ENTERPRISE RISK
MANAGEMENT
Selected Agencies’
Experiences Illustrate
Good Practices in
Managing Risk
Report to the Committee on Oversight
and Government Reform, House of
Representatives
December 2016
GAO-17-63
United States Government Accountability Office
United States Government Accountability Office
Highlights of GAO-17-63, a report to the
Committee on Oversight and Government
Reform, House of Representatives
December 2016
ENTERPRISE RISK MANAGEMENT
Selected Agencies’ Experiences Illustrate Good
Practices in
Managing Risk
What GAO Found
Enterprise Risk Management (ERM) is a forward-looking management approach
that allows agencies to assess threats and opportunities that could affect the
achievement of its goals. While there are a number of different frameworks for
ERM, the figure below lists essential elements for an agency to carry out ERM
effectively. GAO reviewed its risk management framework and incorporated
changes to better address recent and emerging federal experience with ERM
and identify the essential elements of ERM as shown below.
GAO has identified six good practices to use when implementing ERM.
Essential Elements and Good Practices of Enterprise Risk Management (ERM)
Elements
Align ERM process
to goals and
objectives
Implementing ERM requires the full engagement and commitment of senior
leaders, supports the role of leadership in the agency goal setting process,
Identify Risks
Effectively Raise Risks
Developing an organizational culture to encourage employees to identify and
Assess Risks
Organizational Performance Management
Integrating the prioritized risk assessment into strategic planning and
organizational performance management processes helps improve
Select Risk
Response
Processes
Customizing ERM helps agency leaders regularly consider risk and select
the most appropriate risk response that fits the particular structure and
Monitor Risks
Conducting the ERM review cycle on a regular basis and monitoring the
selected risk response with performance indicators allows the agency to
track results and impact on the mission, and whether the risk response is
Communicate and
Report on Risks
and Communicate Risks
Sharing risk information and incorporating feedback from internal and
external stakeholders can help organizations identify and better manage
risks, as well as increase transparency and accountability to Congress and
Source: GAO. | GAO-17-63
View GAO-17-63. For more information,
contact J. Christopher Mihm at (202) 512
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6806
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mihm[email protected]
Why GAO Did This Study
Federal leaders are responsible for
managing complex and risky missions.
ERM is a way to assist agencies with
managing risk across the organization.
In July 2016, the Office of
Management and Budget (OMB)
issued an updated circular requiring
federal agencies to implement ERM to
ensure federal managers are
effectively managing risks that could
affect the achievement of agency
strategic objectives.
GAO’s objectives were to (1) update its
risk management framework to more
fully include evolving requirements and
essential elements for federal
enterprise risk management, and (2)
identify good practices that selected
agencies have taken that illustrate
those essential elements.
GAO reviewed literature to identify
good ERM practices that generally
aligned with the essential elements
and validated these with subject matter
specialists.
GAO also interviewed officials
representing the 24 Chief Financial
Officer (CFO) Act agencies about ERM
activities and reviewed documentation
where available to corroborate officials’
statements. GAO studied agencies’
practices using ERM and selected
examples that best illustrated the
essential elements and good practices
of ERM.
GAO provided a draft of this report to
OMB and the 24 CFO Act agencies for
review and comment. OMB generally
agreed with the report. Of the CFO act
agencies, 12 provided technical
comments, which GAO included as
appropriate; the others did not provide
any comments.
Page i GAO-17-63 Enterprise Risk Management
Letter 1
Background 5
Updated ERM Framework Provides Assistance to Agencies as
They Implement ERM 7
Emerging Good Practices Are Being Used at Selected Agencies
to Implement ERM 12
Agency Comments and GAO Responses 43
Appendix I Subject Matter Specialists 45
Appendix II Comments from the Social Security Administration 46
Appendix III Comments from the Department of Veterans Affairs 47
Appendix IV GAO Contact and Staff Acknowledgements 49
Tables
Table 1: Essential Elements and Associated Good Practices of
Federal Government Enterprise Risk Management (ERM) 13
Table 2: Department of Commerce Roles and Selected
Responsibilities for Enterprise Risk Management (ERM) 20
Table 3: Comparison of Department of Commerce (Commerce)
and National Institute of Standards and Technology
(NIST) Enterprise Risk Management (ERM) Reference
Cards25
Figures
Figure 1: Essential Elements of Federal Government Enterprise
Risk Management 8
Figure 2: National Institute of Standards and Technology
Leadership Risk Appetite Survey Scale 18
Contents
Page ii GAO-17-63 Enterprise Risk Management
Figure 3: Transportation Security Administration Vulnerability
Management Process 23
Figure 4: Department of the Treasury Quarterly Performance
Review Templates 27
Figure 5: Example of an Office of Personnel Management (OPM)
Dashboard for Preparing the Federal Workforce for
Retirement Goal 29
Figure 6. Transportation Security Administration Risk Taxonomy 33
Figure 7: Selected Questions from Commerce’s Enterprise Risk
Management Maturity Assessment Tool (EMAT) 34
Figure 8: Public and Indian Housing Risk and Mitigation Strategies
Dashboard 36
Figure 9: Public and Indian Housing Key Risk Indicators
Dashboard 38
Figure 10: Internal Revenue Service Risk Acceptance Form and
Tool Decision-Making Tool 42
Page iii GAO-17-63 Enterprise Risk Management
Abbreviations
AFERM Association of Federal Enterprise Risk Management
APG agency priority goals
APMC Agency Program Management Council
CFO Chief Financial Officer
CFOC Chief Financial Officers Council
CIO Chief Information Officer
CMO Chief Management Officer
Commerce Department of Commerce
COO Chief Operating Officer
COSO Committee of Sponsoring Organizations of the
Treadway Commission
CRO Chief Risk Officer
DATA Act Digital Accountability and Transparency Act of 2014
DHS Department of Homeland Security
Education Department of Education
EMAT ERM Maturity Assessment Tool
ERM Enterprise Risk Management
ERSC Executive Risk Steering Committee
FMFIA Federal Managers’ Financial Integrity Act
FSA Office of Federal Student Aid
FTE Full-time equivalent
GPRA Government Performance and Results Act
GPRAMA GPRA Modernization Act of 2010
HUD Department of Housing and Urban Development
Interior Department of the Interior
IRS Internal Revenue Service
ISO International Organization for Standardization
IT information technology
JPSS Joint Polar Satellite System
Page iv GAO-17-63 Enterprise Risk Management
NIST National Institute of Standards and Technology
NASA National Aeronautics and Space Administration
NOAA National Oceanic and Atmospheric Administration
OCRO Office of the Chief Risk Officer
OMB Office of Management and Budget
OPERM Office of Program Evaluation and Risk Management
OPM Office of Personnel Management
PIC Performance Improvement Council
PIH Office of Public and Indian Housing
PIO Performance Improvement Officer
PwC PricewaterhouseCoopers
QPR quarterly performance review
RAFT Risk Acceptance Form and Tool
RMC Risk Management Council
SSA Social Security Administration
Treasury Department of the Treasury
TSA Transportation Security Administration
VA Department of Veterans Affairs
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Page 1 GAO-17-63 Enterprise Risk Management
441 G St. N.W.
Washington, DC 20548
December 1, 2016
The Honorable Jason Chaffetz
Chairman
The Honorable Elijah E. Cummings
Ranking Member
Committee on Oversight and Government Reform
House of Representatives
Federal government leaders manage complex and inherently risky
missions across their organizations, such as protecting Americans from
health threats, preparing for and responding to natural disasters, building
and managing safe transportation systems, advancing scientific discovery
and space exploration, maintaining a safe workplace, and addressing
security threats. Managing these and other complex challenges, requires
effective leadership and management tools and commitment to delivering
successful outcomes in highly uncertain environments.
While it is not possible to eliminate all uncertainties, it is possible to put in
place strategies to better plan for and manage them. Enterprise Risk
Management (ERM) is one tool that can assist federal leaders in
anticipating and managing risks, as well as considering how multiple risks
in their agency can present even greater challenges and opportunities
when examined as a whole. Risk is the effect of uncertainty on objectives
with the potential for either a negative outcome or a positive outcome or
opportunity. The Office of Management and Budget (OMB) defines ERM
as an effective agency-wide approach to addressing the full spectrum of
the organization’s significant internal and external risks by understanding
the combined impact of risks as an interrelated portfolio, rather than
addressing risks only within silos. An example of an agency enterprise
risk is unfilled mission critical positions across the entire organization that
when examined as a whole could threaten the accomplishment of the
mission.
We first issued our risk management framework in 2005 related to
homeland security efforts for assessing threats and taking appropriate
steps to deal with them.
1
At that time, there was no established
1
GAO, Risk Management: Further Refinements Needed to Assess Risks and Prioritize
Protective Measures at Ports and Critical Infrastructure, GAO-06-91 (Washington, D.C.:
Dec. 15, 2005).
Letter
Page 2 GAO-17-63 Enterprise Risk Management
universally agreed upon set of requirements or processes for a risk
management framework specifically related to homeland security and
combating terrorism. We developed the 2005 framework with five major
phases that helped us assess how the Department of Homeland Security
(DHS) was applying risk management.
In July 2016, OMB issued an update to Circular A-123 requiring federal
agencies to implement ERM to better ensure their managers are
effectively managing risks that could affect the achievement of agency
strategic objectives.
2
Even before OMB required agencies to adopt ERM,
several agencies, after facing significant risks to their mission, were
implementing ERM to address risk-based issues and improve their ability
to respond to future risks. For example:
• The Office of Federal Student Aid (FSA) in the Department of
Education (Education) adopted ERM in 2004, in part, according to
documents we reviewed, to help address long-standing risks including
poor financial management and internal controls, which led us to
place it on our High-Risk List between 1990 and 2005.
