The Dilemma of the Supreme Audit Institutions: Autonomy or Relevance?

A Case Study of the Government Accountability Office (GAO)

Old Title: Supreme Audit Institutions: Explaining the Variation in the Degree of
Influence

Asif M Shahan
Department of Public and International Affairs
George Mason University
E-mail: ashahan@gmu.edu

Prepared for presentation in the International Research Society for Public Management Conference,
2014

Electronic copy available at: http://ssrn.com/abstract=2573457

 Abstract

The "Institutions of Accountability" (IOA) are considered as important instruments for ensuring
horizontal accountability and of these, the role played by the Supreme Audit Institutions (SAIs) is
particularly important. These SAIs are set up based on the constitutional and legal framework of
countries and they help the legislatures to enforce accountability, reduce fiduciary risk and measure
the outcome of different programs. Even though the SAIs are supposed to be "autonomous" and
free from all types of political pressure, while performing their roles and responsibilities, these
institutions have to interact with different political actors. As a result of this interaction, the SAIs,
through concentrating on measuring the performance of different government programs/ agencies,
have started playing an important role in the political/policy arena and this has made the SAIs more
relevant in the political realm. Consequently, the SAIs are now facing a unique dilemma- whereas
autonomy requires that the SAIs be completely independent from the political actors while
performing its duties, relevance requires keeping close connection with these actors so that their
recommendations are being implemented. In other words, if the institution concentrates too much
on protecting its autonomy by maintaining its distance from the other political actors, it may fail in
affecting the policies/programs as per its recommendations. On the other hand, if the institution
focuses on being relevant in the policy arena by interacting with the political actor, it may find itself
vulnerable to political demand or pressure and thereby, may lose its autonomy. This paper has
attempted to capture the dynamics of the autonomy-relevance dilemma faced by the SAIs and
explore the strategies adopted by these institutions in dealing with this. While doing that, it has
made an effort to develop a theoretical framework as a way to begin unpacking the political
relationships and roles played by SAIs throughout the world.

Electronic copy available at: http://ssrn.com/abstract=2573457

 1. Introduction

Accountability is an important ingredient of democratic rule and good governance. Historically, the
concept is closely associated with accounting though it was first used as a tool by the sovereigns to hold
their subjects into account (Dubnick, 2002). However, with the growth of modern state structure, the
meaning of accountability has reversed. Now the concept indicates the answerability of the government
authorities to the citizens (Bovens, 2005: 183). Furthermore, through moving beyond the narrow realm
of accounting and book-keeping, the o ept has a hie ed a i o i status with normative value
atta hed to it. A ou ta ilit is thus esse tial a d good fo go e e t a d e si pl a t ha e
e ough of it Pos e , ; Pos e & h a tz, ; Pollitt, : . In fact, accountability is an
important component of the "good governance" paradigm propagated by the World Bank and it is
considered as a basic "human right". Accordingly, accountability allows the citizens to claim their rights
and at the same time, accountability mechanisms can play an effective role to prevent corruption which
will allow the state to move towards development (WB, 2011). The relationship between accountability
and prevention of corruption has been widely acknowledged. In the World Development Report of
2004, the World Bank points out that the absence of accountability mechanisms may result into - a.
misallocation of public resources; b. failure of public resources to attain desired outcomes; c. weak
performance by service providers and; d. lack of awareness i pa t of the se i e e efi ia ies to "a ail
themselves of services" (WB, 2004).

E e though the sig ifi a e of Accountability is ell-recognized in the literature of governance and
development, defining the concept has always been difficult. The simplest definition of the concept
refers to a "process of holding to account, overseeing, and keeping in check those persons who are
entrusted with public responsibilities in the fulfillment of their tasks and functions" (Schedler, 1999).
However, recent literature on the concept points out that accountability comprises of two different
stages- fi st, the e is a all fo a ou ta ilit , "that is ei g e ui ed to p o ide a e pla atio of hat
has been done, or not done, and why" and the second stage is the process of holding accountable, i.e.
"being sanctioned and put into effect remedial measures if something has gone wrong" (Jones and
Stewart, 2009). In other words, accountability means not only the process of holding someone
accountable but also assigning blame or rewards. Therefore, institutionalization of accountability
mechanism requires establishing relationship between two or more actors where one of them is
obligated to explain and justify his or her actions to the other(s) and face consequences.

In identifying this relationship, accountability literature has concentrated on two different dimensions.
The first one is considered to be a relationship between the citizens (electorate) and the government.
This dimension, known as democratic or vertical accountability, allows the citizens to elect the members
of a representative body which in turn selects the members of the government. The government
th ough i iste ial espo si ilit to the ep ese tati e od , e de s a a ou t of its a tio to the
citizens (White & Hollingsworth, 1999:7). The citizens evaluate the performance of their elected
representatives and render their judgment through electing or not electing them in the elections. The
second dimension concentrates on the relationship between the elected representatives and the public
agencies that carry out different programs and policies. Often known as managerial, administrative or
horizontal accountability, this method is exercised in the following way- first, the elected
representatives design a number of rules and regulations that guide the activities of different agencies
and second, they also establish a number of institutions that monitor whether the agencies are
complying with these rules and regulations. As Diamond (2008) explains, horizontal accountability
invests some agencies of the state with the power and responsibility to monitor the conduct of their
ou te pa ts . These i stitutio s a e k o as "i stitutio s of a ou ta ilit " a d of these, the

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particularly important ones are- ou te - o uptio o issio , o uds e , audit o issio s,
parliamentary oversight committees, judiciary which are bestowed with the responsibility of
i estigati g e ide e of aste, f aud, a d a use e e uti e age ies .

