 
contracts, and other forms of federal assistance--such data are readily 
available to the public. In addition, in conjunction with performance 
data, this information can be used as a tool for reexamining federal 
roles and the efficiency and effectiveness of various mechanisms and 
partners in the pursuit of federal objectives. These data are also used 
as inputs for the development of economic analyses such as the 
Consolidated Federal Funds Report, which analysts use to measure and 
assess federal expenditures in state and substate areas. 

Data Limitations and Reliability Concerns Contribute to an Incomplete 
and Unreliable Picture of Federal Funding: 

The data presently collected provide an incomplete and, for portions, 
unreliable picture of federal funding to nonprofit organizations. 
First, information on funding reaching nonprofit organizations through 
indirect mechanisms is generally not available, though we present some 
estimates for some programs in table 1. Therefore, we cannot conduct a 
comprehensive assessment of how much federal money reaches nonprofit 
organizations through subcontracts, subgrants, or through fee-for- 
service payments to for-profit enterprises that are subsequently spent 
on nonprofit organizations or through other mechanisms. Nonprofit 
organizations may receive considerable funding through indirect 
mechanisms, in particular through indirect grants to state and local 
governments. According to OMB, federal grant outlays to state and local 
governments amounted to $434 billion in 2006, and one study estimated 
that about 26 percent of such funds reached nonprofit organizations in 
fiscal year 2001.[Footnote 23] 

Second, nonprofit entities are not reliably identified, which limits 
the reliability and completeness of reported funding amounts in two key 
data systems, FPDS-NG and FAADS. These systems are the only 
governmentwide systems for obtaining detailed information on federal 
procurement and assistance, and their data are used to populate 
USAspending.gov. However, in developing the funding information 
outlined above, we found that nonprofit organizations are not reliably 
identified in either of these systems. For example, based on our 
testing of a sample of records, we estimate that 8 percent of the 
records in FAADS coded as nonprofit organizations are actually other 
entity types, and that 5 percent of records coded as other entities are 
actually nonprofits. (See appendix II for further details on our 
approach and results of reliability testing.) Similarly, 27 percent of 
the vendors in FPDS-NG with nonprofit contract actions also had 
contract actions where they were classified as not being nonprofit 
organizations. This represents 1,768 vendors, who constituted a 
majority of reported nonprofit obligations ($8 billion of $12 billion 
total). 

We have previously reported concerns about the accuracy and 
completeness of data in FPDS-NG and FAADS.[Footnote 24] For example, we 
reported in February 2006 that data submitted for inclusion in FAADS on 
financial assistance awards related to economic development were often 
inaccurate and incomplete.[Footnote 25] During the course of our 
current review we identified one program that FAADS data indicated 
provided almost $1 billion to nonprofit organizations. However, program 
officials told us that the program only provided a total of around $150 
million to all recipients. According to OMB, figures in FAADS and FPDS- 
NG have, in the past, been incomplete, untimely, and inaccurate. For 
example, agencies have reported loan guarantee amounts only when a 
default occurs. 

In addition to these overall concerns about the reliability and 
integrity of the databases, several ways in which the data are captured 
and stored prevented us from distinguishing funding to nonprofit 
organizations from funding to other groups. For example: 

* Nonprofit institutions of higher education in FAADS are classified 
along with other private higher-education institutions. Based on a 
sample of these records, we estimate that 95 percent of the records in 
this category were actually nonprofit organizations. (See appendix II 
for further details.) 

* Similarly, tax expenditure estimates in various areas include 
benefits to nonprofit as well as other entities. For example, though 
Treasury estimates that the low-income housing tax credit cost the 
federal government $4.4 billion in 2006 in forgone revenues, the 
portion of that total that is related to projects developed by 
nonprofit organizations is not systematically assessed. 

Limitations and Reliability Concerns Caused by Various Factors: 

Limitations in the data presently collected may be caused by several 
factors including a reliance on data that are not verified and a lack 
of clear guidance defining a "nonprofit" organization. Agency officials 
told us that the nonprofit status of organizations can be self-reported 
by recipients or entered by agency officials and not verified in most 
data systems we examined including FPDS-NG, FAADS, and Medicare's 
Health Plan Management System (HPMS) which provides information on 
Medicare managed care and prescription drug plan payments. Furthermore, 
there is no consistent, governmentwide definition of "nonprofit." 
Guidance for registrants in the Central Contractor Registration, which 
agencies may use to identify the nonprofit status of entities for 
federal assistance and contracts in FAADS, FPDS-NG, and 
USAspending.gov, asks registrants simply to identify whether they are 
"for profit", "non profit", or "other not for profit."[Footnote 26] 
Similarly, HPMS provides no guidance for recipients. These concerns are 
not new, as we have previously reported that data in FPDS-NG and FAADS 
can be improved. For example, we have recommended automating data 
checks and improving knowledge among program officials about reporting 
requirements.[Footnote 27] 

Efforts to Improve Data Collection May Improve Information on Federal 
Funding to Nonprofit Organizations, Though Concerns Will Likely Remain: 

Efforts are underway to improve the funding data collected by the 
federal government and may, if appropriately implemented, provide 
further and more accurate information on federal funding to nonprofit 
organizations. In March 2008, OMB issued a memo with new guidelines, 
emphasizing the need to report timely, accurate, and complete data for 
FAADS and FPDS-NG, as prescribed by the Federal Funding Accountability 
and Transparency Act of 2006 (FFATA). The act, and OMB's efforts to 
implement it, may improve data collected on grants, contracts, credit, 
and fee-for-service payments. First, the act requires data on subawards 
such as subcontracts and subgrants to be collected and reported. These 
indirect mechanisms are likely to be a major way nonprofit 
organizations receive federal assistance and this will represent the 
first time data will be collected to address it. Second, the act 
requires the use of unique identifiers for entities receiving certain 
types of federal assistance. It is currently very difficult to assess 
the nonprofit status of a single recipient across federal funding 
databases or over time because these databases do not have a unique 
entity identifier. Having unique identifiers could facilitate agency 
and outside analysts' verification and tracking of nonprofit 
organizations and their status and therefore could facilitate the 
identification of errors and improve the data. Third, recognizing that 
data in the past have been incomplete, untimely, and inaccurate, OMB 
has issued guidance for agency data submissions under FFATA that 
specifies more exactly how agencies are to report credit assistance 
(loans and loan guarantees) and requires agencies to ensure that they 
provide appropriate oversight for the accuracy of data and validate all 
data submissions. If appropriately pursued, such validation could 
encourage agencies to implement policies and processes to improve the 
quality of data they submit to federal funding sites. 

Officials from the General Services Administration (GSA) and OMB 
indicated they have considered an approach to verify the nonprofit 
status of nonprofit organizations receiving grants. A GSA official 
indicated that GSA is considering using the Central Contractor 
Registration (CCR)[Footnote 28] to validate information on these 
recipients' nonprofit status. While using the CCR to verify nonprofit 
status presents challenges, such as there being no central registry for 
state nonprofit designations and having a time lag with data from IRS's 
publicly available master file of federally tax-exempt organizations, 
an OMB official noted that this is potentially a source for validating 
nonprofit status. 

