Detailed Information on the
International Trade Administration: U.S. and Foreign Commercial Service Assessment

Implement long-term measures in the 2005 Annual Performance Plan that include a market test of performance.

Improve the quality of targets set to reflect performance.

Develop additional efficiency measures.

Work to implement an activity-based accounting system to better track how much USFCS services cost.

Measure: Number of transactions made as a result of ITA involvement

Explanation:The number of export transactions executed by U.S. businesses directly resulting from counseling, matchmaking, research, information products or other trade promotion activities.

Measure: Number of U.S. firms exporting for the first time

Explanation:The number of U.S. firms that transact an actual verifiable export sale for the first time.

Measure: Number of New-to-Market Firms

Explanation:The number of firms that ITA assisted that were planning to export to a new market for the first time.

Measure: Number of U.S. exporters entering a new market

Explanation:The number of U.S. firms that transact an actual verifiable export sale in a new market, or introduce new products line in a market to which it currently exports.

Measure: Number of New-to-Export firms

Explanation:The number of firms ITA assisted that were planning to export for the first time.

Measure: Number of new or enhanced ITA partnerships with public and private sector entities to promote US exports

Explanation:

Measure: By 2007, the US&FCS will increase the baseline of the "Number of US firms exporting for the first time by 1% of the total exporting base. The US&FCS has targeted 5,000 firms to begin exporting over the next six years from a baseline of 400,000 SMEs that currently do not export.

Explanation:

Measure: By 2007, the US&FCS will increase the baseline of the "Number of US firms entering a new market" by 20% of the total baseline of firms exporting to only one market. The US&FCS has targeted 40,000 firms to enter more than one market over the next six years from a baseline of 200,000 SMEs that currently export to only one market.

Explanation:

Measure: By 2007, the US&FCS will increase the "Number of transactions made as a result of ITA's involvement" by 43%. In FY 2001, the US&FCS completed 11,160 transactions and by 2007 the US&FCS has targeted 16,000 transactions. This constitutes a 43% increase over 2001.

Explanation:

Measure: Percentage of USFCS that is fee-funded. ITA has determined that by 2007, 3% of the US&FCS program will be fee funded. (Under development.)

Explanation:

Is the program purpose clear?

Explanation: The U.S.&FCS helps U.S. companies, particularly small and medium-sized enterprises (SMEs), make sales in international markets. US&FCS's purpose is clearly stated through statutory authority and provided to stakeholders and customers through its marketing materials.

Evidence: Sections 2301 and 4721 of the Omnibus Trade and Competitiveness Act of 1988 (P.L. 100-418).

Does the program address a specific and existing problem, interest, or need?

Explanation: In response to concerns about the effectiveness of government export promotion programs, overseas commercial work was transferred from State to the Commerce Department in 1980. The US&FCS program was established to: 1) promote exports of goods and services from the United States, particularly by small and medium-sized enterprises and 2) assist US exporters in their dealings with foreign governments.

Evidence: 1) 1989 GAO report. 2) Sections 4721 of the Omnibus Trade and Competitiveness Act of 1988 (P.L. 100-418). 3) The FY 2002 National Export Strategy indicates that only about 1% of U.S. small businesses export their product or service. 4) U.S. Exporting Companies: Initial Findings From 2001 Exporter Database, March 2003 indicates that, in 2001, 90% of all SMEs in the database conducted business from a single U.S. location. Without overseas operations, SMEs are less able to overcome foreign trade barriers and market imperfections than their larger company counterparts, which have overseas operations or foreign affiliates.

Is the program designed so that it is not redundant or duplicative of any Federal, state, local or private effort?

Explanation: Although US&FCS continues to improve its coordination with private and public trade promotion agencies, studies indicate that businesses serviced by US&FCS can also obtain similar services from state, local and private sector entities. For example, Customized Market Research, which provides firms with customized information on overseas markets, is also provided by at least 3 private firms. Another example is Platinum Key Services and Flexible Market Search which are two customized advisory services provided by US&FCS. A study found that many private sector entities were willing to offer a complete and extended level of effort for 3 to 6 months to a company tomestablish a foothold in an export market. Another example is US&FCS's Showtime service which provides U.S.companies a list of international trade events they can attend. The State of Maryland's Office of International Business also provides listings of international trade shows. In addition to export promotion consulting, FedEx and UPS do trade compliance and tariff consulting work for exporters.