3
• The Internal Revenue Service (IRS) adopted an ERM program in
2013 to address issues related to the review of tax-exempt
applications cited in a Department of the Treasury (Treasury)
Inspector General for Tax Administration report that would improve
IRS operations broadly, as well as provide a common framework for
capturing, reporting, and addressing risk areas, and improve the
timeliness of reporting identified risks to the IRS Commissioner, IRS
leaders, and external stakeholders, such as Congress.
4
• The Office of Public and Indian Housing (PIH) at the Department of
Housing and Urban Development (HUD) finalized its ERM framework
and implementation plans in 2014. This was done in response to
several high profile financial and compliance issues with public
housing authorities, as well as concerns over the completeness of its
2
OMB, Management’s Responsibility for Enterprise Risk Management and Internal
Control, Circular No. A-123, (July 15, 2016).
3
In 2005, FSA was removed from our High-Risk List, not just as a result of adopting ERM,
but also through a combination of leadership commitment, capacity to resolve the risk, the
development of a corrective action plan, monitoring of the corrective measures, and
demonstrated progress in resolving the high-risk area.
4
IRS, Charting a Path Forward: Initial Assessment and Plan of Action (Washington, D.C.:
June 24, 2013).
Page 3 GAO-17-63 Enterprise Risk Management
Federal Managers' Financial Integrity Act (FMFIA) certifications
including internal controls and risk management practices, according
to agency officials.
5
We performed our work for this report under the authority of the
Comptroller General to conduct evaluations to assist Congress with its
oversight responsibilities. Our objectives were to (1) update our risk
management framework to more fully include evolving requirements and
essential elements for federal ERM, and (2) identify good practices that
selected agencies were taking that illustrate those essential elements. We
also considered views of subject matter specialists with current
experience in ERM. See appendix I for the list of subject matter
specialists who advised us in our review of the practices.
To adapt our 2005 risk management framework to focus on ERM, we
identified essential elements needed to execute ERM and assist agencies
as they implement and sustain their ERM programs that are generally
consistent with other commonly used ERM frameworks, such as the ISO
31000 Risk Management Principles and Guidelines and the 2004 COSO
Enterprise Risk Management - Integrated Framework.
6
When we shared
these essential elements with subject matter specialists, they confirmed
that they represent the critical elements of the ERM process.
To identify good practices in using ERM, we analyzed and synthesized
ERM literature using ProQuest, First Search, and Scopus bibliographic
databases in public and business sources.
7
We validated these good
practices with subject matter specialists with knowledge specific to the
use of ERM in government settings, and, based on their suggestions, we
refined the practices. We then considered the essential elements of ERM
relative to our identified good practices and determined how these
5
31 U.S.C. § 3512.7
6
International Organization for Standardization (ISO), ISO 31000-Risk Management
Principles and Guidelines, (ISO, Nov.15, 2009), and Committee of Sponsoring
Organizations of the Treadway Commission (COSO), and COSO, Enterprise Risk
Management-Integrated Framework, 2004. COSO has since updated ERM framework,
Enterprise Risk Management-Aligning Strategy with Performance, exposure draft issued
in June 2016, but we did not include this in our analysis.
7
In the bibliographic database search, we used the following terms, enterprise risk
management, best practices, leading practices, government, and public sector, for years
2005 through 2015, and searched in scholarly and trade journals, conference
proceedings, and dissertations and theses.
Page 4 GAO-17-63 Enterprise Risk Management
practices generally fit with the essential elements as a way to assist
agencies as they implemented ERM.
To identify what agencies were doing consistent with our essential
elements and how their good practices were used in implementing ERM,
we used a semi-structured interview protocol and spoke with officials
representing 21 of the 24 executive branch agencies covered in the Chief
Financial Officers (CFO) Act of 1990, as amended.
8
Three agencies did
not participate in interviews but provided us with written responses to our
questions, including the Departments of Agriculture and the Interior and
the Social Security Administration. We asked each of the 24 agencies
whether or not the agency had ERM in place and their perspectives on
ERM.
To identify case illustrations of the good practices, we reviewed
information from agency interviews and documentation they provided
about their ERM practices. From the ERM practices of 24 CFO Act
agencies and their component agencies, we selected examples that best
illustrated our essential elements and good practices. In conducting the
case illustrations, we interviewed agency officials and reviewed agency
documentation about their use of ERM. We selected examples from nine
agencies including the Department of Commerce (Commerce) and its
component bureaus the National Institute of Standards and Technology
(NIST) and the National Oceanic and Atmospheric Administration
(NOAA), DHS’s Transportation Security Administration (TSA), PIH, the
Office of Personnel Management (OPM), Treasury and the IRS, and FSA.
We also interviewed OMB officials from the offices involved in the update
of Circular A-123, the Office of Performance and Personnel Management
and the Office of Federal Financial Management, to gain their
perspectives on agencies’ implementation of ERM.
We conducted this performance audit from June 2015 to December 2016
in accordance with generally accepted government auditing standards.
8
31 U.S.C. § 901(b). The 24 CFO Act agencies, generally the largest federal agencies,
are the Departments of Agriculture, Commerce, Defense, Education, Energy, Health and
Human Services, Homeland Security, Housing and Urban Development, the Interior,
Justice, Labor, State, Transportation, the Treasury, and Veterans Affairs, as well as the
Agency for International Development, Environmental Protection Agency, General
Services Administration, National Aeronautics and Space Administration, National Science
Foundation, Nuclear Regulatory Commission, Office of Personnel Management, Small
Business Administration, and Social Security Administration.
Page 5 GAO-17-63 Enterprise Risk Management
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.
ERM allows management to understand an organization’s portfolio of top-
risk exposures, which could affect the organization’s success in meeting
its goal. As such, ERM is a decision-making tool that allows leadership to
view risks from across an organization’s portfolio of responsibilities. ERM
recognizes how risks interact (i.e., how one risk can magnify or offset
another risk), and also examines the interaction of risk treatments
(actions taken to address a risk), such as acceptance or avoidance. For
example, treatment of one risk in one part of the organization can create
a new risk elsewhere or can affect the effectiveness of the risk treatment
applied to another risk. ERM is part of overall organizational governance
and accountability functions and encompasses all areas where an
organization is exposed to risk (financial, operational, reporting,
compliance, governance, strategic, reputation, etc.).
In July 2016, OMB updated its Circular No. A-123 guidance to establish
management’s responsibilities for ERM, as well as updates to internal
control in accordance with Standards for Internal Control in the Federal
Government.
9
OMB also updated Circular No. A-11, Preparation,
Submission, and Execution of the Budget in 2016 and refers agencies to
Circular No. A-123 for implementation requirements for ERM.
10
Circular
No. A-123 guides agencies on how to integrate organizational
performance and ERM to yield an “enterprise-wide, strategically-aligned
portfolio view of organizational challenges that provides better insight
about how to most effectively prioritize resource allocations to ensure
successful mission delivery.” The updated requirements in Circulars A-
123 and A-11 help modernize existing management efforts by requiring
agencies to implement an ERM capability coordinated with the strategic
planning and strategic review process established by the GPRA
Modernization Act of 2010 (GPRAMA), and with the internal control
processes required by the FMFIA and in our Standards for Internal
9
GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014).
10
OMB, Circular No. A-11, Preparation, Submission, and Execution of the Budget pt 6,§§
270 (July 2016).
Background
Page 6 GAO-17-63 Enterprise Risk Management
Control in the Federal Government.
11
This integrated governance
structure is designed to improve mission delivery, reduce costs, and focus
corrective actions towards key risks.
More specifically, Circular No. A-123 discusses both internal control and
ERM and how these fit together to manage agency risks. Our Standards
for Internal Control in the Federal Government describes internal control
as a process put in place by an entity’s oversight body, management, and
other personnel that provides reasonable assurance that objectives
related to operations, compliance, and reporting will be achieved, and
serves as the first line of defense in safeguarding assets.
12
Internal
control is also part of ERM and used to manage or reduce risks in an
organization. Prior to implementing ERM, risk management focused on
traditional internal control concepts to managing risk exposures. Beyond
traditional internal controls, ERM promotes risk management by
considering its effect across the entire organization and how it may
interact with other identified risks.
13
Additionally, ERM also addresses
other topics such as setting strategy, governance, communicating with
stakeholders, and measuring performance, and its principles apply at all
levels of the organization and across all functions.
14
Implementation of OMB circulars is expected to engage all agency
management, beyond the traditional ownership of A-123 by the Chief
Financial Officer community. According to the A-123 Circular, it requires
leadership from the agency Chief Operating Officer (COO) and
Performance Improvement Officer (PIO) or other senior official with
responsibility for the enterprise, and close collaboration across all agency
mission and mission-support functions.
15
The A-123 guidance also
11
Pub. L. No. 111-352, 124 Stat. 3866 (Jan. 4, 2011).
12
GAO-14-704G.
13
For additional discussion about ERM in the federal government, see Dr. Karen Hardy,
Enterprise Risk Management, A Guide for Government Professionals, (San Francisco,
CA: John Wiley & Sons, Inc., 2015), and Thomas H. Stanton and Douglas W. Webster,
Managing Risk and Performance, (Hoboken, NJ: John Wiley & Sons, Inc., 2014).
14
See COSO, Enterprise Risk Management-Aligning Strategy with Performance, exposure
draft issued in June 2016, for additional information on ERM and its relationship to internal
controls.
15
Agencies are required to designate a senior executive within the agency as a
Performance Improvement Officer (PIO), who reports directly to the COO and has
responsibilities to assist the agency head and COO with performance management
activities.