Data Sources Suggest Significant Federal Funds Reach Nonprofit 
Organizations: 

Our analysis of data presently collected suggests that significant 
federal funds reached nonprofit organizations in 2006, as shown in 
table 1. Although we identified a number of data limitations and 
reliability concerns with several key data sources as discussed above, 
we nevertheless found the data overall to be sufficiently reliable to 
provide an approximate indication of the general magnitude of federal 
assistance across these mechanisms. Available data, and our estimates 
based on these sources, suggest that federal funding made up a 
significant portion of nonprofit organizations' total revenues. The 
Urban Institute estimated that nonprofit organizations that submitted 
Forms 990 to the IRS received $1.6 trillion in revenues in 2005. (See 
appendix I for specific information on data sources and analysis.) 

Table 1: Amounts and Limitations of Data on 2006 Federal Funds 
Involving Nonprofit Organizations: 

Mechanism: Federal funds provided: Fee-for-service and vouchers; 
Approximate amount of total funds to nonprofits: $135 billion through 
Medicare; 
Data source: Centers for Medicare & Medicaid Services (CMS) Automated 
Plan Payment System, Health Plan Management System, Provider of 
Services files, and Health Care Information System; 
Limitations and data reliability concerns: Includes payments to some 
Blue Cross/Blue Shield plans that are not nonprofits. 

Mechanism: Federal funds provided: Fee-for-service and vouchers; 
Approximate amount of total funds to nonprofits: $10 billion in 
additional payments to nonprofits; 
Data source: Federal Award and Assistance Data System (FAADS); 
Limitations and data reliability concerns: Nonprofit status not 
reliable, funding amounts potentially unreliable and incomplete. 

Mechanism: Federal funds provided: Direct grants; 
Approximate amount of total funds to nonprofits: $25 billion; 
Data source: FAADS; 
Limitations and data reliability concerns: Nonprofit status not 
reliable, funding amounts potentially unreliable and incomplete. 

Mechanism: Federal funds provided: Contracts; 
Approximate amount of total funds to nonprofits: $10 billion; 
Data source: Federal Procurement Data System--Next Generation (FPDS-
NG); 
Limitations and data reliability concerns: Nonprofit status not 
reliable, funding amounts potentially unreliable and incomplete. 

Mechanism: Federal funds provided: Indirect grants and contracts; 
Approximate amount of total funds to nonprofits: $55 billion from 
Medicaid and State Children's Health Insurance Program (SCHIP) reached 
nonprofits; 
Data source: CMS Financial Management Report; 
Limitations and data reliability concerns: Estimate based on limited 
program data. 

Mechanism: Additional funds available due to federal policies: Credit 
(loans and loan guarantees); 
Approximate amount of total funds to nonprofits: $450 million in direct 
loans and $2.5 billion in loan guarantees; 
Data source: FAADS; 
Limitations and data reliability concerns: Amounts may not be 
consistently captured, nonprofit status not reliable, funding amount 
potentially unreliable and incomplete. 

Mechanism: Additional funds available due to federal policies: Tax 
expenditures (federal revenues forgone); 
Approximate amount of total funds to nonprofits: $50 billion 
specifically related to nonprofits and additional funds for activities 
that involve nonprofit as well as other entities; 
Data source: OMB, Analytical Perspectives, Budget of the United States 
Government, Fiscal Year 2008; 
Limitations and data reliability concerns: Unclear how much of the 
value of these tax expenditures reach nonprofits. 

Source: GAO analysis of data sources outlined above. 

Note: Amounts are for fiscal year 2006 except for Medicare and tax 
expenditures, which are for calendar year 2006. Tax expenditures and 
credit amounts are not directly comparable to other funding amounts. 
Also, we rounded our estimates to the nearest 5 billion. Additional 
information on the methods used to calculate these amounts are found in 
appendix I. 

[End of table] 

* Fee-for-Service and Vouchers--Data from the Medicare program and the 
Federal Award and Assistance Data System (FAADS) indicate that federal 
fee-for-service or voucher programs provided nonprofit organizations 
with about $145 billion in 2006.[Footnote 29] Medicare was the largest 
source of such funds, having paid nonprofit health care providers and 
managed care plans about $135 billion in calendar year 2006.[Footnote 
30] Other fee-for-service or voucher programs, such as federal Pell 
Grants and the Federal Work-Study program, obligated about $10 billion 
to nonprofit organizations in 2006. Together, these data suggest that 
nonprofit organizations received about one-third of total federal fee- 
for-service funding. 

* Direct Grants--A large number of direct grant programs provided about 
$25 billion to nonprofit organizations in 2006, about 5 percent of 
total grant funding. 

* Contracts--About $10 billion was obligated in actions with nonprofit 
organizations, representing less than 3 percent of total contract 
obligations in 2006. 

* Indirect Grants--Comprehensive data on grant funds that indirectly 
reach nonprofit subrecipients are not available. We examined two 
specific programs that make up a large portion of total funding to 
states, Medicaid and the State Children's Health Insurance Program 
(SCHIP), and estimate that around $55 billion was passed on by states 
to nonprofit organizations based on program-reported expenditures and 
the share of nonprofit organizations in the health care sector overall. 
There are a number of other programs for which federal funds flow 
through states to nonprofit organizations but we did not attempt to 
estimate that funding. We did attempt to identify information on 
federal funds flowing through the three states that, according to 
FAADS, received the highest amount of federal financial assistance-- 
California, New York, and Texas. However, state officials indicated 
that none of these states collected data across agencies on federal 
funding provided to nonprofit organizations, although we did identify 
some individual state agencies that maintained these data. For example, 
the Texas Department of State Health Services' records indicated that 
over $280 million in federal funds were encumbered on active contracts 
with nonprofit organizations during the state's fiscal year 2007. Since 
we were unable to comprehensively assess such funding to nonprofit 
organizations, we believe that total funding to nonprofits through 
indirect grants was likely more than $55 billion in 2006. 

* Indirect Contracts--We did not identify any information on which to 
assess the funding nonprofit organizations received indirectly through 
other contractors. 

Further, some federal policies result in additional funds being 
available to nonprofit organizations. 