Evidence: 1) According to the KPMG Fee Study (January 2003), in contrast to other federal agencies, a majority of ITA's products and services do not enjoy a monopoly in their markets because the majority of these products can be obtained elsewhere. 2) Two University of North Carolina studies (1995 and 2002) indicated that, although exporters found government programs, such as US&FCS, to make a positive contribution to US exports, the private sector emerged as the clear leader of providing services to abroad. 3) State of Maryland http://www.choosemaryland.org/international/export/Trade%20Events/index.asp 4) US Chamber of Commerce: http://www.uschamber.com/chambers/ 5) World Trade Centers Association: http://iserve.wtca.org/ 6) FedEx Trade Networks has over 330 locations worldwide and they office international trade consulting, trade seminars, information technology including fully integrated regulatory compliance tools for imports and exports as well as duty and tax collection. http//www.fedex.com/ 7) UPS (http://www.ups.com/) 8) Council of State Governments reports that states maintain over 200 independent overseas trade promotion offices (May 2002).

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: Although US&FCS has streamlined and co-located offices, the agency could increase its efficiency if the agency had a better sense of how much it costs to provide its products and services. Although US&FCS currently charges fees for some products and services, the agency does not have a consistently-applied pricing or marketing strategy for its services domestically or abroad. The infrastructure for capturing cost and customer information are inadequate for making informed decisions. Some recommendations US&FCS should consider are: 1) Standardize the management of portfolio of products/services and customer, market, cost and price information to ensure quality and reliability. 2) Improve integration and functionality of customer management systems. 3) Perform ongoing competitor and market analysis. 4) Implement a product/service cost accounting system and cost accounting through performance goals and rewards. 5) The program design and feedback relies primarily on customer service surveys. External third-party evaluations would assist US&FCS in assessing how effective its programs are over the long-term in assisting U.S. firms export. Ultimately, the ability to collect fees as a result of services rendered provide a market test that the customer finds the services valuable.

Evidence: 1) KPMG User Fee Study (January, 2003) 2) Booz Allen Study (1998) 3) GAO: U.S. Export Assistance Centers: Customer Service Enhanced But Potential to Improve Operations Exists (GAO/T-NSIAD-96-213)

Is the program effectively targeted, so program resources reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: In response to a fragmented structure of federal export promotion services, through the Trade Promotion Coordinating Committee, US&FCS joined with U.S. Export-Import Bank and Small Business Administration to establish a network of U.S. Export Assistance Centers to coordinate with themselves and other non-federal agencies, such as state agencies and world trade centers. To date, there are 12 USEAC offices where US&FCS is co-located with SBA and Export Import Bank to effectively target services to U.S. firms in a coordinated fashion. Furthermore, 69% of domestic offices are co-located with non-federal partners. US&FCS has also implemented new products and eliminated services as a result of past studies to better target resources. In addition to this structure, as mandated by law, ITA/FCS targets the businesses that can not afford private sector comparable services (primarily small to medium sized businesses). FCS is working on better defining its criteria for targetting assistance. Thirdly, FCS is evaluating how to better account for its cost and pass long an appropriate level of cost to the customer. Lastly, ITA is reviewing its organizational structure to determine how to better deliver its services.

Evidence: 1) Export Promotion: Governmentwide Strategy Needed for Federal Programs (GAO/T-GGD-93-7); Export Promotion: Federal Programs Lack Organizational and Funding Cohesiveness (GAO/NSIAD-92-49); Export Promotion: U.S. Export Assistance Centers Seek to Improve Services (GAO/NSIAD-99-180) 2) 1998 Booz Allen report findings led to development of "Centers of Innovation" program to develop new products and services. Platinum Key Service and Flexible Market Research are results.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The purpose of US&FCS is to help U.S. companies, particularly small and medium-sized enterprises (SMEs), make sales in international markets. Although US&FCS has a number of quantifiable performance measures, the current measures do not tie to an overall long-term outcome that accomplishes the purpose of the program (e.g., By 2007, US&FCS will increase exports by U.S. firms by x%.). However, ITA/FCS have developed long-term performance measures to be included in the FY 2005 Annual Performance Plan, which includes a long-term measure that includes a market test of services.