Page 7 GAO-17-63 Enterprise Risk Management
requires agencies to create a risk profile that helps them identify and
assess risks arising from mission and mission-support operations, and
consider those risks as part of the annual strategic review process.
Circular A-123 requires that agencies’ risk profiles include risks to
strategic, operations, reporting and compliance objectives.
A federal interagency group of ERM practitioners developed a Playbook
released through the Performance Improvement Council (PIC) and the
Chief Financial Officers Council (CFOC) in July 2016 to provide federal
agencies with a resource to support ERM.
16
In particular, the Playbook
assists them in implementing the required elements in the updated A-123
Circular.
17
To assist agencies in better assessing challenges and opportunities from
an enterprise-wide view, we have updated our risk management
framework first published in 2005 to more fully include recent experience
and guidance, as well as specific enterprise-wide elements.
18
As
mentioned previously, our 2005 risk management framework was
developed in the context of risks associated with homeland security and
combating terrorism. However, increased attention to ERM concepts and
their applicability to all federal agencies and missions led us to revise our
risk framework to incorporate ERM concepts that can help leaders better
address uncertainties in the federal environment, changing and more
complex operating environments due to technology and other global
factors, the passage of GPRAMA and its focus on overall performance
improvement, and stakeholders seeking greater transparency and
accountability. For many similar reasons, the Committee of Sponsoring
Organizations of the Treadway Commission (COSO) initiated an effort to
update its ERM framework for 2016, and the International Organization
16
U.S. CFO Council and Performance Improvement Council, Playbook: Enterprise Risk
Management for the U.S. Federal Government, (Washington, D.C.: Jul. 29, 2016).
17
GPRAMA established the Performance Improvement Council (PIC) in law and included
additional responsibilities. The PIC is charged with assisting OMB to improve the
performance of the federal government. Among its other responsibilities, the PIC is to
facilitate the exchange among agencies of useful performance improvement practices and
work to resolve government-wide or crosscutting performance issues. The Chief Financial
Officers Council (CFOC) is comprised of federal CFOs, senior officials at OMB, and the
U.S. Treasury to address the critical issues in federal financial management with
collaborative leadership
18
GAO-06-91.
Updated ERM
Framework Provides
Assistance to
Agencies as They
Implement ERM
Page 8 GAO-17-63 Enterprise Risk Management
for Standardization (ISO) plans to update its ERM framework in 2017.
Further, as noted, OMB has now incorporated ERM into Circulars A-11
and A-123 to help improve overall agency performance.
We identified six essential elements to assist federal agencies as they
move forward with ERM implementation. Figure 1 below shows how
ERM’s essential elements fit together to form a continuing process for
managing enterprise risks. The absence of any one of the elements
below would likely result in an agency incompletely identifying and
managing enterprise risk. For example, if an agency did not monitor risks,
then it would have no way to ensure that it had responded to risks
successfully. There is no “one right” ERM framework that all organizations
should adopt. However, agencies should include certain essential
elements in their ERM program.
Figure 1: Essential Elements of Federal Government Enterprise Risk Management
Page 9 GAO-17-63 Enterprise Risk Management
Below we describe each essential element in more detail, why it is
important, and some actions necessary to successfully build an ERM
program.
1. Align the ERM process to agency goals and objectives. Ensure
the ERM process maximizes the achievement of agency mission and
results. Agency leaders examine strategic objectives by regularly
considering how uncertainties, both risks and opportunities, could
affect the agency’s ability to achieve its mission. ERM subject matter
specialists confirmed that this element is critical because the ERM
process should support the achievement of agency goals and
objectives and provide value for the organization and its stakeholders.
By aligning the ERM process to the agency mission, agency leaders
can address risks via an enterprise-wide, strategically-aligned portfolio
rather than addressing individual risks within silos. Thus, agency
leaders can make better, more effective decisions when prioritizing
risks and allocating resources to manage risks to mission delivery.
While leadership is integral throughout the ERM process, it is an
especially critical component of aligning ERM to agency goals and
objectives because senior leaders have an active role in strategic
planning and accountability for results.
2. Identify risks. Assemble a comprehensive list of risks, both threats
and opportunities, that could affect the agency from achieving its
goals and objectives. This element of ERM systematically identifies
the sources of risks as they relate to strategic objectives by examining
internal and external factors that could affect their accomplishment. It
is important that risks either can be opportunities for, or threats to,
accomplishing strategic objectives. The literature we reviewed, as well
as subject matter specialists, pointed out that identifying risks in any
organization is challenging for employees, as they may be concerned
about reprisals for highlighting "bad news."
Risks to objectives can often be grouped by type or category. For
example, a number of risks may be grouped together in categories
such as strategic, program, operational, reporting, reputational,
technological, etc. Categorizing risks can help agency leaders see
how risks relate and to what extent the sources of the risks are
similar. The risks are linked to relevant strategic objectives and
documented in a risk register or some other comprehensive format
that also identifies the relevant source and a risk owner to manage the
treatment of the risk. Comprehensive risk identification is critical even
if the agency does not control the source of the risk. The literature and
subject matter specialists we consulted told us that it is important to
Page 10 GAO-17-63 Enterprise Risk Management
build a culture where all employees can effectively raise risks. It is
also important for the risk owner to be the person who is most
knowledgeable about the risk, as this person is likely to have the most
insight about appropriate ways to treat the risk.
3. Assess risks. Examine risks considering both the likelihood of the
risk and the impact of the risk on the mission to help prioritize risk
response. Agency leaders, risk owners, and subject matter experts
assess each risk by assigning the likelihood of the risk’s occurrence
and the potential impact if the risk occurs. It is important to use the
best information available to make the risk assessment as realistic as
possible. Risk owners may be in the best position to assess risks.
Risks are ranked based on organizational priorities in relation to
strategic objectives. Risks are ranked based on organizational
priorities in relation to strategic objectives. Agencies need to be
familiar with the strengths of their internal control when assessing
risks to determine whether the likelihood of a risk event is higher or
lower based on the level of uncertainty within the existing control
environment. Senior leaders determine if a risk requires treatment or
not. Some identified risks may not require treatment at all because
they fall within the agency's risk appetite, defined as how much risk
the organization is willing to accept relative to mission achievement.
The literature we reviewed and subject matter specialists noted that
integrating ERM efforts with strategic planning and organizational
performance management would help an organization more
effectively assess its risks with respect to the impact on the mission.
4. Select risk response. Select a risk treatment response (based on
risk appetite) including acceptance, avoidance, reduction, sharing, or
transfer. Agency leaders review the prioritized list of risks and select
the most appropriate treatment strategy to manage the risk. When
selecting the risk response, subject matter experts noted that it is
important to involve stakeholders that may also be affected, not only
by the risk, but also by the risk treatment. Subject matter specialists
also told us that when agencies discuss proposed risk treatments,
they should also consider treatment costs and benefits. Not all
treatment strategies manage the risk entirely; there may be some
residual risk after the risk treatment is applied. Senior leaders need to
decide if the residual risk is within their risk appetite and if additional
treatment will be required. The risk response should also fit into the
management structure, culture, and processes of the agency, so that
ERM becomes an integral part of regular management functions. One
subject matter specialist suggested that maximize opportunity should
also be included as a risk treatment response, so that leaders may
Page 11 GAO-17-63 Enterprise Risk Management
capture the positive outcomes or opportunities associated with some
risks.
5. Monitor Risks. Monitor how risks are changing and if responses are
successful. After implementing the risk response, agencies must
monitor the risk to help ensure that the entire risk management
process remains current and relevant. The literature we reviewed also
suggests using a risk register or other comprehensive risk report to
track the success of the treatment for managing the risk. Senior
leaders and risk owners review the effectiveness of the selected risk
treatment and change the risk response as necessary. Subject matter
specialists noted that a good practice includes continuously
monitoring and managing risks. Monitoring should be a planned part
of the ERM process and can involve regular checking as part of
management processes or part of a periodic risk review. Senior
leaders also could use performance measures to help track the
success of the treatment, and if it has had the desired effect on the
mission.
6. Communicate and Report on Risks. Communicate risks with
stakeholders and report on the status of addressing the risks.
Communicating and reporting risk information informs agency
stakeholders about the status of identified risks and their associated
treatments, and assures them that agency leaders are managing risk
effectively. In a federal setting, communicating risk is important
because of the additional transparency expected by Congress,
taxpayers, and other relevant stakeholders. Communicating risk
information through a dedicated risk management report or integrating
risk information into existing organizational performance management
reports, such as the annual performance and accountability report,
may be useful ways of sharing progress on the management of risk.
The literature we reviewed showed and subject matter specialists
confirmed that sharing risk information is a good practice. However,
concerns may arise about sharing overly specific information or risk
responses that would rely on sensitive information. Safeguards should
be put in place to help secure information that requires careful
management, such as information that could jeopardize security,
safety, health, or fraud prevention efforts. In this case, agencies can
help alleviate concerns by establishing safeguards, such as
communicating risk information only to appropriate parties, encrypting
sensitive data, authorizing users' level of rights and privileges, and
providing information on a need-to-know basis.
Page 12 GAO-17-63 Enterprise Risk Management
We identified six good practices that nine agencies are implementing that
illustrate ERM’s essential elements. The selected good practices are not
all inclusive, but represent steps that federal agencies can take to initiate
and sustain an effective ERM process, as well as practices that can apply
to more advanced agencies as their ERM processes mature. We expect
that as federal experiences with ERM evolve, we will be able to refine
these practices and identify additional ones.