* Credit--Available data from FAADS indicates that about $450 million 
in direct loans and $2.5 billion in loan guarantees were issued 
directly to nonprofit organizations in 2006, though OMB has raised 
concerns with how some of these data are reported.[Footnote 31] For 
example, we found that these data do not include one of the largest 
federal credit programs, the Federal Family Education Loan program. 
Based on data from OMB, we estimate that in 2006, the federal 
government had about $120 billion in outstanding loans or guarantees 
involving nonprofit organizations through four key credit programs. 
This includes our estimate of student loans that were used at nonprofit 
institutions of higher education.[Footnote 32] Based on OMB's estimates 
of the future costs to the federal government of these credit programs, 
the future costs of credit involving nonprofit organizations is likely 
to be about $15 billion.[Footnote 33] 

* Tax Policies and Tax Expenditures--Though more difficult to assess 
and not directly comparable to funding through other mechanisms, 
federal tax policies provide significant financial benefits to 
nonprofit organizations. As described above, federal tax policy 
benefits nonprofit organizations by (1) exempting nonprofits from 
having to pay federal income taxes on activities substantially related 
to the purpose that led to the nonprofits' tax exemption, and (2) 
through specific tax expenditures, or tax provisions that grant special 
tax relief for certain behaviors by taxpayers or for taxpayers in 
special circumstances. Researchers have estimated the amount of revenue 
the federal government may forgo by not taxing nonprofit income, and 
the Treasury's Office of Tax Analysis annually compiles a list of tax 
expenditures and estimates of their cost.[Footnote 34] There has been 
no comprehensive research on the revenue lost from not taxing nonprofit 
organizations, although existing research offers estimates for specific 
portions of the nonprofit sector. One study estimated that the value of 
the federal and state income tax exemption for charitable nonprofit 
organizations was about $10 billion in 2002.[Footnote 35] In 2005, the 
Joint Committee on Taxation estimated that taxing large credit unions 
similarly to the way that other thrift institutions are taxed would 
raise $6.5 billion between 2006 and 2010. However, in their assessment 
of the consequences of taxing nonprofit organizations more broadly, the 
Congressional Budget Office found that taxing nonprofits would likely 
yield less tax revenues than their size and share of economic activity 
might suggest because nonprofits were likely to reduce their taxable 
income by lowering prices and increasing compensation and other costs. 
[Footnote 36] 

Various specific tax expenditures also benefit nonprofit organizations. 
Table 2 presents five tax expenditures that involve nonprofit 
organizations and which Treasury estimated to represent $49 billion in 
forgone revenue in 2006, primarily through the deductibility of 
charitable contributions.[Footnote 37] The deductibility of charitable 
contributions creates an incentive for corporations and individuals to 
provide support for charitable activities, and the availability of tax- 
exempt bond financing can enable certain nonprofit organizations to 
borrow funds at lower interest rates. Other tax expenditures indirectly 
benefit nonprofit organizations by increasing the demand for services 
provided by nonprofits as well as other entities. For example, the 
exclusion of employer contributions for health care insurance and 
various education-related tax expenditures are aimed at broad health 
and education objectives and not particularly targeted at nonprofit 
provision of those services. However, since nonprofit organizations 
provide a large portion of health care and educational services to the 
nation, some of the value of these tax expenditures reaches nonprofits. 

Table 2: Revenue Loss Estimates for Select Tax Expenditures Affecting 
Nonprofit Organizations Reported for Fiscal Year 2006, with Budget 
Function: 

Tax expenditure: Tax expenditures involving nonprofits: Deductibility 
of charitable contributions, other than education and health[A]; 
Revenue loss estimate (dollars in billions): $37.1; 
Budget function: Training, employment and social services. 

Tax expenditure: Tax expenditures involving nonprofits: Deductibility 
of charitable contributions (education); 
Revenue loss estimate (dollars in billions): $4.2; 
Budget function: Education. 

Tax expenditure: Tax expenditures involving nonprofits: Deductibility 
of charitable contributions (health); 
Revenue loss estimate (dollars in billions): $4.2; 
Budget function: Health. 

Tax expenditure: Tax expenditures involving nonprofits: Exclusion of 
interest on bonds for private nonprofit educational facilities; 
Revenue loss estimate (dollars in billions): $2.1; 
Budget function: Education. 

Tax expenditure: Tax expenditures involving nonprofits: Exemption of 
credit union income; 
Revenue loss estimate (dollars in billions): $1.3; 
Budget function: Financial institutions and insurance. 

Tax expenditure: Total; 
Revenue loss estimate (dollars in billions): $48.9. 

Tax expenditure: Examples of tax expenditures involving nonprofits as 
well as others: Exclusion of employer contributions for medical 
insurance premiums and medical care; 
Revenue loss estimate (dollars in billions): $125; 
Budget function: Health. 

Tax expenditure: Examples of tax expenditures involving nonprofits as 
well as others: Credit for low-income housing investments; 
Revenue loss estimate (dollars in billions): $4.4; 
Budget function: Housing. 

Tax expenditure: Examples of tax expenditures involving nonprofits as 
well as others: HOPE tax credit; 
Revenue loss estimate (dollars in billions): $3.9; 
Budget function: Education. 

Tax expenditure: Examples of tax expenditures involving nonprofits as 
well as others: Exclusion of interest on hospital construction bonds; 
Revenue loss estimate (dollars in billions): $3.4; 
Budget function: Health. 

Tax expenditure: Examples of tax expenditures involving nonprofits as 
well as others: Lifetime learning tax credit; 
Revenue loss estimate (dollars in billions): $2.5; 
Budget function: Education. 

Tax expenditure: Examples of tax expenditures involving nonprofits as 
well as others: Empowerment zones and renewal communities; 
Revenue loss estimate (dollars in billions): $1.2; 
Budget function: Community and regional development. 

Tax expenditure: Examples of tax expenditures involving nonprofits as 
well as others: Various other education-related tax expenditures[B]; 
Revenue loss estimate (dollars in billions): $3.4; 
Budget function: Education. 

Tax expenditure: Examples of tax expenditures involving nonprofits as 
well as others: Various other health-related tax expenditures[C]; 
Revenue loss estimate (dollars in billions): $8.0; 
Budget function: Health. 

Source: GAO analysis of OMB data. 

Notes: Data are from Analytical Perspectives, Budget of the United 
States Government, Fiscal Year 2008. From year to year, revenue loss 
estimates may change because Treasury updates its estimates for each 
new budget to reflect legislation enacted, prevailing economic 
conditions, and the latest taxpayer data available. Although there are 
substantial revenues forgone for these tax expenditures, the estimated 
amount of federal spending that would be required to provide equivalent 
assistance is frequently larger than the revenue forgone because this 
spending could be subject to income tax. For example, the so-called 
"outlay equivalent" estimate for the income tax exclusion of employer 
contributions for medical insurance premiums and medical care is $126.7 
billion for fiscal year 2004. 

[A] Some charitable deductions may also reach federal, state, and local 
governments. 

[B] Includes education individual retirement accounts, deductibility of 
student-loan interest, deduction for higher education expenses, state 
prepaid tuition plans, and the exclusion of interest on student-loan 
bonds. 

[C] Includes self-employed medical insurance premiums, Medical Savings 
Accounts/Health Savings Accounts, and the deductibility of medical 
expenses. 

[End of table] 

Conclusions: 

The federal government interacts with nonprofit organizations and a 
wide range of other partners to accomplish mutual goals--providing 
health care, ensuring that youth are educated, providing job training, 
increasing the supply of low-income housing, and many other goals. Much 
of this interaction is tied to federal funding available to nonprofit 
and other recipients, or funding made available as a result of federal 
policies. The available data indicate that these sources represent a 
significant portion of the nonprofit organizations' total revenues. 
Such funds come in many forms, each with varying ways in which the 
federal government is able to monitor and influence recipients' 
performance. As a result, the federal government's ability to influence 
which nonprofit organizations are involved and the quality of their 
services varies, and the involvement of other parties--states, local 
government, and individual contributors--varies. 