Of these, Supreme Audit Institutions (SAIs) are set up based on the constitutional and legal framework
of countries. As per the legal requirements, they help the legislatures to enforce accountability, reduce
fiduciary risk and measure the outcome of different programs. The main role of the SAIs is to monitor
and examine the activities of different government agencies and to publish report on the findings. From
the perspective of ensuring democratic accountability, the Supreme Audit Institutions (SAIs) play two
key roles-

The SAIs analyze whether the agencies are complying with existing rules and regulations and
through doing that examines the credibility of the financial data reported by them. Traditionally,

this has been the main role of these institutions (WB, 2001).
In the last few decades, the demand for public services has increased and this has been
a o pa ied g o i g p essu es fo a ou ta ilit . Co se ue tl , the ou t ies espe iall
the de eloped o es ha e espo ded to a ou ta ilit i pe ati es a ti ulating institutional
efo s fo used o pe fo a e a d esults of go e e t ope atio s a d p og a s Pos e ,
2011: xii). Most of the SAIs have now moved beyond the compliance and financial auditing and
started focusing on performance auditing and assessments.

When I was developing my proposal for the paper, my plan was to evaluate the performances of the
SAIs and explore why the degree of influence exerted by these institutions vary across countries.
However, while analyzing the experiences of different Supreme Audit Institutions, especially the
experiences of the Government Accountability Office (GAO) of the USA, I realize that "influence" is
essentially a problematic term and measuring the "influence" of an institution is extremely difficult. In
fact, even if we try to determine institutional influence by looking at the recommendations
implemented by the legislatures and/or the executives, the problem does not disappear. The simple
reason behind this is- all recommendations and report in the long run are relevant as they can either
become important in a few years or they can feed into other reports.

At the same time, while analyzing the literature on the audit process it also becomes clear to me that in
the last few decades, the role and functions of the SAIs have gone through significant changes in
response to the evolution of the audit procedure. Up to the late-60s, the SAIs focused on transactional
and financial auditing and consequently, the concentration was on ensuring financial control and
checking that government money and assets were being spent as per the legal requirements. However,
in the late-60s, the developed democracies while responding to the worsening financial condition
de ided allo ate li ited fi a ial esou es to ea h poli easo a l a d effi ie tl Azu a, :
86). This change in focus in terms of providing effective services in an efficient manner also forced the
SAIs to respond accordingly and we witnessed a shift in emphasis- whereas traditionally audit activities
were carried out to ensure the responsible use of public money, now a day, audits concentrate more on
e aluati g the pe fo a e of go e e t age ies, hi h is the fo us of toda s public
a ou ta ilit uzuki, : . In effect, performance auditing has now become the most popular
form of audit and is now practiced by most of the western developed democracies. Furthermore, the
developing countries are also being encouraged to adopt this practice. At the same time, Power (2005)
points out that as the SAIs are now moving from their traditional role of compliance auditing towards
analyzing the performance of government organizations through performance auditing, these
institutions are now playing a role in determining policies and e o e e pli it i st u e ts of pu li

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management reform with a key role in monitoring the activities of the state with ever more regulatory
a d o e sight fu tio s Po e , : .

However, this change in focus comes with a caveat- even though the SAIs are supposed to be
"autonomous" and free from all types of political pressure, while performing these new roles and
responsibilities, these institutions now have to interact with different political actors. As a result of this
interaction, the SAIs, through concentrating on measuring the performance of different government
programs/ agencies, have started playing an important role in the political/policy arena and this has
made the SAIs more relevant in the political realm. Consequently, the SAIs are now facing a unique
dilemma- whereas autonomy requires that the SAIs be completely independent from the political actors
while performing its duties, relevance requires keeping close connection with these actors so that their
recommendations are being implemented. In other words, if the institution concentrates too much on
protecting its autonomy by maintaining its distance from the other political actors, it may fail in affecting
the policies/programs as per its recommendations. On the other hand, if the institution focuses on being
relevant in the policy arena by interacting with the political actor, it may find itself vulnerable to political
demand or pressure and thereby, may lose its autonomy.

Considering all these factors, I have decided to significantly revise my research focus. Instead of
exploring the reasons behind the variance in the degree of influence exerted by the SAIs across
countries, in this paper, I have made an effort to capture the dynamics of the autonomy-relevance
dilemma faced by the SAIs and explore the strategies adopted by these institutions in dealing with this.
The research questions that I am addressing are-

A. How and why does this tension between autonomy and relevance arise?
B. How do the SAIs deal with the tension between autonomy and relevance?
C. What types of strategies do SAIs take to balance the tension between the need to preserve its
autonomy and the requirement to maintain its relevance?

The goal of this paper is to develop a broader theoretical framework through analyzing the case of an
SAI, which will eventually answer these research questions. However, before moving into detailed
discussion, two things should be mentioned here-

First, given that I am attempting to develop a theoretical construct, instead of comparing the SAIs of
different countries, I have decided to analyze the historical growth of one specific SAI. Therefore, this
exploratory research strictly relies on "thick description" of one particular SAI. For a study like this,
selecting an appropriate case is extremely important and for the purpose of the paper, I have decided to
focus on Government Accountability Office (GAO) of the United States.