Below in table 1, we identify the essential elements of ERM and the good
practices that support each particular element that agencies can use to
support their ERM programs. The essential elements define what ERM is
and the good practices and case illustrations described in more detail
later in this report provide ways that agencies can effectively implement
ERM. The good practices may fit with more than one essential element,
but are shown in the table next to the element to which they most closely
relate.
Emerging Good
Practices Are Being
Used at Selected
Agencies to
Implement ERM
Page 13 GAO-17-63 Enterprise Risk Management
Table 1: Essential Elements and Associated Good Practices of Federal Government Enterprise Risk Management (ERM)
Element
Good Practice
Align ERM process to goals and objectives
Ensure the ERM process maximizes the
achievement of agency mission and results.`
Leaders Guide and Sustain ERM Strategy
Implementing ERM requires the full engagement and commitment of senior
leaders, which supports the role of leadership in the agency goal setting process,
and demonstrates to agency staff the importance of ERM.
Identify Risks
Assemble a comprehensive list of risks, both
threats and opportunities, that could affect the
agency from achieving its goals and objectives.
Develop a Risk-Informed Culture to Ensure All Employees Can Effectively
Raise Risks
Developing an organizational culture to encourage employees to identify and
discuss risks openly is critical to ERM success.
Assess Risks
Examine risks considering both the likelihood of
the risk and the impact of the risk to help
prioritize risk response.
Integrate ERM Capability to Support Strategic Planning and Organizational
Performance Management
Integrating the prioritized risk assessment into strategic planning and
organizational performance management processes helps improve budgeting,
operational, or resource allocation planning.
Select Risk Response
Select risk treatment response (based on risk
appetite) including acceptance, avoidance,
reduction, sharing, or transfer.
Establish a Customized ERM Program Integrated into Existing Agency
Processes
Customizing ERM helps agency leaders regularly consider risk and select the most
appropriate risk response that fits the particular structure and culture of an agency.
Monitor Risks
Monitor how risks are changing and if responses
are successful.
Continuously Manage Risks
Conducting the ERM review cycle on a regular basis and monitoring the selected
risk response with performance indicators allows the agency to track results and
impact on the mission, and whether the risk response is successful or requires
additional actions.
Communicate and Report on Risks
Communicate risks with stakeholders and report
on the status of addressing the risk.
Share Information with Internal and External Stakeholders to Identify and
Communicate Risks
Sharing risk information and Incorporating feedback from internal and external
stakeholders can help organizations identify and better manage risks, as well as
increase transparency and accountability to Congress and taxpayers.
Source: GAO. | GAO-17-63
The following examples illustrate how selected agencies are guiding and
sustaining ERM strategy through leadership engagement. These include
how they have:
• designated an ERM leader or leaders
• committed organization resources to support ERM, and
• set organizational risk appetite.
This good practice relates most closely to Align ERM Process to Goals
and Objectives as shown in table 1.
Good Practice: Guide and
Sustain ERM Strategy
through Leadership
Engagement
Page 14 GAO-17-63 Enterprise Risk Management
According to the Chief Financial Officer’s Council (CFOC) and
Performance Improvement Council (PIC) Playbook, strong leadership at
the top of the organization, including active participation in oversight, is
extremely important for achieving success in an ERM program. To
manage ERM activities, leadership may choose to designate a Chief Risk
Officer (CRO) or other risk champion to demonstrate the importance of
risk management to the agency and to implement and manage an
effective ERM process across the agency. The CRO role includes leading
the ERM process; involving those that need to participate and holding
them accountable; ensuring that ERM reviews take place regularly;
obtaining resources, such as data and staff support if needed; and
ensuring that risks are communicated appropriately to internal and
external stakeholders, among other things. For example, at TSA, the
CRO serves as the principal advisor on all risks that could affect TSA’s
ability to perform its mission, according to the August 2014 TSA ERM
Policy Manual. The CRO reports directly to the TSA Administrator and the
Deputy Administrator. In conjunction with the Executive Risk Steering
Committee (ERSC) composed of Assistant Administrators who lead
TSA’s program and management offices, the CRO leads TSA in
conducting regular enterprise risk assessments of TSA business
processes or programs, and overseeing processes that identify, assess,
prioritize, respond to, and monitor enterprise risks.
19
Specifically, the August 2014 TSA ERM Policy Manual describes ERSC’s
role to “oversee the development and implementation of processes used
to analyze, prioritize, and address risks across the agency including
terrorism threats facing the transportation sector, along with non-
operational risks that could impede its ability to achieve its strategic
objectives.” The TSA CRO told us that its ERSC provides an opportunity
for all Assistant Administrators to get together to have risk conversations.
For example, the CRO recently recommended that the ERSC add
implementation of the agency’s new financial management system to the
risk register.
19
Assistant Administrators on the ERSC are from the offices of Acquisition, Finance and
Administration, Human Capital, Information Technology, Global Strategies, Intelligence
and Analysis, Law Enforcement/Federal Air Marshal Service, Security Capabilities,
Security Operations, and Security Policy and Industry Engagement, Training and
Development, Professional Responsibility, Legislative Affairs, Strategic Communication
and Public Affairs, Investigations, Civil Rights and Chief Counsel.
TSA’s ERM Process Is Led by
a Chief Risk Officer and
Senior
-Level Executive Risk
Steering Committee
Page 15 GAO-17-63 Enterprise Risk Management
According to the CRO, the system’s implementation was viewed as the
responsibility of the Chief Financial Officer (CFO) and Chief Information
Officer (CIO). However, the implementation needed to be managed at the
enterprise-level because if it was not successfully implemented, the entire
enterprise would be affected. The CRO proposed adding the
implementation of the new financial management system to the TSA risk
register to give the issue broader visibility. The ERSC unanimously
concurred with the recommendation, and staff from the Office of Finance
and Administration—the risk owner—will brief the ERSC periodically on
the status of the effort.
According to TSA’s ERM Policy Manual, the CRO leads the overall ERM
process, while the ERSC brings knowledge and expertise from their
individual organizations to help identify and prioritize risks and
opportunities of TSA’s overall approach to operations. While the CRO and
ERSC play critical roles in ERM oversight, the relevant program offices
still own risks and execute risk management, according to the TSA ERM
Policy Manual.
To launch and sustain a successful ERM program, organizational
resources are needed to help implement leadership’s vision of ERM for
the agency and ensure its ongoing effectiveness. For example, when FSA
began its ERM program in 2004, the Chief Operating Officer (COO)
decided to hire a CRO and give him full responsibility to establish the
ERM organization and program and implement it across the organization.
According to documents we reviewed, the CRO dedicated resources to
define the goal and purpose of the ERM program and met with key
leaders across the agency to socialize the program. Agency leadership
hired staff to establish the ERM program and provided risk management
training to business unit senior leaders and their respective staff. Our
review of documents shows that the FSA continues to provide ERM
training to senior staff and all FSA employees and also participates in an
annual FSA Day, so employees can learn more about all business units
across FSA including the Risk Management Office and its ERM
implementation. In September 2016, the FSA CRO told us that the Risk
Management Office had a staff of 19 full-time equivalent (FTE)
FSA Committed Resources to
Support ERM
Page 16 GAO-17-63 Enterprise Risk Management
employees.
20
FSA continues to provide resources to its ERM program
and has subsequently structured its leadership by involving two senior
leaders and a risk management committee to manage ERM processes.
According to the CRO, its risk committee guides the ERM process, tracks
the agency’s progress in managing risks, and increases accountability for
outcomes.
Both the CRO, the Chairman of the Risk Management Committee and the
Senior Risk Advisor report directly to the FSA Chief Operating Officer
(COO). The CRO manages the day-to-day aspects of assessing risks for
various internal FSA operations, programs and initiatives, as well as
targeting risk assessments on specific high-risk issues, such as the
closing of a large for-profit school. The Chairman of the Risk
Management Committee and the Senior Risk Advisor advise the COO by
identifying and analyzing external risks that could affect the
accomplishment of FSA’s strategic objectives. The Senior Risk Advisor
also gathers and disseminates information internally that relates to FSA
risk issues, such as cybersecurity or financial issues. In addition, he
serves as the Chair of the Risk Management Committee and leads its
monthly meetings.
Other senior leaders and members involved with the Risk Management
Committee were drawn from across the agency and demonstrate the
importance of ERM to FSA. Specifically, the committee is chaired by the
independent senior risk advisor and comprised of the CRO, COO, CFO,
Chief Information Officer (CIO), General Manager of Acquisitions, Chief
Business Operations Officer, Chief of Staff, Chief Compliance Officer,
Deputy COO, and Chief Customer Experience Officer, and meets
monthly. Agency officials said that the participation of the COO, along
with that of the other functional chiefs, indicates ERM’s importance and
the commitment of staff—namely these executives–in the effort.
20
According to OMB, Preparation, Submission and Execution of the Budget, OMB Circular
A-11 (July 1, 2016), FTE employment means the total number of regular straight-time
hours worked (i.e., not including overtime or holiday hours worked) by employees divided
by the number of compensable hours applicable to each fiscal year. Annual leave, sick
leave, compensatory time off and other approved leave categories are considered “hours
worked” for purposes of defining full-time equivalent employment that is reported in the
employment summary.
Page 17 GAO-17-63 Enterprise Risk Management
Developing an agency risk appetite requires leadership involvement and
discussion. The organization should develop a risk appetite statement
and embed it in policies, procedures, decision limits, training, and
communication, so that it is widely understood and used by the agency.