The significant extent and diversity of the federal government's 
partnering with the nonprofit sector should be better understood, but 
this opportunity is being missed, in part, because of the absence of 
complete and accurate data on federal funding reaching recipients of 
different types. Although available data indicate that significant 
federal funding reaches the nonprofit sector, the precise extent of 
that funding is not known because of data limitations. As a result, the 
extent of the federal government's dependence on various sectors for 
delivering services also is unknown. 

Some efforts are underway to improve information on the funding 
reaching nonprofit organizations and other types of organizations. One 
of the areas that is hard to measure is the funding reaching nonprofit 
organizations through indirect grants and contracts. The changes in 
FFATA should improve the availability of this information. However, as 
we found in reviewing data collected by agencies, there are concerns 
about the quality of those data, particularly the type of entity, a 
data element that is critical to accurately understanding the amount of 
federal funding reaching nonprofit organizations. We have reported our 
concerns on the quality of the data and recommended improvements in the 
past, but this additional problem--that nonprofit status is sometimes 
incorrect and defined differently across the federal funding data--has 
additional implications. It prevents the federal government from 
accurately assessing the extent to which it uses this sector and the 
potential effect of the sector's strength as a key partner in 
delivering federal services. 

Recommendation for Executive Action: 

To better ensure the accuracy of information on federal funding 
provided to nonprofit entities in the data available under FFATA, we 
recommend that the Director, OMB, ensure that a consistent definition 
is identified and used to categorize nonprofit organizations in 
USAspending.gov. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to OMB and the Departments of 
Agriculture, Education, Health and Human Services, Housing and Urban 
Development, and Labor. OMB responded in an e-mail that the use of CCR 
would likely offer a consistent method of validating the Internal 
Revenue Service tax-exempt status of nonprofit recipients at the prime 
level and at lower tiers. However, in order to validate nonprofit 
status and effectively capture award data of all nonprofits receiving 
funds passed through other entities, the prime award recipients would 
have to require that those receiving subawards at every award tier 
register in CCR and report their award data directly to a central 
repository. OMB noted that states would likely have the largest volume 
of multitier award activity and would be responsible for ensuring 
compliance at every tier and for validating the data, which could 
impose a major resource burden on states. 

We recognize the additional difficulty of ensuring the accuracy of 
information on those receiving subawards. However, we identified 
unreliable information on nonprofit status for funds that were provided 
directly to nonprofits, and ensuring the accuracy of information on 
these direct recipients would be a first step to improving the data. We 
also believe, however, that as the FFATA data are expanded to include 
data on those receiving subawards, efforts are needed to ensure the 
accuracy of that data, including the nonprofit status of recipients of 
federal funds. We believe that this is the appropriate time--as OMB is 
continuing to develop its approach to implementing FFATA's subaward 
data requirements--to identify approaches that could be effective in 
improving the reliability of this information. 

The Department of Housing and Urban Development also responded by e- 
mail, stating that it concurred with the draft and offering comments 
based on information from its own verification and validation of FPDS- 
NG data. It concurred that data limitations and reliability concerns 
contribute to an incomplete and unreliable picture of federal funding, 
which limits the reliability and completeness of reported funds. 
Further, it concurred that the CCR should be used to validate 
information on recipients' nonprofit status and should have validation 
checks and a consistent definition describing nonprofits. In addition 
to these formal comments, the Department of Agriculture provided a 
technical comment, which we incorporated. The Departments of 
Agriculture, Education, Health and Human Services, and Labor did not 
provide formal comments. 

We will send copies of this report to the Director of OMB and the 
Secretaries of Agriculture, Health and Human Services, Housing and 
Urban Development, Labor, and Education. In addition, the report will 
be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you have any questions about this report, please contact me at (202) 
512-6806 or czerwinskis@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Key contributors to this report are listed in 
appendix III. 

Sincerely yours, 

Signed by: 

Stanley J. Czerwinski: 
Director, Strategic Issues: 

[End of section] 

Appendix I: Detailed Scope and Methodology: 

To identify the direct and indirect mechanisms through which nonprofit 
organizations receive federal funds, we reviewed academic and 
professional literature, met with experts on the nonprofit sector, 
reviewed previous GAO reports on federal programs that involve 
nonprofit organizations, reviewed 19 different programs (see table 3), 
and met with agency officials. We judgmentally selected these programs 
using three criteria: they (1) utilized a variety of direct and 
indirect mechanisms, (2) provided services across a variety of policy 
areas and sectors, and (3) represented programs among the higher dollar 
values of all federal programs that involve nonprofit organizations. 
Although the information obtained from this review cannot be 
generalized as representative of all nonprofit programs or funding 
mechanisms, we believe it provides valuable insight into how these 
funding mechanisms operate and the relationship between the federal and 
nonprofit sectors. 

Table 3: Summary of Targeted Programs Discussed in the Report: 

Grants provided directly to the nonprofit sector: 

Program title: Head Start; 
Agency: Health and Human Services (HHS)/Administration for Children and 
Families (ACF); 
Description: Provides grants to public and private nonprofit and for-
profit agencies that help prepare low-income children for kindergarten 
by providing comprehensive early childhood development services--
including educational, health, nutritional, and social services--to 
children and their families. 

Program title: National Institutes of Health (NIH) Research Grants; 
Agency: HHS/NIH; 
Description: Provides grants to public and private, nonprofit and for-
profit organizations to support the advancement of high-caliber, 
unique, and investigator-initiated research that promotes public 
health. 

Program title: Senior Community Service Employment Program; 
Agency: Department of Labor (DOL)/Employment and Training 
Administration (ETA); 
Description: Funds nonprofit organizations and state and territorial 
governments to provide subsidized, part-time work-based training to 
older workers through employment in a variety of community-service 
oriented jobs in nonprofit and public facilities, including hospitals 
and day care services. 

Indirect grants provided to the nonprofit sector through state 
governments or other entities: 

Program title: Child and Adult Care Food Program; 
Agency: U.S. Department of Agriculture (USDA)/Food and Nutrition 
Service (FNS); 
Description: Provides grants to states that reimburse institutions and 
organizations that provide nutritious meals and snacks to eligible 
children and adults who are enrolled for care at participating child 
care centers, day care homes, adult day care centers, emergency 
shelters, and after-school care programs. 

Program title: Emergency Shelter Grants Program; 
Agency: Housing and Urban Development (HUD)/Office of Community 
Planning and Development; 
Description: Provides funding to states, large cities, urban counties, 
and U.S. territories to provide homeless persons with basic shelter and 
essential supportive services. 

Program title: Medicaid; 
Agency: HHS/Centers for Medicare & Medicaid Services (CMS); 
Description: A state-administered program jointly funded by the federal 
and state governments to provide medical assistance, including acute 
and long-term care for low-income, aged, or disabled individuals. 

Program title: Social Services Block Grant; 
Agency: HHS/ACF; 
Description: Provides funding to states to furnish social services 
including daycare, protective services, adoption, health-related 
services, transportation, or any other social services found necessary 
by the state. 

Program title: Temporary Assistance to Needy Families; 
Agency: HHS/ACF; 
Description: Provides grants to states for a range of benefits and 
services, including providing cash assistance to needy families with 
children. 