Second, the paper is actually part of my dissertation project. However, my dissertation is at its very early
stage and I am in the process of collecting data through reviewing selective reports produced by the
institution over 92 years and interviewing key individuals who are or were associated with the GAO. In
this paper, I have shared some of my initial findings. However, given that it is an ongoing project and so
far I have collected a limited amount of data, the conclusions drawn through this paper should be
considered as working assumptions.

The paper has seven sections. The next section reviews the literature on the SAIs and points out why the
existing scholarship is inadequate to analyze the dynamics of autonomy relevance dilemma faced by
these institutions. The third section of the paper operationalizes the research question and key terms

5
and also talks about the significance of the study. The fourth section describes the methodology that has
been followed in developing the paper. The next section provides an in-depth description of GAO and
analyzes the historical growth of the institutions. In section six, I have made an effort to develop a
theoretical framework to explain how the GAO has dealt with the autonomy-relevance dilemma
throughout its life-span. The concluding section summarizes my main arguments.

2. The Supreme Audit Institutions: The "Neglected" Political Institution

Even though the concept of accountability has achieved an iconic status, so far little attention has been
paid to different institutions that are bestowed with the responsibility of ensuring accountability.
However, recently, the international development organizations like World Bank, Asian Development
Bank have started to focus on these institutions and they have developed policy prescriptions especially
for the developing countries to strengthen the role played by these. Nevertheless, an analysis of these
institutions from a political science perspective is still missing and in most cases, the existing studies
concentrate on legal issues while ignoring the political role played by these institutions.

Like most other Institutions of Accountability, the Supreme Audit Institutions (SAIs) have garnered very
little attention especially in regard to the role played by these institutions in shaping the outcome of
different policies. Till today, the literature on the SAIs largely relies on the classification developed by
the development organizations in explaining their roles and functions. However, as I will explain, this
classification, though useful, is not really helpful in developing a political analysis. As the available
literature on the institution suggests, SAIs they can be categorized into four groups -
a. The Napoleonic Court of Accounts
b. The Collegiate Body
c. The SAIs as government department
d. The Legislative Audit Office ((IMCL, 2003; Lekorwe, 2008).

Of these, The Napoleonic Court of Accounts is modeled on the French system and this particular type of
SAI enjoys judicial authority and remains independent from both the legislature and the executive. This
particular format of SAIs is found in a number of European countries including France, Belgium and few
Francophone countries. On the other hand, even though the Collegiate Bodies are also called Court, they
do not enjoy any judicial authority. In almost all cases, the courts perform a combination of compliance,
financial and performance audit. The Algamene Rakenkamer of the Netherlands and Bundesrechunghof
of Germany are examples of this particular type of SAIs.

The SAI as government department is probably the rarest type of Audit institutions. In this case, the
institution is under the rubric of the executive that is the subject of most audits. The National Audit
Office of China can be cited as a model of this type of SAI. Finally, the Legislative Audit office model is
found mainly in the commonwealth countries (e.g. UK, Australia, India, Bangladesh, Sub-Saharan
Anglophone African countries etc.) and in Presidential systems like the United States. In this particular
system, a Comptroller and Auditor General (C&AG)/Auditor General heads the Office. The C&AG
remains free from the executive organ and reports directly to the parliament or Congress. Contrary to
the Court of Accounts, the Westminster SAIs serves no judicial function rather emphasizes on
compliance, financial and performance auditing. The audit reports are submitted to the entire
parliament or to specific committees, such as the Public Accounts Committee of the parliament or
substantive committees of Congresses which use audits to inform its oversight function.

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Looking at this taxonomy of the audit institutions, it becomes clear that this classification does not take
under consideration the political system or the political environment within which these SAIs function.
At the same time, this particular framework also does not capture the mode of interaction between
these institutions and the political actors. Consequently, whereas the categorization focuses on the
organizational structure, it fails in pointing out the interaction between political push and institutional
pull, which is essential for responding to the research questions.

These limitations of the existing literature for analyzing the Institutions of Accountability in general and
the Supreme Audit Institutions in particular indicates the importance of developing a theoretical
framework that will focus not only on the organizational structure but also will be able to capture the
variation in interaction between the SAIs and other political actors (which will indicate whether the
institutions can deal with political push and thus preserve its autonomy) and the institutional ability of
the SAIs in ensuring accountability through performing their designated duties (which will indicate the
role played by the institution in the political milieu). In fact, developing this theoretical framework and
categorizing the SAIs as per that framework will allow us to compare and explore how different SAIs deal
with the autonomy-relevance dilemma. In this paper, I will attempt to develop a theoretical framework
as a way to begin unpacking the political relationships and roles played by SAIs throughout the world.