Further, the risk appetite may vary for different activities depending on the
expected value to the organization and its stakeholders. To that end, the
National Institute of Standards and Technology (NIST) ERM Office
surveyed its 33-member senior leadership team to measure risk appetite
among its senior leaders. Without a clearly defined risk appetite, NIST
could be taking risks well beyond management’s comfort level, or passing
up strategic opportunities by assuming its leaders were risk averse. The
survey objectives were to “assess management familiarity and use of risk
management principles in day-to-day operations and to solicit
management perspectives and input on risk appetite, including their
opinions on critical thresholds that will inform the NIST enterprise risk
criteria.”
Survey questions focused on the respondent’s self-reported
understanding of a variety of risk management concepts and asked
respondents to rate how they consider risk with respect to management,
safety, and security. The survey assessed officials’ risk appetite across
five areas: NIST Goal Areas, Strategic Objectives, Core Products and
Services, Mission Support Functions, and Core Values. See figure 2 for
the rating scale that NIST used to assess officials’ appetite for risk in
these areas.
National Institute of Standards
and Technology Surveyed
Leaders
’ Views of Risk
Appetite
Page 18 GAO-17-63 Enterprise Risk Management
Figure 2: National Institute of Standards and Technology Leadership Risk Appetite
Survey Scale
Page 19 GAO-17-63 Enterprise Risk Management
The survey results revealed a disconnect between the existing and
desired risk appetite for mission support functions. According to NIST
officials, respondents believed the bureau needed to accept more risk to
allow for innovation within mission support functions. According to
agency officials, to better align risk appetite with mission needs, the NIST
Director tasked the leadership team with developing risk appetite levels
for those areas with the greatest disagreement between the existing and
desired risk appetite, while still remaining compliant with laws and
regulations. Agency officials told us the NIST ERM Office plans to
address this topic via further engagement with senior managers and
subject matter experts.
The following examples illustrate how selected agencies are developing a
risk-informed culture, including how they have:
• encouraged employees to discuss risks openly,
• trained employees on ERM approach
• engaged employees in ERM efforts, and
• customized ERM tools for organizational mission and culture.
This good practice relates most closely to Identify Risks, one of the
Essential Elements of Federal Government ERM shown in table 1.
Successful ERM programs find ways to develop an organizational culture
that allows employees to openly discuss and identify risks, as well as
potential opportunities to enhance organizational goals or value. The
CFOC and PIC Playbook also supports this notion that once ERM is built
into the agency culture, the agency can learn from managed risks or, near
misses, using them to improve how it identifies and analyzes risk. For
example, Commerce officials sought to embed a culture of risk
awareness across the department by defining cascading roles of
leadership and responsibility for ERM across the department and for its
12 bureaus. Additionally, an official noted that Commerce leveraged this
forum to share bureau best practices; develop a common risk lexicon;
and address cross-bureau risks, issues and concerns regarding ERM
practice and implementation. According to the updated ERM program
policy, these roles should support the ERM program and promote a risk
management culture. They also help promote transparency, oversight,
and accountability for a successful ERM program.
Good Practice: Develop a
Risk-Informed Culture to
Ensure All Employees Can
Effectively Raise Risks
Commerce Defined Roles and
Responsibilities Across the
Ag
ency to Build a Risk
Management Culture and
Guide Its ERM Process
Page 20 GAO-17-63 Enterprise Risk Management
Table 2 shows the ERM roles and set of responsibilities within Commerce
and how they support a culture of risk awareness at each level.
Table 2: Department of Commerce Roles and Selected Responsibilities for Enterprise Risk Management (ERM)
Department Level
Role
Selected Responsibilities
Executive Governance Committee composed of senior level
department representatives
Provide policy and management oversight and advice regarding ERM
implementation and operations; facilitate governance and risk
consideration as element of department decision-making; inform
department management of progress towards ERM maturity and
efficacy of policy
Risk Management Council
Recommend and advise on development and implementation of
processes for identifying, assessing, treating, monitoring, and reporting
organizational risks; foster sound risk management practices
throughout the department
Office of Program Evaluation and Risk Management
(OPERM)
Leads the department in increasing knowledge and understanding of
risk; coordinate risk management efforts; monitor execution of
enterprise risk policy across the department
Bureaus and Departmental Offices
Carry out risk management processes and integrate into day-to-day
operations as a means of institutionalizing risk management across
the department
Office of Financial Management
Oversee, assess, and test internal controls over financial reporting as
part of the requirements outlined in Appendix A of OMB Circular A-123
Bureau Level
Role
Selected Responsibilities
Bureau Heads
Appoint a Risk Management Officer; ensure bureau implements ERM
in accordance with policy; ensure timely submission of annual
assurance statement required by the Federal Managers’ Financial
Integrity Act
Risk Management Officers
Serve as champions for overseeing implementation, integration, and
management of ERM framework within bureau; serve on department
Risk Management Council; update bureau risk inventory annually and
elevate common or department-level risks to OPERM as needed;
oversee, assess, and report on bureau ERM maturity annually
Managers and Supervisors
Ensure that those with risk management responsibilities are properly
trained and that employees are aware of and follow sounds risk
management policies and practices
Employees
Manage risk within their area of responsibility
Source: Department of Commerce | GAO-17-63.
To successfully implement and sustain ERM, it is critical that staff, at all
levels, understand how the organization defines ERM, its subsequent
ERM approach, and organizational expectations on their involvement in
the ERM process. The CFOC and PIC Playbook also supports risk
awareness as previously stated because once ERM is built into the
HUD ERM Training
Emphasized Culture Changes
Needed to Raise Risks
Page 21 GAO-17-63 Enterprise Risk Management
agency culture, it can be possible to learn from managed risks and near
misses when risks materialize, and then used to improve the process of
identifying and analyzing risk in the future. Further, the Playbook
suggests that this culture change can only occur if top agency leaders
champion ERM and encourage the flow of information needed for
effective decision making. For example, to promote cultural change and
encourage employees to raise risks, PIH trained about half of its 1,500
employees in 2015. Agency officials told us that they plan to expand on
the 2015 training and provide training to all PIH employees after 2016.
The in-person PIH training includes several features of our identified ERM
good practices, such as leadership support and the importance of
developing a risk-informed culture. For example, the Principal Deputy
Assistant Secretary for PIH was visibly involved in the training and kicked
off the first of the five training modules using a video emphasizing ERM.
The training contained discussions and specific exercises dedicated to
the importance of raising and assessing risks and understanding the
leadership and employee roles in ERM. The first training module
emphasized the factors that can support ERM by highlighting the
following cultural characteristics.
• ERM requires a culture that supports the reporting of risks.
• ERM requires a culture of open feedback.
• A risk-aware culture enables all HUD staff to speak up and then be
listened to by decision-makers.
• Leadership encourages the sharing of risks.
By focusing on the importance of developing a risk aware culture in the
first ERM training module, PIH officials emphasized that ERM requires a
cultural transformation for its success. To enable all employees to
participate and benefit from the training, PIH officials recorded the
modules and made them available on You-Tube.
Our literature review found that building a risk-aware culture supports the
ERM process by encouraging staff across the organization to feel
comfortable raising risks. Involving employees in identifying risks allows
the agency to increase risk awareness and generate solutions to those
identified risks. Some ways to strengthen this culture include the
presence of risk management communities of practice, the development
and dissemination of a risk lexicon agencywide, and conducting forums
that enable frontline staff to raise risk-related strategic or operational
concerns with leadership and senior management. For example, TSA’s
TSA Sponsored Several
Programs t
o Raise Risk
Awareness Among Employees
Page 22 GAO-17-63 Enterprise Risk Management
Office of the Chief Risk Officer (OCRO) has sponsored a number of
activities related to raising risk awareness.
First, TSA has established a risk community of interest open to any
employee in the organization, and has hosted speakers on ERM topics.
These meetings have provided an opportunity for employees across the
administration to learn and discuss risks and become more
knowledgeable about the types of issues that should be raised to
management.
Second, TSA created a risk lexicon, so that all staff involved with ERM
would use and understand risk terminology similarly. The lexicon
describes core concepts and terms that form the basis for the TSA ERM
framework. TSA incorporated the ERM lexicon into the TSA ERM Policy
Manual.
Third, in January 2016, TSA started a vulnerability management process
for offices and functions with responsibility for identifying or addressing
security vulnerabilities. Officials told us that this new process is intended
to help raise risks from the bottom up so that they receive top level
monitoring. According to the December 2015 TSA memo we reviewed,
the process centralizes tracking of vulnerability mitigation efforts with the
CRO, creates a central repository for vulnerability information and
tracking, provides executive engagement and oversight of enterprise
vulnerabilities by the Executive Risk Steering Committee (ERSC),
promotes cross-functional collaboration across TSA offices, and requires
the collaboration of Assistant Administrators and their respective staff
across the Agency.
See figure 3 below for an overview of how TSA’s vulnerability
management process is intended to work. The CRO told us that
employees from all levels can report risks with broader, enterprise-level
application to the OCRO. Once the OCRO decides the risks are at an
enterprise level, the office assembles a working group and submits ideas
to the ERSC to decide at what level it should be addressed. The risk is
then assigned to an executive who will be required to provide a status
update.
Page 23 GAO-17-63 Enterprise Risk Management
Figure 3: Transportation Security Administration Vulnerability Management
Process
Fourth, officials in the TSA OCRO told us that TSA has established points
of contact in every program office, referred to as ERM Liaisons. Each
ERM Liaison is a senior level official that represents their program office
Page 24 GAO-17-63 Enterprise Risk Management
in all ERM related activities. TSA also implemented risk management
awareness training to headquarters and field supervisors that covered
topics such as risk-based decision-making, risk assessment, and
situational awareness. Officials told us they are also embedding ERM
principles into existing training, so that employees will understand how
ERM fits into TSA operations.