Program title: Workforce Investment Act Youth Programs; 
Agency: DOL/ETA; 
Description: Provides formula grants to states to support training and 
related services--including mentoring, leadership development, support 
services such as childcare, and counseling--for certain low-income, at 
risk youth ages 14-21. 

Contracts: 

Program title: Federally Funded Research and Development Centers; 
Agency: Many federal departments and agencies, including the 
Departments of Defense (DOD), Energy (DOE), HHS, and Homeland Security 
(DHS); 
Description: Privately owned but government-funded entities with long-
term contractual relationships with one or more federal agencies 
conducting research in areas such as military space programs, 
nanotechnology, microelectronics, nuclear warfare, and biodefense 
countermeasures, among other areas. 

Fee-for-service payments: 

Program title: Medicare; 
Agency: HHS/CMS; 
Description: Provides health insurance to individuals aged 65 and older 
as well as certain disabled individuals. 

Program title: Pell Grant; 
Agency: Department of Education (Education)/Office of Federal Student 
Aid (FSA); 
Description: Provides need-based grants to low income undergraduate and 
certain postbaccalaureate students to promote access to postsecondary 
education. 

Tax expenditures: 

Program title: Low-Income Housing Tax Credit; 
Agency: Internal Revenue Service (IRS), HUD, and Department of Justice; 
Description: Promotes lower, more affordable rents by providing federal 
tax credits to developers of qualified low-income housing projects, who 
can either use the credits or sell them to investors to raise capital 
(or equity) for real estate projects. 

Program title: Tax-Exempt 501(c)(3) Bonds; 
Agency: IRS; 
Description: Tax-exempt bonds issued by state and local governments, 
the proceeds of which are used to finance property owned by 501(c)(3) 
charitable organizations or a governmental unit. 

Program title: Charitable Contribution Deduction; 
Agency: IRS; 
Description: Provides an incentive for individual and corporate 
taxpayers to donate to nonprofits. 

Credit programs: 

Program title: Federal Direct Student Loans; 
Agency: Education/FSA; 
Description: Provides loans directly to vocational, undergraduate, and 
graduate postsecondary school students and their parents. 

Program title: Federal Family Education Loans; 
Agency: Education/FSA; 
Description: Provides guarantees to encourage private lenders to make 
loans to vocational, undergraduate, and graduate students enrolled at 
eligible postsecondary institutions to help pay for educational 
expenses. 

Program title: Hospital Mortgage Insurance; 
Agency: HUD/Federal Housing Administration; 
Description: Insures nonprofit and for-profit hospitals' loans that 
finance the construction, modernization, equipping, or refinancing of 
acute care hospitals. 

Program title: Rural Development, Utilities Programs--Electric Program; 
Agency: USDA/Rural Development, Utilities Programs; 
Description: Provides financing to electric utilities serving rural 
communities to construct electric distribution, transmission, and 
generation facilities. 

Source: GAO analysis of program data from agencies. 

[End of table] 

To assess federal funding reaching nonprofit organizations through 
various mechanisms, we reviewed the literature on funding to 
nonprofits, assessed the suitability of various potential data sources, 
and analyzed data from those sources we determined to be most 
appropriate. We did not validate all of the data provided through these 
various sources. However, we took several steps to assess data quality. 
Specifically, in sources where individual recipient-level data were 
available, we tested a sample of records with the Internal Revenue 
Service's (IRS) Master File listing of all tax-exempt organizations and 
other sources. (For more information, see appendix II.) To assess the 
reliability of funding figures in these data sources, we interviewed 
agency officials, performed various quality checks, reviewed available 
documentation, and where possible compared data to that from other 
sources. Overall, we determined that the data were sufficiently 
reliable for our engagement purposes. However, we identified 
significant reliability concerns regarding data from two systems, 
Federal Procurement Data System--Next Generation (FPDS-NG) and Federal 
Awards and Assistance Data System (FAADS), which we highlight in the 
body of the report and in appendix II. 

We used the following data sources to estimate federal funding to 
nonprofit organizations: 

* FPDS-NG--We assessed federal contract funding to nonprofit 
organizations by summing the funding for all contract actions involving 
vendors identified as nonprofits in the FPDS-NG in fiscal year 2006. 

* FAADS--To assess federal grant, fee-for-service or voucher, and 
credit assistance to nonprofit organizations, we used data from FAADS. 
We compiled quarterly files for all of fiscal year 2006 and removed any 
actions reported during fiscal year 2006 that are corrections to data 
from previous fiscal years. We did not include corrections to fiscal 
year 2006 data that were reported in subsequent quarterly files. During 
the course of our analysis, we identified a set of records with action 
obligation dates outside of fiscal year 2006 and removed those we 
determined did not relate to fiscal year 2006 actions. FAADS contains 
several assistance types, and we considered grants to include those 
actions coded as being block grants, formula grants, project grants, 
and cooperative agreements. Direct payments for specified use include 
payments under Medicare, and we consider these to be fee-for-service or 
voucher programs. FAADS also reports data on direct loans and loan 
guarantees. We did not comprehensively assess the accuracy of the 
assistance types in FAADS. FAADS funding amounts are primarily based on 
obligations. 

* Medicare--To assess Medicare program funding to nonprofit 
organizations, we analyzed data from Centers for Medicare & Medicaid 
Services (CMS) data systems and assessed information provided by CMS 
officials. For Medicare Part A and B payments to nonprofit 
organizations, we combined data on payments to providers in CMS' Health 
Care Information System (HCIS) with the nonprofit status of those 
providers in the Provider of Services (POS) files. We divided entity 
types in the POS into nonprofit and other categories based on our 
review of documentation and, where documentation was lacking, tests of 
some recipients. We did not consider entities coded as combined types, 
such as combined government and voluntary home health facilities, to be 
nonprofit organizations. CMS officials provided data on Medicare Part C 
(managed care) and D (prescription drug benefit) payments to nonprofit 
and other plan types, which officials told us represent nonprofit 
status from CMS' Health Plan Management System (HPMS) and payment 
figures to those plans from the Automated Plan Payment System (APPS). 
All figures on Medicare payments are for the calendar year 2006. 

* Medicaid and State Children's Health Insurance Program--We estimated 
the amount of federal funds that may have reached nonprofit 
institutions through Medicaid and the State Children's Health Insurance 
Program (SCHIP) by examining program expenditure reports and assessing 
a share of expenditures in select categories that may have reached 
nonprofit organizations. Our calculations are based on a preliminary 
version of CMS' Financial Management Report for fiscal year 2006 that 
was provided to us by CMS and is subject to revisions. We combined 
federal Medicaid and SCHIP expenditures in fiscal year 2006 in select 
service categories that we identified during our review as 
significantly involving nonprofit organizations. We then used nonprofit 
organizations' share of total health care sector revenues from the 
Census Bureau's Service Annual Survey 2006 as a proxy for the portion 
of federal expenditures in these categories that may reach nonprofit 
organizations.[Footnote 38] The actual amount of funds reaching 
nonprofit organizations through Medicaid and SCHIP could be greater or 
less than our estimate for several reasons including how similarly the 
programs rely on nonprofit organizations compared with the health care 
sector overall. To assess the reasonableness of our estimate, we 
discussed our approach and findings with internal GAO experts, 
officials at CMS, and compared our results with those of other 
researchers. 