3. Conceptualizing the Research Puzzle

While analyzing the autonomy-relevance dilemma faced by the SAIs, two issues should be taken under
consideration-

First, SAIs work as an agent of the legislature or the executive based on their positioning in the state
structure. Given that the SAIs are established by the executive and/or the legislature based on the legal
framework of the country, they are always vulnerable to control by these political actors. Using the
Principal-Agent Theory, Miller (2005) suggests a solution to this vulnerability. According to him, in any
political system, the rulers will always try to pursue his/her self-interest, which can often become "self-
destructive". In such a situation, ruler's focus on self-interest will mar the basic principles of democratic
governance. In fact, to deal with this problem (what Miller called "moral hazard" of the principal), the
state delegates certain responsibilities to the autonomous agents and the main goal of these agents is to
"defy the self interest" of the principals". Therefore, to be effective as an agent, the Institutions of
Accountability in general, and the SAIs in particular, have to have certain degree of autonomy which will
allow them to be "non-responsive to the ruler's interest". Thus, autonomy is a key ingredient for
ensuring the success of the SAIs.

Second, as mentioned earlier, traditionally, the SAIs focused on identifying fraud and waste in the
financial system and submitting the report of its findings to the legislature (or executive). The success
relied on identifying the abuse of public resources. However, the advent of performance accountability
has posed a new challenge for the SAIs. At one end, they have to concentrate on measuring
performance of different government programs, agencies which forces the institution to move towards
policy/politics realm and on the other, its success now depends on calculating the number of
recommendatio s that ha e ee i ple e ted the legislatu e. I deed, the e is a push a d pull
d a i that i gs AIs to e o e ele a t to politi al leade s a d i te ests. O the o e ha d, AI s
have an interest in securing the implementation of their recommendations, causing them to step up
thei e gage e t ith the politi al p o ess. O the othe ha d, politi al leade s o e to ie AI s
performance audits as more central to their political and governance challenges, prompting political
leaders to draw SAIs more centrally into their legislative development and oversight agendas.

7
This focus has made the SAIs more relevant in the political realm and brought it closer to the political
actors. As a result of this, we are witnessing a complex tension between relevance and autonomy faced
by the SAIs. As I have indicated earlier, the goals of this paper are to capture the dynamics of autonomy-
relevance dilemma faced by the SAIs, to identify the factors that cause this dilemma and explore the
strategies adopted by the institutions to deal with this. In order to do that, a proper definition of the two
key research concepts, i.e. autonomy and relevance needs to be developed.

Institutional autonomy is often thought as the "degree of freedom an institution has to steer itself"
(Askling et al, 1999; Marton, 2000). However, this definition is vague and does not provide a clear
description of the term. From this perspective, Oliver's (1991) definition is more appropriate. She
defined autonomy as an institution's abilit to " ake its o de isio s a out the use a d allo atio of
its i te al esou es ithout efe e e o ega d to the de a ds o e pe tatio s of li kage pa t e s"
(Oliver, 1991: 944-945). In case of the SAIs, the executive and the legislative branch can be considered as
the linkage partners and thus, its autonomy, to a large extent, will depend on its ability to defy the
demands and expectations of these "partners". In fact, as mentioned above, as per the Principal-Agent
theory, without having this ability, an SAI will never be able to perform in an effective and efficient
manner.

Furthermore, the definition also indicates that the autonomy of the SAI refers to its capacity (i.e. ability
to make its own decision) to conduct self-initiated audit activities (i.e. "use of internal resources") and to
enjoy complete control over the procedure of auditing (i.e. allocating resources). In other words, the
term autonomy is comprised of two different components- substantive, i.e. the power of the institution
to determine its own goals and programs (in case of the SAIs, the power to conduct self-initiated
studies) and procedural, i.e. the power of the institution to determine the means by which "its goals and
programs are pursued" (In case of SAIs, the control over the means of conducting audit) (Berdahl, 1990:
170).

On the other hand, in this context, relevance refers to the ability of the SAIs to create an impact on the
policies or programs through submitting its reports and findings to the proper authority. In other words,
an SAI will become relevant only when it will be able to contribute to the policy dialogue. However,
based on Carpenter's (2001) discussion on bureaucratic autonomy, it can be argued that an SAI can only
influence the political actors and/or organized interests to accept its argument on policy issues when it
can "establish political legitimacy- a reputation for expertise, efficiency, or moral protection" (Carpenter,
2001: 4). Thereby, the relevance of the SAIs in the policy domain depends on the ability of the institution
to portray itself as a neutral expert, who "seeks and reports factual information that is countable,
quantifiable and provable" (Mosher, 1979: 245).

Needless to say, in most cases, the SAIs function as agents of the legislature and up to this point, I have
discussed the dilemma faced by the agent. However, it also raises an important question, i.e. whether
the existing environment within which the SAIs function allows these institutions to develop strategies
to deal with this problem. In order to analyze this, it is necessary to explore the role played by the
principals (in this case the legislatures and/or the executives) within this whole political process.

As I have argued earlier, the principals set up the independent agent to deal with its "moral hazard", i.e.
to promote its self-interest which may harm the democratic principles. Nevertheless, this does not mean
that they, after setting up the institution, will stop interfering in the institution's functions. In fact, the
tension between autonomy and relevance takes place only when the principals attempt to cross the

8
boundary and creates pressure on the SAI. However, while doing that, the principals may also face the
same dilemma. The reason behind this is, the principals are always in need of credible information in
developing their policy choices. As Joyce (2011) argues, "policymakers and their constituents need to be
confronted with the truth- i the fo of the ost eut al a al sis possi le o pa ti ula poli
choices" (Joyce, 2011: Loc 165). This need for information creates a difficult situation for the principals -
at one end, they look for credible, neutral experts whose information they can trust which makes them
dependable on the institutions. On the other hand, as the principals are asking the SAIs to be more
relevant in the political process by providing information about policy decisions, they are actually
threatening the autonomy of the institution, as they want it to look into policy areas as per their
requirements and in some cases, they expect specific results- "to make their policy proposals look better
(less costly) and other policies look worse" (Joyce, 2011). This creates the essential dilemma for the
principals- if they do not succeed in incorporating the SAIs within the policy process, they will not get
credible, unbiased information which they badly need and if they start dictating the terms, the SAIs will
lose autonomy and the credibility and legitimacy of the information will be undermined.