Customizing ERM tools and templates can help ensure risk management
efforts fit agency culture and operations. For example, NIST tailored
certain elements of the Commerce ERM framework to better reflect the
bureau’s risk thresholds. Commerce has developed a set of standard risk
assessment criteria to help identify and rate risks, referred to as the
Commerce ERM Reference Card. NIST officials reported that some of the
safety and security terms used at Commerce differed from the terms used
at NIST and required tailoring to map to NIST’s existing safety risk
framework, which is a heavily embedded component of NIST operations
and culture. To better align to NIST, the NIST ERM Program split safety
and security risks into distinct categories when establishing a tailored
ERM framework for the bureau (see table 3).
According to agency officials, the NIST ERM Reference Card also
leverages American National Standards Institute guidelines, so it does not
introduce another separate and potentially conflicting set of terms.
Officials told us that these adaptations to the NIST ERM framework help
maintain continuity with the Commerce framework, but reflect the
particular mission, needs, and culture of NIST.
NIST Adapted the Commerce
ERM Framework to Reflect
Lab Safety Vocabulary
Appropriate to Its Culture
Page 25 GAO-17-63 Enterprise Risk Management
Table 3: Comparison of Department of Commerce (Commerce) and National Institute of Standards and Technology (NIST)
Enterprise Risk Management (ERM) Reference Cards
Risk Level
(lowest to
highest)
Commerce
Safety & Security
(includes IT security)
NIST
Safety
(of Personnel, the
Environment and
Public Health)
NIST
Security
(includes Cyber,
Personnel and
Physical Security)
1
No harm
Near miss. Minimal treatment
required.
Minimal Impact. Easily contained asset damage,
loss or harm.
2
Minor first aid treatment or
minor loss of Commerce
asset
Minor first aid treatment or
routine clean-up
Limited loss of NIST asset or temporary disruption
to operations. Slight facility/property damage or
harm.
3
Medical treatment required or
moderate loss of Commerce
asset.
Medical treatment beyond first
aid required, lost work day(s).
More than routine clean-up.
Moderate loss of NIST asset or moderate impact
to operations. More than slight facility/property
damage or harm.
4
Serious injury or major loss of
Commerce asset
Serious injury, temporary
disability. Temporary
environmental or public health
impact.
Major loss of NIST asset, including subsystem
loss, inability to perform essential functions or
serious facility/property damage or harm.
5
Death or permanent injury or
complete loss of Commerce
asset
Death or permanent disability.
Lasting environmental or
public health impact.
Catastrophic; unrecoverable major system/facility
loss or harm. Inability to perform multiple essential
functions.
Source: Department of Commerce. | GAO-17-63
The following examples illustrate how selected agencies are integrating
ERM capability to support strategic planning and organizational
performance management. These include how they have:
• incorporated ERM into strategic planning processes, and
• used ERM to improve information for agency decisions.
This good practice most closely relates to Assess Risks, one of the
Essential Elements of Federal Government ERM, shown in table 1.
Through ERM, an agency looks for opportunities that may arise out of
specific situations, assesses their risk, and develops strategies to achieve
positive outcomes. In the federal environment, agencies can leverage the
GPRAMA performance planning and reporting framework to help better
manage risks and improve decision making. For example, Treasury has
integrated ERM into its existing strategic planning and management
processes. According to our review of the literature and the subject matter
specialists we interviewed, using existing processes helps to avoid
creating overlapping processes. Further, by incorporating ERM this way,
Good Practice: Integrate
ERM Capability to Support
Strategic Planning and
Organizational
Performance Management
Treasury Used Risk
Discussions in Quarterly
Performance Reviews
Page 26 GAO-17-63 Enterprise Risk Management
risk management becomes an integral part of setting goals, including
agency priority goals (APG), ultimately achieving an organization’s
desired outcomes. Agencies can use regular performance reviews, such
as the quarterly performance reviews of APGs and annual leadership-
driven strategic objective review, to help increase attention on progress
towards the outcomes agencies are trying to achieve. According to OMB
Circular No. A-11, agencies are expected to manage risks and challenges
related to delivering the organization’s mission. The agency’s strategic
review is a process by which the agency should coordinate its analysis of
risk using ERM to make risk-aware decisions, including the development
of risk profiles as a component of the annual strategic review, identifying
risks arising from mission and mission-support operations, and providing
a thoughtful analysis of the risks an agency faces towards achieving its
strategic objectives. Instituting ERM can help agency leaders make risk-
aware decisions that affect prioritization, performance, and resource
allocation.
Treasury officials stated they integrated ERM into their quarterly
performance or data-driven reviews and strategic reviews, both of which
already existed. Officials stated this action has helped elevate and focus
risk discussions. Staff from the management office and individual bureaus
work together to complete the template slide, which is used to include a
risk element in their performance reviews. As part of this process, they
are assessing risk. See figure 4 for how risk is incorporated into
Treasury’s quarterly performance review (QPR) template. Officials stated
that they believe this approach to prepare for the data-driven review has
helped improve outcomes at Treasury. For example, according to agency
officials, Treasury used its QPR process to increase cybersecurity.
Treasury officials also told us that during the fall and the spring, each
Treasury bureau completes the data-driven review templates. Agency
officials are to use the summer data-driven review as an opportunity to
discuss budget formulation. In winter, they are to use the annual data-
driven review to show progress towards achieving strategic objectives.
21
According to agency officials, the strategic review examines and
assesses risks identified as part of the data-driven reviews and
aggregates and analyzes these results at the cross cutting strategic
21
OMB requires agencies to conduct leadership-driven, annual reviews of their progress
towards achieving each strategic objective—the outcome or impact the agency is
intending to achieve through its various programs and initiatives—established in their
strategic plans. These reviews are known as the strategic review.
Page 27 GAO-17-63 Enterprise Risk Management
objective level, which helps improve agency performance. Integrating
ERM into this existing data-driven review process avoids creating a
duplicative process and increases the focus on risk.
Figure 4: Department of the Treasury Quarterly Performance Review Templates
In another example, Treasury officials identified implementation of the
Digital Accountability and Transparency Act of 2014 (DATA Act) both at
Treasury and government-wide as a risk and established “Financial
Transparency” as one of its two APGs for fiscal years 2016 and 2017.
According to agency officials, incorporating risk management into the
data-driven review process sends a signal about the importance of the
DATA Act and brings additional leadership focus and scrutiny needed to
successfully implement the law.
Page 28 GAO-17-63 Enterprise Risk Management
The literature we reviewed notes that ERM contributes to leaders’ ability
to identify risks and adjust organizational priorities to enhance decision-
making efforts. For example, OPM has a Risk Management Council
(RMC) that builds risk-review reporting and management strategies into
existing decision making and performance management structures. This
includes Performance Dashboards, APG reviews, and regular meetings
of the senior management team, as is recommended by the CFOC and
PIC Playbook. The RMC also uses an existing performance dashboard
for strategic goal reviews as part of its ERM process and to help inform
decisions as a result of these reviews. Officials told us they present their
dashboards every 6 or 7 weeks to the Chief Management Officer (CMO)
and RMC, as part of preparing for their data-driven reviews. Each project
and its risks are mapped against the strategic plan. When officials
responsible for a goal identify risks, they must also provide action plan
strategies, timelines, and milestones for mitigating risks.
Figure 5 shows an OPM dashboard to illustrate how OPM tracks progress
on a goal of preparing the federal workforce for retirement, for such a risk
as an unexpected retirement surge, and documents mitigation strategies
to address such events. According to agency officials, the CMO and RMC
monitor high level and high visibility risks on a weekly basis. In August
2016, OPM officials told us they were monitoring five to seven major
projects, such as information technology (IT) security implementation and
retirement services processes.
OPM Builds Agency View of
Risk into Decision Making and
Organizational Performance
Management Reviews
Page 29 GAO-17-63 Enterprise Risk Management
Figure 5: Example of an Office of Personnel Management (OPM) Dashboard for Preparing the Federal Workforce for
Retirement Goal
Page 30 GAO-17-63 Enterprise Risk Management
Each quarterly data-driven review includes an in-depth look into a specific
goal and the examination of risks as part of the review. Officials told us
that in the past 3 years, they have covered each of the strategic goals
using the dashboard. According to officials, during one of these reviews,
OPM identified a new risk related to having sufficient qualified contracting
staff to meet the goal of effective and efficient IT systems. Since OPM
considers contracting a significant component of that goal, they decided
to create the Office of Procurement Operations to help increase attention
to contracting staff. Using ERM, OPM officials told us they believe that
they could better prioritize funding requests across the agency, ultimately
balance limited resources, and make better informed decisions.
The following examples illustrate how selected agencies are establishing
a customized ERM program into existing agency processes. These
include how they have:
• designed an ERM program that allows for customized agency fit,
• developed a consistent, routinized ERM program, and
• used a maturity model approach to build an ERM program.
This good practice relates primarily to Identify Risk and Select Risk
Response, two of the Essential Elements of Federal Government ERM
shown in table 1.
Effective ERM implementation starts with agencies establishing a
customized ERM program that fits their specific organizational mission,
culture, operating environment, and business processes but also contains
the essential elements of an ERM framework. The CFOC and PIC
Playbook focuses on the importance of a customized ERM program to
meet agency needs. This involves taking into account policy concerns,
mission needs, stakeholder interests and priorities, agency culture, and
the acceptable level for each risk, both for the agency as a whole and for
the specific programs.