Evidence: 1) ITA Strategic Plan (2002-2006)2) ITA's FY 2002 Annual Performance and Accountability Report: www.osec.doc.gov/bmi/budget/02APPR/02ita.pdf 3) ITA/FCS FY 2005 Annual Performance Plan.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: ITA collects data to monitor U.S. trade that can provide baseline data regarding the U.S. firms that seek to export. US&FCS's Strategic Plan identifies mission-focused goals such as "open markets" or "increase SME exporters and exports" and has recently devised long-term measures that identify timeframes which will be incorporated into its FY 2005 Annual Performance Plan. These long-term measures coincide with ITA/FCS's current annual measures.

Evidence: 1) 2001 US Exporter Database2) ITA Strategic Plan (FY 2002-2006)3) ITA's FY 2002 Annual Performance and Accountability Report: www.osec.doc.gov/bmi/budget/02APPR/02ita.pdf 3) ITA/FCS FY 2005 Annual Performance Plan.

Does the program have a limited number of specific annual performance measures that demonstrate progress toward achieving the program's long-term measures?

Explanation: Although ITA measures are shared, US&FCS constitutes two-thirds of ITA's budget. As the primary export promotion agency at ITA, US&FCS is charged with increasing export transactions. To this end, US&FCS has six specific annual performance measures that demonstrate some progress in promoting exports. ITA's strategic plan articulates the following long-term goals: increasing trade opportunities by opening markets and providing leadership in promoting trade and broadening participation by increasing SNE exporters and exports and facilitate deal-making. Although the measures accommodate these goals, long-term quantifiable outcome measures (e.g., Increasing exports by x number by 200y) would better enable US&FCS to define its progress.

Evidence: 1) ITA's FY 2002 Annual Performance and Accountability Report: www.osec.doc.gov/bmi/budget/02APPR/02ita.pdf2) US&FCS Budget information, FY 1988-FY 20033) ITA Strategic Plan FY 2002-FY 2006.

Does the program have baselines and ambitious targets and timeframes for its annual measures?

Explanation: ITA's baseline is informed from performance in the previous year and calibrated every year as necessary. Annual targets appear to be ambitious but could be better linked to long-term outcome measures by articulating a specific long-term target.

Evidence: 1) ITA's FY 2002 Annual Performance and Accountability Report: www.osec.doc.gov/bmi/budget/02APPR/02ita.pdf

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, etc.) commit to and work toward the annual and/or long-term goals of the program?

Explanation: Partners commit to the annual performance measures through performance documents, MOUs, or agreement letters. In the case of TPCC partners (SBA and Export Import Bank), US&FCS co-location increases these agencies' abilities to work toward annual performance goals. ITA/US&FCS could enhance partner outputs by clearly identifying long-term outcome goals that link with annual measures.

Evidence: 1) ITA Strategic Plan (2002-2006) 2) US&FCS Memorandums of Understanding (e.g., National Association of Women-Owned Businesses) 3) Agreement letter and sample report between US&FCS and USDA FAS. 4) US&FCS and USAID partnership on Ecolinks program (e.g., FY 2002 Export Successes).

Are independent and quality evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: US&FCS's primary assessment mechanism has been customer service surveys. Although these surveys yield relevant information, they do not provide an external assessment of US&FCS products and services and compare them to a long-term baseline on which to determine progress. Although numerous Office Inspector General performance and financial audits have been performed on aspects of US&FCS and the General Accounting Office (GAO) has examined export promotion coordination, comprehensive reviews of US&FCS's performance and validation of past performance have not been conducted. The absence of an an external assessment of the long-term effects of US&FCS services (e.g., sustainability of new to export firms as exporters US&FCS assists) makes it difficult to fully understand how effective US&FCS is in fulfilling its purpose.

Evidence: 1) Report Card on Trade I, 19952) Report Card on Trade II, 20023) IG Reports: www.oig.doc.gov/E-Library/Reports/Recent/body_recent.html 4) GAO Reports on export promotion: www.gao.gov

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Although budget estimates include direct and indirect overhead cost, including rent, utilities, Departmental support and services provided to the US&FCS by the Department of State, US&FCS does not know how much it spends to provide its services so resource needs can not be tied to the budget.