Given that the SAIs and the Members of legislative or executive organ (depending on the institutional
set up of the SAIs) have two different sets of priorities, it requires a synthesis between these two very
different worlds without which the interest of both experts and politicians are undermined. Therefore,
the question is- is it possible to develop such a "bounded rational" strategy which will "satisfy" both the
actors? If yes, how? And, what happens if it becomes impossible to develop such a strategy? Finding
answers to these questions are major goals of this research and through answering these questions, it
will be possible not only to analyze the dynamics of autonomy-relevance dilemma but also to explore
and explain the specific strategies adopted by the SAIs

In order to develop these answers, I intend to provide a framework anchored in a case study of the
acknowledged worldwide leader among SAIs the Government Accountability Office (GAO) of the
United States. I will attempt to provide a historical analysis to find out how the GAO has attempted to
deal with the autonomy-relevance dilemma over time, what strategies it has undertaken and how
successful these strategies have been in dealing with this dilemma. In other words, I have decided to
rely on exploratory research and "thick description" of one particular SAI.

4. Methodology

Case Selection

In order to develop the theoretical framework necessary for understanding the dynamics between
autonomy-relevance dilemma, choosing an appropriate case is extremely important. Choosing the right
case is important as it will help me not only in understanding the experiences of a particular SAI but also
in taking the first step in developing a theoretical construct which will provide a basis for comparing
different SAIs. I argue that I should select an SAI which have the experiences of both living without
facing the tension and surviving within this tension. At the same time, such an institution should have
both experiences- it should suffer from political push and also should show some signs of responding to
the political pressure.

The GAO is an excellent candidate for a single case study for various reasons. First, the age s histo
provides a singular case of an audit institution that has evolved through the entire spectrum of the
autonomy-relevance dilemma. The GAO has during its 90 year history ranged from a period of studied
independence and autonomy from the Congress and other actors and the most recent period of strong

9
interdependence with the Congress that raises the autonomy-relevance dilemma. Thus, analyzing the
experiences of the GAO allows me to identify the reasons behind the variation and at the same time,
helps me to compare different strategies undertaken by the agency in different time-frames. This study
on GAO may also be considered as a comparative study. However, instead of doing a cross-country
comparative study, I am comparing the same institution at different time frames. As I will discuss later, I
have divided the entire life-span of GAO into four eras and thereby, explore how the same institution
deals with different degree of autonomy-relevance dilemma at different times.

Second, the GAO s le el of i ol e e t ith poli ake s o ajo poli issues is at the fo ef o t of
the worldwide SAI community in the depth and scale of engagement with policymakers. However, since
a othe ad a ed atio s AIs a e getti g pulled deepe i to the poli aki g p o ess, a deep
understanding of the GAO experience has worldwide significance. The engagement of auditors with
policymakers challenges a central tenet of the audit standards that guides the profession resting on the
credo of independence. Indeed, when GAO has been examined by other SAI staffs in a professional peer
review process, GAO has had to address how it can sustain its vaunted independence in the face of the
significant role played by Congress in setting the audit agenda for the agency.

Finally, in case of the SAI, significant attention has been attributed to the concept of independence and
it has been often argued that it is not possible for an SAI to become an autonomous actor without
ensuring its independent status. In fact, the INTOSAI, the umbrella organization of international
government audit community has acknowledged the significance of independence of the SAIs as early as
1977 and the Lima declaration adopted by the organization stated that the Supreme Audit Institutions
can accomplish their tasks objectively and effectively only if they are independent of the audited entity
and are protected against outside influence (Fiedler, 2004: 108). This focus on independence was
further highlighted in the 2007 Mexico Declaration of SAI independence. According to different analysis,
the basic principles of the independence of SAI includes-

a. Independence from different branches of the government, i.e. the SAIs should remain free from
the influence of both the legislature and the executive. As the main goal of the SAIs is to audit
the activities of the executive organ, it should perform this while remaining outside of the
executive which will protect itself from undue influence. Independence of the SAI from the
legislature is a complex issue as the SAIs of most countries work with or on behalf of the
go e e t. Ho e e , a i depe de t AI should ot e su je t to a di e tio s the
legislature in the p og a i g, pla i g a d o du ti g of its audits .
b. Functional Independence- the concept of functional independence is comprised of two
dimensions- at one end the SAIs should have the ability to decide its audit activities and
guidelines and on the other, due importance should be placed on the reports submitted by the
SAIs to the appropriate bodies. If the SAIs does not enjoy discretion in discharging its audit
activities, it will eventually depend on the other organs of the state and may become a political
tool. O the othe ha d, if AIs epo ts a d e o e datio s a e ot o side ed to e
important, it will not allow them to hold the government agencies accountable.
c. Financial independence, i.e. the SAIs should have adequate independence in determining the
size of their budgets and in allocating it appropriately.
d. Organizational independence, i.e. the Auditor Generals or heads of the SAIs should have tenure
security and they should not perform at the pleasure of the government. It has been argued that
if the appointment and removal procedure of the Head and members of the SAIs are not clearly
stipulated in the constitution and legal framework, the SAI may not be able to perform