* Other Indirect Grants through States--For perspective on the extent 
to which states collect data on federal funding passed through to 
nonprofit organizations, we spoke to officials from the three states 
obtaining the most federal assistance funds in 2006, based on the FAADS 
data from that year--California, New York, Texas--as well as two states 
suggested by others as developing information systems to track those 
funds--Michigan and Maryland. We discussed their present and planned 
activities to track these funds and, when available, obtained limited 
information that they collected. 

* Credit--In addition to using data from FAADS, we assessed federal 
funding to nonprofit organizations through credit programs by examining 
the Office of Management and Budget's (OMB) compilation of data on 
federal credit programs in the President's Budget.[Footnote 39] OMB 
reports on the face value of federal credit outstanding as well as the 
estimated future cost of outstanding federal credit. 

* Tax Policy--To assess the costs of tax policies that benefit 
nonprofit organizations, we reviewed the literature on nonprofits and 
taxes and reviewed estimates of the value of nonprofits' tax exemption 
and the revenue loss estimates associated with various specific tax 
expenditures. In particular, we assessed estimates of the costs of 
several specific tax expenditures that benefit nonprofit organizations 
in the Department of the Treasury's Office of Tax Analysis list of tax 
expenditures and estimates of their cost as reported by OMB in the 
President's Budget submission.[Footnote 40] We had analyzed the 
development of these estimates extensively for recent work.[Footnote 
41] We did not attempt to identify all tax expenditures that involve 
nonprofit organizations. In several cases, estimates of the cost of tax 
expenditures include tax expenditures involving nonprofit and other 
entities. For example, the exclusion of interest for hospital 
construction bonds benefits nonprofit and other hospitals. We were 
unable to distinguish the portion of these tax expenditures that 
involved nonprofit organizations. 

[End of section] 

Appendix II: Nonprofit Identification in Key Data Systems: 

To assess how reliably nonprofit organizations are identified within 
key data systems for our purposes, we tested random samples of 
populations from various segments of these databases against 
alternative sources. We tested samples of records in the Federal Awards 
and Assistance Data System (FAADS), Federal Procurement Data System-- 
Next Generation (FPDS-NG), and Medicare's Provider of Services (POS) 
and Health Plan Management System (HPMS).[Footnote 42] For FAADS, our 
testing is based on a sample of 96 records coded as nonprofit 
organizations and 97 records coded as other entity types. For FPDS-NG, 
we tested 95 vendors that were consistently coded as nonprofit 
organizations, and 96 vendors of all other types. For the POS, we 
tested 96 providers including nonprofit and other types. We tested 87 
HPMS plans. 

For each of these samples, we compared the nonprofit status of records 
with organizations' status in several sources including the Internal 
Revenue Service's Business Master File,[Footnote 43] the 2002 Census of 
Governments,[Footnote 44] the 2005 Higher Education Directory,[Footnote 
45] the American Hospital Association's 2007 Guide,[Footnote 46] and 
information from the Department of Housing and Urban Development (HUD) 
that is compiled by the National Housing Trust on housing developments. 
Since we relied on matching organizations by name and location across 
these data sources, we used our professional judgment based on the 
preponderance of the evidence across multiple data sources in assessing 
whether a given organization was a nonprofit or other entity type. 
Because of limitations involved with name searches and the lack of 
comprehensive sources for entities that are not nonprofit 
organizations, we were unable to verify the status of a significant 
portion of sampled records in many of these data sources, as shown in 
table 4 below. We also estimate that a significant portion of records 
in FAADS and vendors in FPDS-NG are miscoded for the purposes of our 
assessment. These are not necessarily errors since these databases use 
various definitions of nonprofit organizations in their systems, none 
of which align exactly with our definition of a nonprofit. 

Table 4: Estimated Reliability of Nonprofit Identification in Key Data 
Systems Based on Samples of Records: 

Database and segment of records: FAADS: Nonprofits; 
Percent estimated to be correctly identified (with 95 percent 
confidence interval): 70; (60-79); 
Percent unable to verify (with 95 percent confidence interval): 22; 
(14-31); 
Percent estimated to be miscoded for our purposes (with 95 percent 
confidence interval)[A]: 8; (4-16). 

Database and segment of records: FAADS: All other recipients[B]; 
Percent estimated to be correctly identified (with 95 percent 
confidence interval): 59; (48-69); 
Percent unable to verify (with 95 percent confidence interval): 36; 
(27-46); 
Percent estimated to be miscoded for our purposes (with 95 percent 
confidence interval)[A]: 5; (2-12). 

Database and segment of records: FPDS-NG[C]: Nonprofits; 
Percent estimated to be correctly identified (with 95 percent 
confidence interval): 74; (64-82); 
Percent unable to verify (with 95 percent confidence interval): 11; 
(5-19); 
Percent estimated to be miscoded for our purposes (with 95 percent 
confidence interval)[A]: 16; (9-25). 

Database and segment of records: FPDS-NG[C]: All other recipients; 
Percent estimated to be correctly identified (with 95 percent 
confidence interval): 100; (97-100); 
Percent unable to verify (with 95 percent confidence interval): 0; 
(0-3); 
Percent estimated to be miscoded for our purposes (with 95 percent 
confidence interval)[A]: 0; (0-3). 

Database and segment of records: Medicare Provider of Services (POS); 
Percent estimated to be correctly identified (with 95 percent 
confidence interval): 91; (83-96); 
Percent unable to verify (with 95 percent confidence interval): 8; 
(4-16); 
Percent estimated to be miscoded for our purposes (with 95 percent 
confidence interval)[A]: 1; (0-6). 

Database and segment of records: Medicare Health Plan Management System 
(HPMS)[D]; 
Percent estimated to be correctly identified (with 95 percent 
confidence interval): 82; (72-89); 
Percent unable to verify (with 95 percent confidence interval): 2; 
(0-8); 
Percent estimated to be miscoded for our purposes (with 95 percent 
confidence interval)[A]: 16; (9-26). 

Source: GAO analysis of Census Bureau, CMS, General Services 
Administration, and OMB data. 

Notes: GAO analysis of Federal Awards and Assistance Data System 
(FAADS), Federal Procurement Data System--Next Generation (FPDS-NG), 
Medicare Provider of Services (POS) and Health Plan Management System 
(HPMS) data. 

[A] Though miscoded for the purposes of our assessment, these are not 
necessarily errors because databases use various definitions of 
nonprofit organizations in their systems none of which align exactly 
with our definition of a nonprofit. 

[B] This includes those records in FAADS that are not labeled as 
nonprofit organizations or private institutions of higher education. 

[C] FPDS-NG samples were drawn from the set of vendors who were 
consistently labeled in FPDS-NG. This assessment excludes 1,768 vendors 
in FAADS with some contract actions where they are labeled as nonprofit 
organizations and other contract actions where they are labeled as 
other recipient types. 