Evidence: www.osec.doc.gov/bmi/budget/04APP/04ita.pdf

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: US&FCS has a bi-annual Strategic Plan that provides a mechanism for the program to review and recast annual priorities and identify opportunities to advance the ITA strategic mission. In addition to the bi-annual US&FCS Strategic Plan, the US&FCS has permanent members assigned to the ITA Strategic Planning Leadership Team (SPLT). The SPLT meets monthly to discuss key performance issues, evaluate performance targets and results. Issues identified above are being examined for appropriate action. ITA is also in the process of adopting a plan to implement appropriate recommendations from the recent KPMG Fee Study. This plan includes short-term goals (nominally increasing some fees), mid-term goals (standardizing fees and implementing cost-accounting to determine how much it costs to provide services) and long-term goals (e.g., x% fee-funded by 200y).

Evidence: ITA Strategic Planning Leadership Team

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The US&FCS performance information is regularly collected from multiple sources including client surveys through the Client Relationship Management unit and Management and Performance Reviews by the Office of Planning and feedback solicited from partners. The US&FCS uses this performance information to manage the program and improve performance by integrating performance information in its program and resource-planning systems and in its accountability systems for offices and for staff.

Evidence: 1) Performance information on export successes and client satisfaction are entered into a common database using a standard format. 2) Specific reporting criteria and standards for products and services are defined in the US&FCS Operations Manual. 3) US&FCS uses an economic model developed by Global Insights Inc. for decisions about overseas operations resource allocation. Global Insights Inc. also reviewed the domestic model used by the field.

Are Federal managers and program partners (grantees, subgrantees, contractors, cost-sharing partners, etc.) held accountable for cost, schedule and performance results?

Explanation: Federal managers and program partners are held accountable for cost, schedule and performance results through rigorous annual office-level and staff-level performance plans. Plans are clear, specific and performance-based. They follow standard templates to ensure consistency and mission-focus. An evaluation system is in place to hold staff accountable for performance and to recognize strong and weak performers. Federal managers are held accountable for cost through a de-layered management structure and cost-benefit resource allocation models.

Evidence: 1) Annual Performance Plans for all Senior Commercial Officiers includes a critical element dedicated to management and performance measures. Performance appraisals for trade specialists are linked to key performance measures (e.g., number of export successes) and banded to GS levels. 2) Senior Federal managers heads each domestic and international office and are responsible for all expenditures. 3) US&FCS has redeployed resources, such as withdrawing an FSO from a foreign post, because few results were achieved. 4) Management at all levels uses data from the US&FCS Client Management System, which records client information, to gauge performance and ensure agency goals are achieved.

Are all funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: The US&FCS obligates appropriated and trust funds in a timely manner based on annual fiscal plans detailing expected expenditures for all accounts. The US&FCS has established procedures for reporting and tracking expenditures in order to allow management to verify funds are spent appropriately and that obligations are consistent with the overall program plan. Independent auditors have verified that the US&FCS follows generally accepted accounting practices for the United States and that only limited amounts of unobligated funds remain at the end of each fiscal year.

Evidence: 1) In FY 2002, the US&FCS obligated 99.7% of its available operations and administration funds. This trend has been in place for several years [FY 2001-97% and FY 2000-97.2%] and includes all funds. 2) Independent auditors have verified that the US&FCS follows generally accepted accounting practices for the Untied States and as documented by KPMG in its 2002 Independent Auditors' Report of the Department's FY 2001 and FY 2002 consolidated financial statements and statement of net cost presented in the FY 2002 Performance and Accountability Report (www.osec.doc.gov/bmi/budget/02APPR/02ita.pdf).

Does the program have procedures (e.g., competitive sourcing/cost comparisons, IT improvements, approporaite incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The US&FCS encourages efficiencies and cost effectiveness through incentives that return a portion of achieved savings to the generating office and a de-layered management structure that delegates budget management to front line managers. The US&FCS also uses both cost comparisons and competitive sourcing to acquire cost-effective and expert services. FCS has also co-located offices in its U.S. Export Assistance Centers with Export-Import Bank, Small Business Administration, and local domestic Chambers of Commerce over the years and has reduced overhead costs in some instances as a result. US&FCS is working on determining a unit cost and implementing a standard pricing structure.