10
 independently. Furthermore, an independent SAI should enjoy the authority to employ and
dismiss its own employees (INTOSAI Audit Standard)

If we look at the four tenets of independence, it becomes clear that GAO faces challenges in fulfilling
these criteria. Mosher (1979) explains it best- "The uniqueness of the GAO stems in part from its legal
and official status in the U.S. government. It is an arm of the Congress, from which it receives its powers,
responsibilities, and resources" (Mosher, 1979: 2). This question of independence is anything but clear
in a system of separated institutio s sha i g po e s. O the o e ha d, the GAO s audit age da is
critically shaped by Congressional requests and laws and its budget is controlled by the Congress. On the
other ha d, Moshe o ludes that GAO has a distinct identity and a considerable degree of
independence in terms not only of law but also of discretion in its program and internal administration"
(Mosher, 1979: 259).

Many international organizations assert a formal and structural interpretation of auditor independence
only those institutions that can control their own agendas and budgets can be said to be independent
from this perspective. However, this study will test the proposition that it is indeed possible for an SAI to
preserve its autonomy even when it has to depend on the legislatures for its functions and resources,
i.e. when it is not independent in the traditional sense.

Choice of Method and Data Collection

For the purpose of this paper, my goal is to develop a theoretical framework which will capture the
dynamics between relevance and dilemma and in order to do that, I have concentrated on the
experiences of one particular SAI and have made an effort to explore why that particular SAI had to face
different levels of autonomy-relevance dilemma at different stages; how the SAI had to deal with this
dilemma and what types of strategies the SAI undertook over years to deal with this. In other words, I
have concentrated on explaining and exploring the dynamics that takes place in causing an event.

As Ma ell poi ts out, fo a stud like this, i.e. he e the esea he t ies to, "see the o ld i
terms of people, situation, events, and the processes that connect these" and is interested in capturing
the pa ti ipa ts pe spe ti es of the "e e ts, experiences, and actions they are involved with or engage
in; developing an understanding of the particular context "within which the participants act, and the
influence that this context has on their actions"; and, understanding the "process through which events
and actions take place", s/he should conduct qualitative studies (Maxwell, 2013: 30-31). Needless to say,
my goal is exactly what Maxwell has stated and in this paper, I have followed the qualitative research
approach.

In my original research project, to develop a comprehensive theoretical framework, I have decided to

The changing role of the GAO

collect primary data on the following issues-

The external pressure faced by the GAO over time and whether the pattern or type of pressure

The role played by the GAO in the policy process and the way GAO plays this role (both formal
has gone through changes

The perception of the people in regard to institutional autonomy and GAO's ability in terms of
and informal)

The specific strategies or approaches taken by the outside actors to create pressure over the
protecting this autonomy

GAO

11
 The specific strategies or approaches taken by the GAO to respond to this pressure.

In order to do that, I will review the annual performance report produced by the GAO in the last 92
years. At the same time, I will randomly select 10 reports prepared by the GAO and submitted to the

how the focus of auditing conducted by the GAO has shifted over time,
Congress from each decade and by reviewing these 90 reports will examine

whether these reports were/are self-initiated or generated through congressional request

whether the GAO has become more responsive to the Congressional need
how the GAO develops its audit strategy
the impact of these reports

Furthermore, to find out the answers to the general questions regarding GAO's interaction with the
Congress and specific questions in regard to the reports mentioned above, I will focus on semi-
structured interviews and will try to interview about 40 ex and current GAO officials and Congressional
staff.

Given that I am still at the very early stage of collecting data, in this paper, I have mainly relied on
secondary data. In order to analyze the development of the GAO, I have extensively reviewed the
literature that has covered the historical growth of the institution. I have done so to understand how the
interaction between the GAO and the Members of the Congress has evolved over time and how this
evolution has generated variation in the level of autonomy-relevance dilemma. However, while doing
that I have to face one significant problem- the literature on the GAO is scarce. There are very few
studies on the GAO and a number of them mostly provide historical narratives (Trask, 1996; Pois, 1979).
So far, only four systematic studies have been done on this institution which either attempt to analyze
the relationship of the GAO with other political actors (Mosher, 1979, 1984; Rubin, 2003) or explore the
effort of the leadership of the SAI in changing the organizational culture (Walker, 1986). In fact, in the
last 27 years, no comprehensive study has been done to examine the changing role and functions of the
institution.1

In this paper, to deal with this problem, I have adopted a limited approach. I have randomly selected
seven annual performance reports of the GAO (Annual Performance reports of 1977, 1978, 1979, 1980,
1982, 2008 and 2011) and by reviewing these reports have attempted to identify whether the GAO-
Congress relationship has indeed changed over time. I have specifically tried to explore whether the
GAO has become more responsive to Congressional Requests and whether the participation of the
institution's members in Congressional hearing and testimonies has increased over time. This will
eventually show the changing pattern of interaction between the Congress and GAO. I have also
reviewed four in-depth interviews conducted by the GAO as part of its oral history program.
Furthermore, in order to understand the effect of the interaction, I have so far interviewed two current
GAO officials and data collected through these interviews have also been included in this paper.
Nevertheless, as I have indicated in the introductory section, due to the lack of adequate primary data,
the conclusions that I have drawn should be considered as working assumptions.