For example, in 2004, the Department of Education’s (Education) Office
of Federal Student Aid (FSA) began establishing a formal ERM program,
based on the Committee of Sponsoring Organizations of the Treadway
Commission (COSO) ERM Framework, to help address longstanding
risks using customized implementation plans. More specifically, FSA’s
framework and materials were customized for it to ensure that they were
specific to work within a government setting, and to capture the nuances
Good Practice: Establish a
Customized ERM Program
Integrated into Existing
Agency Processes
The Office of Federal Student
Aid Customized Its Approach
to Designing and Implementing
ERM
Page 31 GAO-17-63 Enterprise Risk Management
of FSA's business model. Agency officials told us that one reason they
adopted a COSO-based model for ERM is that it was geared toward
achieving an entity's objectives, and could be customized to meet FSA’s
organizational needs as a performance-based organization.
22
Thus, FSA adopted a three-phase approach that allowed for increased
maturity over time, and customized it to help the organization adapt to the
new program using a COSO-based methodology for risk management.
According to FSA documents, the first phase involved creating the ERM
organization, designing a high-level implementation plan, and forming its
enterprise risk committee to help support its first ERM efforts. The second
phase involved creating a strategic plan and detailed project plan to
implement ERM. For example, the original FSA ERM Strategic Plan
contained an ERM vision statement (see textbox below) for aligning
strategic risks with goals and objectives. The FSA Plan also provided its
approach for identifying risks that could affect FSA’s ability to achieve
these objectives.
Federal Student Aid Enterprise Risk Management Original Vision Statement
“Our vision is to create the premier Enterprise Risk Management Program in the
Federal government. One that provides for an integrated view of risk across the entire
Federal Student Aid organization; aligns strategic risks with the organization’s goals
and objectives; ensures that risk issues are integrated into the strategic decision
making process; and manages risk to further the achievement of performance goals.”
Source: FSA|GAO-17-63
During the initial implementation of FSA's ERM program, the ERM
strategic goals were to:
1. provide for an integrated view of risks across the organization,
2. ensure that strategic risks are aligned with strategic goals and
objectives,
3. develop a progressive risk culture that fosters an increased focus on
risk and awareness of related issues throughout the organization, and
22
To address longstanding management weaknesses, the Higher Education Act of 1965
was amended in 1998, to establish FSA as the first federal performance-based
organization (PBO). A PBO is intended to transform the delivery of public services by
committing to achieving specific measurable goals with targets for improvement, in
exchange for being provided with more flexibility to manage its operations.
Page 32 GAO-17-63 Enterprise Risk Management
4. improve the quality and availability of risk information across all levels
of the organization, especially for executive management.
Finally, according to documents we reviewed, the third phase of FSA’s
ERM implementation included developing enterprise-level risk reports,
and advanced methods, tools, and techniques to monitor and manage
risk. For example, the documents we reviewed showed that some of the
key tools that supported FSA’s ERM implementation included ERM
terminology, risk categories, risk ratings, and a risk-tracking system.
These tools help FSA select an appropriate risk response that works with
existing agency processes and culture.
A consistent process for risk review that systematically categorizes risk
helps leaders to ensure that the consideration of potential risk takes
place. The CFOC and PIC Playbook suggests that organizations define
risk categories to support their business processes, and use these
categories consistently. For example, to identify and review risks, the TSA
Risk taxonomy organizes risks into categories so the agency can
consistently identify, assess, measure, and monitor risks across the
organization, as discussed in the TSA Policy Manual.
The TSA Risk Taxonomy captures the risks in all aspects of mission
operations, business operations, governance, and information. Figure 6
lists each risk category that is reviewed. The taxonomy helps TSA both
collect risks and identify the most critical, and helps ensure that the same
vocabulary and categorization system are used across TSA. Officials
report that they chose these categories to help break down organizational
silos and help identify all types of risks. For example, they did not want
“mission risk” to consider only the Federal Air Marshal Service and airport
checkpoint screening. Rather, they wanted a broad understanding of risks
across the various TSA components.
TSA Risk Taxonomy Promotes
a Consistent Approach to the
Risk Review Process
Page 33 GAO-17-63 Enterprise Risk Management
Figure 6. Transportation Security Administration Risk Taxonomy
TSA officials stated that they believe the taxonomy will be even more
useful when TSA has an automated computer application to help analyze
all similar and related risks across the enterprise.
OMB is encouraging agencies to use a maturity model approach in the
ERM guidance provided in A-123. Results from our literature review and
OMB suggested that a maturity model allows the organization to plan for
continued agency improvement as its efforts mature. For example, to
assist implementing a department-wide ERM process, Commerce
developed an ERM Maturity Assessment Tool (EMAT), as well as a
comprehensive guidebook and other tools, to share with its 12 bureaus.
The EMAT consists of 83 questions to help bureaus determine their ERM
maturity (see figure 7 for a sample of EMAT questions). According to
agency officials, bureaus are required to conduct EMAT assessments
annually. According to agency officials, while the EMAT lays out the basic
components of ERM, the bureaus may customize the tool to fit their
respective organizations. Commerce expects the bureaus to demonstrate
increased levels of maturity over time. Agency officials reported that
overall, the level of maturity has increased since the program began.
Commerce Designed an
Assessment Tool for Its
Bureaus to Determine Their
ERM Maturity
Page 34 GAO-17-63 Enterprise Risk Management
Discussions of the EMAT have allowed bureaus to learn from each other
and identify strategies for addressing common challenges. According to
officials, these challenges include documenting risk treatment plans and
providing the rationale to support management’s risk mitigation choices.
Figure 7: Selected Questions from Commerce’s Enterprise Risk Management Maturity Assessment Tool (EMAT)
Page 35 GAO-17-63 Enterprise Risk Management
The following example illustrates how a select agency is continuously
managing risks including how it has:
• tracked and monitored current and emerging risks.
This good practice most closely relates to Monitor Risks, one of the
Essential Elements of Federal Government ERM shown in table 1.
Continuously managing risk requires a systematic or routine risk review
function to help senior leaders and other stakeholders accomplish the
organizational mission. The CFOC and PIC Playbook recommends that
risks be identified and assessed throughout the year as part of a regular
process, including surveillance of leading risk indicators both internally
and externally. For example, PIH has two risk management dashboards,
which it uses to monitor and review risks.
The Risk and Mitigation Strategies Dashboard shown in figure 8,
according to PIH officials, helps them monitor risks and mitigation actions
that PIH is actively pursuing. Officials told us that the risk division
prepares and presents this dashboard to the Risk Committee quarterly.
The dashboard provides a snapshot view for the current period, analysis
of mitigation action to date, and trends for the projected risk. It tracks the
highest level risks to PIH as determined by the Risk Committee, along
with the corresponding mitigation plans. Currently, officials told us PIH is
managing the top risks using the dashboard. Risk division staff continually
update the dashboard to concisely display the status of both risk and
mitigation efforts.
Good Practice:
Continuously Manage
Risks
HUD Uses Risk Dashboards to
Monitor Risks
Page 36 GAO-17-63 Enterprise Risk Management
Figure 8: Public and Indian Housing Risk and Mitigation Strategies Dashboard
The second dashboard in figure 9, Key Risk Indicators Dashboard,
monitors external, future risks to PIH’s mission. Agency officials told us
that the dashboard is used as an early-warning system for emerging
risks, which the Risk Committee must address before the next annual risk
assessment cycle begins. The dashboard includes a risk-level column
that documents the residual risk, and is measured on a five-point scale
with one being the lowest and five being the highest, which is assigned by
Page 37 GAO-17-63 Enterprise Risk Management
the relevant Deputy Assistant Secretary and Risk Division staff. A
trending column indicates whether the risk is projected to increase,
decrease, or remain the same. There is also a link to a document that
summarizes the risk assessment including the risks and measures to
address the risk and anticipated impact. The Risk Committee reviews the
dashboard as needed, but not less than quarterly.
Page 38 GAO-17-63 Enterprise Risk Management
Figure 9: Public and Indian Housing Key Risk Indicators Dashboard
Page 39 GAO-17-63 Enterprise Risk Management
These two dashboards show how an agency uses the continuous risk
review cycle. The cycle allows leaders to treat risks until they are satisfied
the risk is under control or successfully treated or managed.
The following examples illustrate how selected agencies are sharing
information with internal and external stakeholders to identify and
communicate risks. These include how they have:
• incorporated feedback on risks from internal and external
stakeholders to better manage risks, and
• shared risk information across the enterprise.
This good practice most closely relates to Communicate and Report on
Risks in the Essential Elements of Federal Government ERM shown in
table 1.
Effective information and communication are vital for an agency to
achieve its objectives and this often involves multiple stakeholders, inside
and outside the organization. ERM programs should incorporate feedback
from internal and external stakeholders because their respective insights
can help organizations identify and better manage risks. For example, the
National Oceanic and Atmospheric Administration (NOAA) and the
National Aeronautics and Space Administration (NASA) are creating and
sharing inter-agency risk information as part of their joint management of
the Joint Polar Satellite System (JPSS) program.
23
JPSS is a
collaborative effort between NOAA and NASA; the program was created
with the President’s Fiscal Year 2011 Budget Request to acquire,
develop, launch, operate and sustain three polar-orbiting satellites. The
purpose of the JPSS program is to replace aging polar satellites and
provide critical environmental data used in forecasting such weather
events as the path and intensity of a hurricane and measuring climate
variations. These two agencies have a signed agreement, or
23
Given the criticality of satellite data to weather forecasting, the likelihood of a significant
satellite data gap, and the potential impact of a gap on the health and safety of the U.S.
population and economy, the issue was added to our High Risk List in 2013. In 2014, we
recommended that NOAA track completion dates for risk mitigation activities, update its
data gap assessment, address shortfalls in its contingency plan, prioritize mitigation
projects most likely to address a gap, and report progress on all mitigation projects. NOAA
implemented the recommendation to track completion dates for risk mitigation activities,
and we have closed it as of July 2015.