Evidence: 1) US&FCS streamlined and reallocated resources by severing 33 Foreign Service National and Personal Service Contractor positions, closed five constituent posts, three country operations, consolidated six domestic offices and reorganized a number of USEAC hubs to achieve greater efficiency (10/4/2001 reorganization) 2) Reduced one layer of Office of Domestic Operations management, streamlined field regions from four to two, and reduced rent in ten domestic offices. Two-thirds of all ODO offices are co-located with strategic trade promotion partners. (4/29/2002 consolidation efforts) 3) Domestic offices that generate savings through their efforts receive 10% of the documented savings. 4) US&FCS is effectively converting work performed Foreign Service Nationals to Personal Service Agreements at overseas posts when appropriate. 5) US&FCS privatized 40 trade missions since 1995.

Does the program collaborate and coordinate effectively with related programs?

Explanation: Effective collaboration is supported and facilitated by the Trade Promotion Coordinating Committee (TPCC), an interagency committee chaired by the Secretary of Commerce. It was established under the Export Enhancement Act of 1992 to provide a unifying framework to coordinate the export promotion and export financing activities of the U.S. Government and to develop a government-wide strategic plan for carrying out such programs. US&FCS works closely with the TPCC in planning and implementing a wide range of collaborative activities at the Federal, State and local levels.

Evidence: 1) The 1993 National Export Strategy, developed by the TPCC, called for the establishment of Export Assistance Centers. Of the 108 Export Assistance Centers in the United States, two-thirds are physically co-located with Federal, State, or local partners. 2) MOU among Commerce, Export-Import Bank, and Small Business Administration defines the roles of these agencies in 108 Export Assistance Centers (USEACs) in the United States. 3) MOU between US&FCS and Overseas Private Investment Corporation for joint training and marketing programs to best enable staff to cross-advertise products and services. 4) Over the last three years, USDA's Foreign Agriculture Service and US&FCS have recently enahced their partnership through a joint team which include State Regional Trade Groups, and the National Association of State Departments of Agriculture. US&FCS and FAS have developed a matrix of services for food-related companies to facilitate provision of services to businesses.

Does the program use strong financial management practices?

Explanation: US&FCS is in conformity with the accounting principles generally accepted in the Untied States. Per findings of clean financial audits, strong procedures are in place to ensure funds are spent as intended. Financial contractors also use strong financial management practices, as evidenced by clean financial audits.

Evidence: 1) Inspector General's audit of FY 2002 Consolidated Financial Statements (1-16-2003, Audit Report No. FSD-15214-3-0002) 2) KPMG 2002 Independent Auditors' Report of Department's FY 2001 and FY 2002 consolidated financial statements.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The US&FCS has systems for identifying and correcting deficiencies in program management, and takes prompt, effective action when deficiencies are identified. These systems serve to prevent problems from occurring or detect problems at an early stage before they become severe. Responses to previous questions document strong accountability systems (rigorous office and manager performance plans) and aggressive training programs to ensure managers develop and maintain top-quality skills, which are vital to foster managerial integrity to prevent problems from developing. ITA is also in the process of adopting a plan to implement appropriate recommendations from the recent KPMG Fee Study. This plan includes short-term goals (nominally increasing some fees), mid-term goals (standardizing fees and implementing cost-accounting to determine how much it costs to provide services) and long-term goals (e.g., x% fee-funded by 200y).

Evidence: 1) US&FCS Management and Program Reviews (MPRs) conducted annually on domestic and international offices and address management, program and administrative operations. Findings are used to develop training programs and improve administrative and funds management control. For example, exit certification for Senior Commerical Officers are being introduced in FY 2003 based on MPRs. 2) GAO: Export Promotion: Government Agencies Should Combine Small Business Export Training Programs. September 2001. GAO-01-1023. Commerce and SBA implemented the findings by combining the training programs. 3) Implementation of IG audit findings (e.g, US&FCS Italy's Effectiveness Can Be Further Enahnced By Forcusing on Management and Program Improvements, IPE-14232, March 2002; US and Foreign Commercial Service Is Addressing Foreign Service Personnel Management Issues, #10829-9-0001, September 1999; Dallas USEAC is Rebuliding to More Aggressively Pursue Export Promotion Activities, #IPE-11006, September 1998)

Has the program demonstrated adequate progress in achieving its long-term outcome performance goals?