5. The Case of GAO: From Autonomy to 'Constructive Engagement'

1
Even though Rubin's (2003) book has a chapter on GAO and sheds some light on the changing relationship
between Congress and the GAO, it mainly focuses on the institution's ability in managing budget cutback.

12
Mosher's 1979 and 1984 studies on the institution are relevant for my paper. Mosher has taken an
"outside-in" approach in analyzing the GAO and portrayed how the change in the broader socio-
economic environment has forced the institution to change its function and roles over time. However,
Mosher's study ends in 1978 and according to him, up to that point, the GAO has gone through three
different phases-

The First GAO (1921- 1945)

The Second GAO (1945- 1954)
The Third GAO (1966-1978)

In his study, Mosher points out that the growth of GAO is closely related with the development of an
executive budget system and in fact, the Budget and Accounting Act of 1921, which laid the foundation
of the GAO, as a p odu t of the d i e fo e e uti e udget s ste Moshe , : . Du i g the
late nineteenth and early twentieth century, there was growing suspicion about the existence of
corruption, fraud and waste in the government activities. This concern coupled with greater
dissatisfaction of the general people about the economic condition gave rise to a variety of reform
efforts. Considering the situation, the administrative scholars called for a larger reform movement which
relied on the following themes- "economy, efficiency, honesty, control and accountability. Its tools were
also comparable: strong central executive leadership; reorganization along rational and hierarchical
lines; merit and specialization of personnel; planning; executive budget; and an independent audit"
(Mosher, 1979: 44). The Budget and Accounting Act of 1921 was thus an outcome of a broader reform
movement and its main goal was to establish an executive budget system. At the same time, up to that
point, the internal control of the federal financial system was ensured by the Department of Treasury
and "one, two or three Comptrollers" and one to six auditors were in charge of conducting the audit.
The Act of 1921 not only allowed the development of an executive budget system but also established
the GAO, which was put in charge of controlling all accounting activities of the government. This new
institution was brought under the control of the Congress and Mosher indicates that most member of
the Congress considered the GAO as a "quid pro quo" for establishing the executive budget system. The
Act of 1921 stipulated that the Comptroller General and Assistant Comptroller General would be
appointed by the President with the consent of the Senate and they would enjoy terms of 15 years. The
Comptroller General and the Assistant Comptroller General could be removed only by impeachment or
concurrent resolution of both houses of the Congress.

In the remaining part of this section, relying on the existing literature, I will make an effort to explain
how the GAO's role, functions and interaction with the legislative branch changed over time and how
that has affected the autonomy-relevance dilemma faced by the SAI. In identifying the time frame, I
have relied on the basic framework developed by Mosher and have made two changes- first, I have
extended the third phase from 1978 to 1985 and added an extra time-frame, i.e. 1985 to present.

a. The Formation Phase (1921- 1945)

During this period GAO was led by John R. McCarl (1921- 1936) and Lindsay Warren. The agency mainly
concentrated on reviewing and checking of the accounts of the thousands of federal disbursing offices
a ou d the go e e t a d of the suppo ti g do u e ts a d ou he s that a o pa ied the
(Mosher, 1984). At the same time, the GAO rendered opinions on the matters of law as the agency
enjoyed the power to provide final interpretation in laws related with appropriations. A key feature of
this period was the effort of the agency to establish itself as independent organization separated from

13
both the Congress a d the E e uti e. The s Act did not associate the agency with the Congress and
it was virtually left alone. Though it did submit annual reports to the Congress, the Congress remained
largely apathetic to the need of the agency. Moreover, due to its strict adherence to legal frameworks
and accounting principles, it developed a somewhat hostile and tensed relationship with the executive
organ. In fact, as Havens (1990) pointed out the first Comptroller General of the GAO, John McCarl
essentially concentrated on two things- he was really concerned about wasteful standing and made a
conscious effort to establish GAO as an independent institution. In some cases, he took matters too far
a d "did nitpick, he took some dollar exceptions, and did some ridiculous things" (GAO, 1990). For
instance, during his tenure, "in one now humorous incident, GAO questioned how the Interior
Department intended to use a camera it had purchased. The penciled response to the auditors from
Secretary Harold Ickes was brief and to the point, 'To take pictures, you damned fool'" (Havens, 1990:3).
Even though McCarl's stance often brought the institution into frequent conflict, it did help the GAO to
build its own reputation. In 1990, in an interview (which was conducted as part of the oral history
program), the GAO officials who worked during that period stated that, "He was rather standoffish; he
as 't taki g o de s f o a od up o the Hill.Late , t o e e s told me that you have a real
good organization, but the reason you have a good reputation for independence is McCarl. I think that is
true" (GAO, 1990: 12-13). Lindsay Warren, after taking control from McCarl followed the same trend.