Good Practice: Share
Information with Internal
and External Stakeholders
to Identify and
Communicate Risks
Two Agencies Use A
Memoran
dum of
Understanding to Share
Accountability and Ownership
for Risks from a Shared
Satellite Program
Page 40 GAO-17-63 Enterprise Risk Management
memorandum of understanding, to share ownership for risk that details
the responsibilities for delivering the satellite and overall cost and
schedule performance. In particular, NOAA has overall responsibility for
the cost and schedule of the program, as well as the entire JPSS
program. NOAA manages the ground segment elements needed for data
collection and distribution, while NASA manages the system acquisition,
engineering, and integration of the satellite, as well as the JPSS Common
Ground System.
Because of this management arrangement, the Joint Polar Satellite
System (JPSS) program also required “joint” risk tracking and
management. Other program documentation also points to the agencies’
close collaboration on risk management. The March 2014, JPSS Risk
Management Plan describes how risk management practices are planned
for consistency with NASA’s risk management requirements and outlines
roles and responsibilities. NOAA officials stated that they share
programmatic and technical information across the two agencies, and that
certain high-level risks are elevated through Commerce quarterly. Our
review of meeting agendas and presentations show that NASA and
NOAA officials met monthly as part of a NOAA held Agency Program
Management Council (APMC) to track JPSS’s progress and that of other
satellite programs. These meetings also allowed participants to discuss
and approve courses of action for top program risks. During the APMC
meetings, the JPSS program director presented status updates and other
information including risks. Participants discussed risks, cost,
performance, schedule, and other relevant issues for each program.
Sharing information helps promote trust within and outside of the
organization, increases accountability for managing risks, and helps
stakeholders understand the basis for identified risks and resulting
treatment plans. Further, internal and external stakeholders may be able
to provide new expertise and insight that can help organizations identify
and better manage risks. Both the NASA Program Managers and the
NOAA Program Director or their representatives attend meetings to
discuss potential issues, according to NOAA officials. Each major satellite
program also has an independent Standing Review Board. At defined
program/project milestones, the Standing Review Board reviews relevant
data and writes up its conclusions, presents an independent review of the
program/project, and highlights key risks to the convening authorities.
NOAA officials said that having a joint risk-sharing process established for
JPSS and other joint programs allows them to elevate risks both internally
up through the agency, and externally, more quickly and efficiently. For
Page 41 GAO-17-63 Enterprise Risk Management
example, for another satellite program, NOAA had to reschedule its
launch date due to a problem that arose with the launch service provider.
After it became clear that the program was going to miss its schedule
baseline, it was elevated up through NOAA. According to NOAA, NASA
officials then explained to the APMC the steps they were taking to
address the risk. As a result of having a process to elevate the risk,
NOAA was able to discuss risks associated with the launch vehicle and
how it planned to proceed with a new launch date range. According to
NOAA officials, because the APMC discussion developed joint
information, this information was available to pass on more quickly to
Congress.
When discussing potential risks, gathering input from across an
enterprise helps to ensure decisions work for all agency groups affected.
It also gives groups an opportunity to share any concerns or ideas that
can improve outcomes. Appropriate and timely sharing of information
within an organization ensures that risk information remains relevant,
useful, and current. The CFOC and PIC Playbook also notes that
informed decision making requires the flow of information regarding risks
and clarity about uncertainties or ambiguities—up and down the hierarchy
and across silos—to the relevant decision makers so they can make
informed decisions. For example, IRS uses the Risk Acceptance Form
and Tool (RAFT) as shown in figure 10 to document business decisions
within a consistent framework. As part of the RAFT development process,
IRS considers the views of internal and external stakeholders. According
to agency officials, the RAFT assists IRS business units in making better
risk-based decisions and elevating risks to the appropriate level. IRS
officials said the RAFT also encourages units to consider how decisions
may affect other units, as well as external stakeholders. As a result,
business units often collaborate on key decisions by completing the
RAFT, including considering and documenting risks associated with those
decisions.
IRS Uses a Decision-Making
Tool that Includes Input from
Stakeholders Across the
Enterprise
Page 42 GAO-17-63 Enterprise Risk Management
Figure 10: Internal Revenue Service Risk Acceptance Form and Tool Decision-Making Tool
Page 43 GAO-17-63 Enterprise Risk Management
According to IRS officials, the RAFT is used as a guide to articulate
rationales behind decisions within the context of risk appetite and serves
as a documentation trail to support these business decisions. IRS agency
officials told us that one goal of its ERM program is to look at risk across
the enterprise rather than taking a narrow approach to risk management.
This also applies when making risk informed decisions, such as those
that would be documented on a RAFT. As such, the RAFT includes the
following instructions: “If the decision impacts or involves multiple
organizations, coordinate with the respective points-of-contact to ensure
all relevant information regarding the risk(s) are addressed in each
section.” The form also allows users to identify other business units
involved in the decision and external stakeholders affected by the
decision.
We provided a draft of this report to Office of Management and Budget
(OMB) and the 24 Chief Financial Officer (CFO) Act agencies for review
and comment.
24
OMB staff provided us with oral comments and stated
they generally agreed with the essential elements and good practices as
identified in this report. They also provided technical comments that we
incorporated as appropriate. We received written responses from the
Social Security Administration (SSA) and Department of Veterans Affairs
(VA) reprinted in appendices II and III. The SSA and the VA neither
agreed nor disagreed with our findings. However, VA mentioned that
enterprise risk management should be monitored at a minimum as part of
the quarterly reviews of Agency Priority Goals because of the high-level
audience led by the Deputy Secretary and suggested that monitoring
risks more frequently should be emphasized as a practice that most
agencies should follow, among other things. SSA stated that they are
adopting the good practices identified in the report.
Of the remaining 22 CFO Act agencies, we received technical comments
from 10 agencies, which we incorporated as appropriate, 10 had no
comments, and two others did not respond.
24
31 U.S.C. § 901(b). The 24 CFO Act agencies, generally the largest federal agencies,
are the Departments of Agriculture, Commerce, Defense, Education, Energy, Health and
Human Services, Homeland Security, Housing and Urban Development, the Interior,
Justice, Labor, State, Transportation, the Treasury, and Veterans Affairs, as well as the
Agency for International Development, Environmental Protection Agency, General
Services Administration, National Aeronautics and Space Administration, National Science
Foundation, Nuclear Regulatory Commission, Office of Personnel Management, Small
Business Administration, and Social Security Administration.
Agency Comments
and GAO Responses
Page 44 GAO-17-63 Enterprise Risk Management
We are sending copies of this report to the Director of OMB as well as
appropriate congressional committees and other interested parties. In
addition, this report is available at no charge on the GAO website at
http://www.gao.gov.
If you or your staff members have any questions about this report, please
contact me at (202) 512-6806 or mihmj@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to this
report are listed in appendix IV.
J. Christopher Mihm
Managing Director, Strategic Issues
Appendix I: Subject Matter Specialists
Page 45 GAO-17-63 Enterprise Risk Management
Todd Grams, Association of Federal Enterprise Risk Management (AFERM),
President; Deloitte & Touche LLP, Managing Director; Internal Revenue Service,
former Chief of Staff, Chief Financial Officer (CFO) and Chief Information Officer;
and Department of Veterans Affairs, former CFO and Performance Improvement
Officer
Frank Martens, Director, PricewaterhouseCoopers (PwC), Risk Assurance Services
and Project Lead Director on the PwC team working with the Committee of
Sponsoring Organizations of the Treadway Commission to update the Enterprise
Risk Management Framework- Aligning Risk with Strategy, exposure draft June
2016
Linda Springer, former Executive Director, Ernst & Young, LLP; former Director of
the Office of Personnel Management and former Controller and former, Director,
Office of Federal Financial Management at OMB
Thomas Stanton, AFERM, Past President; Fellow at Johns Hopkins University, and
author of articles and books on ERM in the public sector
Dr. Doug Webster, AFERM, Co-founder and Past President; George Washington
University Center for Excellence in Public Leadership, Senior Fellow;
author of articles and a book on ERM in the public sector; and Director, Risk
Management at the U.S. Agency for International Development, Office of the Chief
Financial Officer.
Appendix I: Subject Matter Specialists
Appendix II: Comments from the Social
Security Administration
Page 46 GAO-17-63 Enterprise Risk Management
Appendix II: Comments from the Social
Security Administration
Appendix III: Comments from the Department
of Veterans Affairs
Page 47 GAO-17-63 Enterprise Risk Management
Appendix III: Comments from the
Department of Veterans Affairs
Appendix III: Comments from the Department
of Veterans Affairs
Page 48 GAO-17-63 Enterprise Risk Management
Appendix IV: GAO Contact and Staff
Acknowledgements
Page 49 GAO-17-63 Enterprise Risk Management
J. Christopher Mihm, (202) 512-6806 or mihmj@gao.gov
In addition to the individual named above, William M. Reinsberg,
Assistant Director, Carole J. Cimitile, Analyst-in-Charge, Shea Bader,
Crystal Bernard, Amy Bowser, Alexandra Edwards, Ellen Grady, Erin E.
Kennedy, Erik Kjeldgaard, Robert Gebhart, Sharon Miller, Anthony
Patterson, Laurel Plume, Robert Robinson, Cynthia Saunders, Stewart
W. Small, Katherine Wulff, and Jessica L. Yutzy made major contributions
to this report.
Appendix IV: GAO Contact and Staff
Acknowledgements
GAO Contact
Staff
Acknowledgements
(451159)
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