Explanation: US&FCS's performance is subject to critical external factors in the trade environment which include relative strength of U.S. currency, fluidity of exchange rates, and economic shocks in foreign markets which may adversely affect the demand for US exports. US&FCS has demonstrated some progress in achieving its annual performance goals, and has introduced new long-term performance measures in the FY 2005 Annual Performance Plan that should enable the agency to better demonstrate progress towards achieving its articulated long-term goals.

Evidence: 1) 2001 US Exporter Database2) ITA Strategic Plan (FY 2002-2006)3) ITA's FY 2002 Annual Performance and Accountability Report: www.osec.doc.gov/bmi/budget/02APPR/02ita.pdf 4) ITA's FY 2005 Annual Performance Plan

Does the program (including program partners) achieve its annual performance goals?

Explanation: Although US&FCS has demonstrated active partnerships with both private and public organizations, the absence of quantifiable long-term goals makes determining how well the annual performance goals are doing in order to that goal difficult to ascertain. Furthermore, the agency has two years of data that indicate that it has had uneven success. Although 5 of 6 measures in FY 2001 were met, only 1 of the 6 measures in FY 2002 was met.

Evidence: ITA's FY 2002 Annual Performance and Accountability Report: www.osec.doc.gov/bmi/budget/02APPR/02ita.pdf

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program performance goals each year?

Explanation: Although US&FCS does not have an efficiency measure, the programs efforts to reduce overhead, co-locate with partners, employ PSCs overseas have led to increased efficiencies in the program and the agency's work toward achieving program goals. ITA/US&FCS should develop a unit cost measure (e.g., cost per export). US&FCS does not include a measure that indicates the counseling that they do for U.S. firms that do not export. A measure that includes a percent of total firms that export of total firms assisted may inform US&FCS's progress toward accomplishing its purpose. Consolidating the number of websites and web content into export.gov would assist potential and current exporters access to US&FCS information.

Evidence: [See Evidence for question 3.4]1) Reduced one layer of Office of Domestic Operations management, streamlined field regions from four to two, and reduced rent in ten domestic offices. Two-thirds of all ODO offices are co-located with strategic trade promotion partners. (4/29/2002 consolidation efforts) 2) Domestic offices that generate savings through their efforts receive 10% of the documented savings. 3) US&FCS is effectively converting work performed Foreign Service Nationals to Personal Service Agreements at overseas posts when appropriate.4) US&FCS privatized 40 trade missions since 1995.5) Four US&FCS websites currently display similar information and some sites connect to information others do not. www.usatrade.gov/ www.buyusa.gov/home/ www.buyusa.com

Does the performance of this program compare favorably to other programs, including government, private, etc., that have similar purpose and goals?

Explanation: Although surveys of the US&FCS program report that SME users feel Commerce trade promotion programs have a positive impact more frequently than any other government resource and are the top provider of basic export information to businesses; studies also report that private service providers continue to account for the overwhelming majority of all services provided.

Evidence: 1) Report Card on Trade I, 1995 2) Report Card on Trade II, 2002 3) KPMG Fee Study, 2003

Do independent and quality evaluations of this program indicate that the program is effective and achieving results?

Explanation: As stated above, surveys of exporters indicate that US&FCS program is rated by SME users as having a positive impact more frequently than any other government resource. However, as stated in qu. 2.6, US&FCS's primary assessment mechanism has been customer service surveys. Although these surveys yield relevant information, they do not provide a comprehensive independent assessment of US&FCS products and services. Although numerous Office Inspector General performance and financial audits have been performed on aspects of US&FCS and the General Accounting Office (GAO) has examined export promotion coordination, comprehensive reviews of US&FCS's performance and validation of past performance have not been conducted.

Evidence: 1) Report Card on Trade I, 19952) Report Card on Trade II, 20023) KPMG Fee Study, 20034) IG Reports: www.oig.doc.gov/E-Library/Reports/Recent/body_recent.html 5) GAO Reports on export promotion: www.gao.gov