[D] Most entities that we labeled as miscoded in the HPMS system were 
due to Blue Cross/Blue Shield plans that were listed as nonprofit 
organizations. Because these organizations are not federal tax-exempt 
organizations, we did not include them in our definition of nonprofit 
organizations. 

[End of table] 

We used the same approach and sources to assess the portion of records 
in FAADS labeled as private institutions of higher education that were 
nonprofit organizations. Based on our tests of a sample of 96 records, 
we estimate that 95 percent are nonprofit organizations (with a 95 
percent confidence interval of 88-98 percent). 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Stanley J. Czerwinski, (202) 512-6806 or czerwinskis@gao.gov: 

Acknowledgments: 

In addition to the contact named above, Thomas James, Assistant 
Director; Carol Patey, Analyst-in-Charge; James Ashley; Kathleen Boggs; 
David Dornisch; Kathryn Edelman; Mark Egger; Shannon Finnegan; Quindi 
Franco; Arthur James; Martha Kelly; Julia Kennon; Thomas McCabe; 
Jessica Nierenberg; and Carolyn Yocom made key contributions to this 
report. 

[End of section] 

Footnotes: 

[1] Except where otherwise noted, we use 2006 to refer to the federal 
2006 fiscal year. 

[2] The Federal Funding Accountability and Transparency Act of 2006 
(FFATA) requires the federal government to collect and report data on 
subawards. 

[3] The Urban Institute, "The Nonprofit Sector in Brief: Facts and 
Figures from the Nonprofit Almanac 2008" (2008), [hyperlink, 
http://nccs.urban.org/statistcs/quickfacts.cfm] (downloaded Oct. 24, 
2008). Data only include nonprofits with gross receipts greater than 
$25,000 that filed Form 990 with the Internal Revenue Service (IRS). 
Also, revenues from certain religious organizations, such as churches, 
may not be included because they are not required to register with the 
IRS, although some have chosen to do so. 

[4] For the purposes of this review, we define nonprofit organizations 
as any organization having federal tax-exempt status as approved by the 
IRS under section 501(a) of the Internal Revenue Code. This includes 
all organizations covered under section 501(c) of the Internal Revenue 
Code, such as charities, social welfare organizations, and chambers of 
commerce. 

[5] U.S. Internal Revenue Service, Data Book, [hyperlink, 
http://www.irs.gov/pub/irs-soi/07dbexemptact.pdf] (downloaded June 11, 
2008). 

[6] These figures only include revenues from charities classified as 
501(c)(3) organizations and do not include 501(c)(3) private 
foundations and other tax-exempt organizations, such as trade 
organizations and labor unions. Also, revenues from certain religious 
organizations, such as churches, may not be included because they are 
not required to register with the IRS, although some have chosen to do 
so. 

[7] After receiving tax-exempt recognition, many nonprofit 
organizations must annually file an information return, Form 990 (or 
990-EZ), to report their financial transactions and activities. In 
2005, certain religious organizations and entities with gross receipts 
of $25,000 or less were not required to file annual information 
returns. 

[8] Amy Blackwood, Kennard T. Wing, and Thomas H. Pollak, "The 
Nonprofit Sector in Brief--Facts and Figures from the Nonprofit Almanac 
2008: Public Charities, Giving, and Volunteering" (Urban Institute, 
2008), [hyperlink, http://nccs.urban.org/statistics/quickfacts.cfm] 
(downloaded Oct. 24, 2008). 

[9] See GAO, Nonprofit Sector: Increasing Numbers and Key Role in 
Delivering Federal Services, [hyperlink, 
http://www.gao.gov/products/GAO-07-1084T] (Washington, D.C.: July 24, 
2007), 4. Data from National Center for Charitable Statistics (using 
the IRS Business Master File, May 2006), [hyperlink, 
http://nccsdataweb.urban.org/NCCS/Public/index.php] (downloaded Dec. 
18, 2006). 

[10] GAO, Tax-Exempt Sector: Governance, Transparency, and Oversight 
Are Critical for Maintaining Public Trust, [hyperlink, 
http://www.gao.gov/products/GAO-05-561T] (Washington, D.C.: Apr. 20, 
2005), 10. 

[11] [hyperlink, http://www.gao.gov/products/GAO-07-1084T]. 

[12] The Federal Grant and Cooperative Agreement Act of 1977 discusses 
the use of grant relationships versus procurement contracts. The act's 
provisions are intended to prescribe criteria for executive agencies in 
selecting appropriate legal instruments to achieve uniformity in grant 
and cooperative agreement use, a clear definition of the relationships 
they reflect, and a better understanding of the responsibilities of the 
parties to them. The distinction between these two forms of assistance 
is that substantial involvement is expected between the executive 
agency and the state, local government, or other recipient when 
carrying out the activity contemplated in a cooperative agreement, 
whereas such involvement is not expected in carrying out a grant 
agreement (see 31 U.S.C. § 6304-05). Cooperative agreements are useful 
where federal project management would be helpful due to the novelty or 
complexity involved, where collaborative research is desirable, or 
federal involvement is needed in early stages where standards are being 
developed. Given the similarity between these two forms of assistance, 
we refer to grants and cooperative agreements as grants in the 
remainder of this report. 

[13] Pub. L. No. 109-282, 120 Stat. 186 (Sept. 26, 2006). 

[14] The Single Audit Act requires nonfederal entities that expend 
$500,000 or more annually in federal awards to undergo an audit. 31 
U.S.C. § 7502. However, entities spending less than $500,000 in federal 
awards are not required to undergo an audit and therefore information 
on these entities is not provided in the Federal Audit Clearinghouse. 

[15] See GAO, Temporomandibular Joint and Muscle Disorders: NIH 
Supports a Wide Range of Research, [hyperlink, 
http://www.gao.gov/products/GAO-08-454R] (Washington, D.C.: Apr. 4, 
2008). 

[16] Although electricity cooperatives may not be traditionally 
considered nonprofit organizations, they fall under the definition of 
"nonprofit" used in this report because they are classified as tax- 
exempt entities under the tax code. 

[17] However, exempt organizations are subject to tax on income earned 
through activities that are unrelated to their tax-exempt purpose, 
commonly referred to as unrelated business income tax. 26 U.S.C. § 
501(b). 

[18] For additional information on tax expenditures, see GAO, 
Government Performance and Accountability: Tax Expenditures Represent a 
Substantial Federal Commitment and Need to Be Reexamined, [hyperlink, 
http://www.gao.gov/products/GAO-05-690] (Washington, D.C.: Sept. 23, 
2005). 

[19] Individuals may also deduct charitable contributions to federal, 
state, and local governments if the contribution is solely for public 
purposes. 

[20] Depending on the state, nonprofit organizations may compete with 
for-profit entities for state-allocated Social Services Block Grant 
funds. 

[21] An official from the Centers for Medicare & Medicaid Services 
stated that oversight over nonprofit and for-profit contract providers 
is the same within the managed care and part B components of Medicare, 
which cover hospital insurance and insurance coverage for physician 
visits. 

[22] Pub. L. No. 97-255, 96 Stat. 814 (Sept. 8, 1982), codified at 31 
U.S.C. § 3512(c); see also Office of Management and Budget, Revisions 
to OMB Circular A-123, Management's Responsibility for Internal Control 
(Washington, D.C.: Dec. 21, 2004). 

[23] Woods Bowman and Marion Fremont-Smith, "Nonprofits and State and 
Local Governments," in Nonprofits and Government: Collaboration and 
Conflict (Washington, D.C.: The Urban Institute Press, 2006), 193. 

[24] See GAO, Reliability of Federal Procurement Data, [hyperlink, 
http://www.gao.gov/products/GAO-04-295R] (Washington, D.C.: Dec. 30, 
2003); Improvements Needed to the Federal Procurement Data System-Next 
Generation, [hyperlink, http://www.gao.gov/products/GAO-05-960R] 
(Washington, D.C.: Sept. 27, 2005); Alaska Native Villages: Recent 
Federal Assistance Exceeded $3 Billion, with Most Provided to Regional 
Nonprofits, [hyperlink, http://www.gao.gov/products/GAO-05-719] 
(Washington, D.C.: Aug. 2, 2005). 

[25] GAO, Rural Economic Development: More Assurance Is Needed That 
Grant Funding Information Is Accurately Reported, [hyperlink, 
http://www.gao.gov/products/GAO-06-294] (Washington, D.C.: Feb. 24, 
2006), 23. 

[26] Central Contractor Registration, CCR Handbook (March 2008), p. 12. 

[27] See [hyperlink, http://www.gao.gov/products/GAO-04-295], 5; 
[hyperlink, http://www.gao.gov/products/GAO-05-960R], 5; and 
[hyperlink, http://www.gao.gov/products/GAO-06-294], 32. 

[28] CCR is the primary registrant database used by the federal 
government to collect, validate, store, and disseminate data in support 
of agency procurement activities. Currently, organizations must 
register in CCR to be awarded contracts by the federal government. 

[29] Figures from these two data systems are not entirely comparable 
because (1) funding in FAADS is primarily obligations, whereas Medicare 
figures refer to outlays; and (2) FAADS refers to the federal fiscal 
year while Medicare figures are for the calendar year. 

[30] Figures for Medicare managed care and prescription drug care 
plans, totaling $26 billion in calendar year 2006, include some 
payments to Blue Cross/Blue Shield plans that are not federal tax- 
exempt organizations. 

[31] According to the FAADS reporting manual, amounts in FAADS for 
direct loans are "the gross amount of the loan" and guaranteed loans 
are the "amount of the Federal Government's contingent liability." OMB 
and U.S. Department of Commerce, Bureau of the Census, Federal 
Assistance Award Data System Reporting Manual for Federal Fiscal Year 
2006 (2006), 25. However, OMB has reported that FAADS only includes 
loan guarantee information when a default claim payment has been made. 

[32] According to data from FAADS, 20 percent of Federal Direct Student 
Loans went to nonprofit organizations in 2006. We therefore estimated 
that 20 percent of total outstanding direct and guaranteed federal 
student loans were used at nonprofit schools. 

[33] The future costs are the subsidy cost and estimated uncollectible 
principal and interest for direct loans, and estimated liabilities for 
loan guarantees. The subsidy cost, as defined by the Federal Credit 
Reform Act of 1990, is the government's estimated net long-term cost, 
in present value terms, of direct or guaranteed loans over the entire 
period the loans are outstanding. 

[34] Generally, tax expenditure costs are estimated by comparing the 
revenue raised under current law with revenue that would have been 
raised if a given provision did not exist, assuming all other parts of 
the tax code remain constant and taxpayer behavior is unchanged. These 
revenue loss estimates are intended to provide information about the 
value of tax expenditures. However, tax expenditure estimates do not 
incorporate any behavioral responses and thus do not necessarily 
represent the exact amount of revenue that would be gained if a 
specific tax expenditure were repealed. In addition, the value of the 
tax expenditure depends on baselines used and various other 
assumptions. 

[35] Evelyn Brody and Joseph J. Cordes, "Tax Treatment of Nonprofit 
Organizations: A Two-Edged Sword?" in Nonprofits and Government: 
Collaboration & Conflict, 2nd ed. (Washington, D.C.: The Urban 
Institute Press, 2006), 141-180. 

[36] Congressional Budget Office, Taxing the Untaxed Business Sector 
(Washington, D.C., July 2005). 

[37] Aggregate tax expenditure estimates must be interpreted carefully 
because of inherent limitations in the meaning of the summed estimates. 
The sum of the individual tax expenditure estimates is useful for 
gauging the general magnitude of revenue forgone through provisions of 
the tax code but does not take into account interactions between 
individual provisions. 

[38] The Service Annual Survey 2006 includes revenues at government- 
operated hospitals along with revenues at tax-exempt establishments. 
Therefore, in order to get revenues at private tax-exempt institutions 
corresponding to our definition of nonprofit organizations, we subtract 
revenues to government hospitals from total revenues at tax-exempt 
firms. 

[39] Office of Management and Budget, Analytical Perspectives, Budget 
of the United States Government, Fiscal Year 2009 (Washington, D.C.: 
2008). 

[40] Generally, tax expenditure costs are estimated by comparing the 
revenue raised under current law with revenue that would have been 
raised if a given provision did not exist, assuming all other parts of 
the tax code remain constant and taxpayer behavior is unchanged. These 
revenue loss estimates are intended to provide information about the 
value of tax expenditures. However, tax expenditure estimates do not 
incorporate any behavioral responses and thus do not necessarily 
represent the exact amount of revenue that would be gained if a 
specific tax expenditure were repealed. In addition, the value of the 
tax expenditure depends on baselines used and various other 
assumptions. 

[41] GAO, Government Performance and Accountability: Tax Expenditures 
Represent a Substantial Federal Commitment and Need to Be Reexamined, 
[hyperlink, http://www.gao.gov/products/GAO-05-690] (Washington, D.C.: 
Sept. 23, 2005), 79-81. 

[42] Each of these systems was tested at different levels because of 
how the data are collected. We tested FAADS records at the obligation 
or award level such that one recipient may be associated with multiple 
records. FPDS-NG and Medicare data were tested at the vendor or 
provider level and may have multiple funding actions associated with 
each vendor. 

[43] Internal Revenue Service, Business Master File [hyperlink, 
http://www.irs.gov/taxstats/charitablestats/article/0,,id=97186,00.html,
 downloaded on Aug. 6, 2008, containing data that had been updated as 
of July 31, 2008). 

[44] U.S. Census Bureau, 2002 Census of Governments: Governments 
Integrated Directory Public Use Files [hyperlink, 
http://www.census.gov/govs/www/cog2002.html], downloaded Sept. 18, 
2008). 

[45] Higher Education Publications, Inc., 2005 Higher Education 
Directory (Falls Church, Va., 2005). 

[46] American Hospital Association, AHA Guide 2007 (Chicago, Ill., 
2007). We considered the following control codes in the AHA Guide to be 
nonprofit organizations: church operated nongovernment nonprofit, other 
nongoverment nonprofit, church operated osteophathic, and other not-for-
profit osteophathic. All other control codes were considered to be 
other entity types. 

[End of section] 

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