However, the GAO, at this early period had gone through some significant events which had far reaching
consequences. Though the Congress rarely took an interest in the need of the organization and did not
utilize the GAO reports in holding the executive accountable, it played the role of the protector for the
agency. For instance, in 1932 when President Hoover submitted a reorganization order to the Congress
hi h ould ha e t a sfe ed the po e to p es i e a d supe i te d a ou ti g fo s, p o edu es
and audits of the depart e t a d age ies f o the GAO to the OMB the BOB , Co g ess p o ptl
voted it down. Similarly, during President Roosevelt's efforts of reorganization, the Congress protected
the GAO by exempting it from the Reorganization Act of 1937. This was probably due to the fact that in
a shared power system, the Congress wanted to have some leverage at its disposal which it could use
later. Whatever the reason is, these incidents eventually indicate the growth of a close relationship
between the Congress and the GAO. In fact, the ex-GAO officials commented that the institution started
to help the legislatures in developing their bills through providing necessary information in the 1940s.

The discussion above points out two things- first, at this early stage, even though the institution started
to develop a close relationship with the Congress, it mainly focused on maintaining its autonomy by
keeping distance from the legislatures. Second, the GAO concentrated on voucher-based auditing and
submitting report to the Congress and did not take any initiative to play any role in the policy arena. In
other words, as the institution was at its formative stage, it did not have to deal with the autonomy-
relevance dilemma.

b. The Professionalization Phase- from traditional to comprehensive auditing (1945-1966)

That the role of leadership is really significant in defining the role of the agency can be best exemplified
through the contribution of Lindsay Warren, the Comptroller General of the GAO during 1940-1954.
During his tenure, the agency reevaluated its relationship with other agencies and demonstrated a
greater willingness to work co-operatively with the executive organ. Warren was a member of the
House and he used his earlier connection for the benefit of the agency. In fact, during his tenure,
through the Reorganization Act of 1945, the Congress acknowledged the GAO as an institutional tool of
the legislative in holding the executive accountable. Warren eventually revolutionized the functioning of
the agency. The World War II overwhelmed the agency with paperwork and it faced a backlog of 35

14
million unaudited vouchers in 1945. As a response to this, the agency shifted its focus from voucher
auditing to comprehensive auditing, i.e. auditing tended to concentrate o the e onomy and efficiency
ith hi h fu tio s e e a ied outthe isdo a d effe ti e ess of a age e t Moshe , :
137). Consequently, the GAO, in partnership with Treasury department and Bureau of Budgeting,
focused on developing a system that would bette se e the eeds of age a age e t,
go e e t ide fi a ial epo ti g a d udgeti g Moshe , : . The institution decided to
transfer the basic responsibility for control and internal auditing to the operating agencies while it
assumed the role of prescribing principles and standards to govern all federal accounting and auditing.

However, it is important to note that during this period, the interaction between the Congressional
Committees/Members and the GAO intensified. The Office of Legislative Liaison (OLL) was established
and it was incorporated in the GAO's organizational chart in 1956. At this stage, even though the GAO
still focused on the accounting functions, a number of its officials worked closely with the Congressional
Members and the committees to develop and revise legislation. As one ex-GAO employee recalled,
"When we worked with the committees like that, we sat down with them in the drafting sessions. We
helped revise the legislation, even wrote speeches for the Congressmen, and helped prepare the
committee report" (GAO, 1990: 11). However, most probably this close connection with the Congress
was maintained at an individual level as few other employees pointed out that they never had any such
experiences and in fact, GAO, as an institution, still preferred to maintain its distance from the legislative
organ. The Congress also did not seek help from the institution on a regular basis and the GAO seldom
testified before the Congress. At the same time, the GAO rarely responded to the requests made by the
Congressional members and instead, they tried to "develop interest" among the committees on the
issues investigated by the GAO on its own initiative. For instance, in its annual report submitted to the
Congress in 1963, the institution stated that in that fiscal year, the GAO submitted 818 audit reports and
of these, only 141 reports were prepared in response to the request of the Committees or individual
members on a specific issue (GAO, 1963).

During this time-frame, the enactment of the George Act of 1945 opened a new window of opportunity
for the GAO. This act authorized the GAO to conduct commercial type audits of all government
corporations. As a result, GAO established a Corporate Audit Division and a number of experienced
commercial accountants were hired in that department. This movement started the professionalization
of the GAO. Though the number of total employees reduced from 15000 to 6000, the number of
experienced accounting professionals increased from a handful to 1500. The efforts of professionalizing
the agency continued during the tenure of Joseph Campbell (1954-1966) as the number of accountants
increased to 2200 and the audit reports continued to emphasize on general management.

Based on the above discussion, it can be argued that during this particular phase, the institution was
aiming at developing its own identity by focusing on specific professional development schemes. The
GAO developed its own mission and it performed its roles and responsibilities effectively and efficiently.
It is interesting to note that even though at this stage, the Congress had already acknowledged the role
of the GAO, the i stitutio e ai ed "i depe de t, e e of Co g ess, i the e e ise of so e of its
powers and in its choice of the majority of its projects and the conduct of virtually all of them" (Mosher,
1979: 2). Therefore, even though the GAO started interacting with the Congress, its main focus was
developing its autonomous status and it did not aim at playing any role in the policy arena.

c. The Contested Independence Phase (1966- 1985)

Another major transformation occurred in the GAO when Elmar Staats joined the agency as

15
Comptroller General and du i g this phase, the GAO s ole t a sfo ed f o pe fo i g the financial
and managerial auditing towards evaluating the effectiveness of federal government programs. The
GAOs shift to a ds p og a e aluatio is largely due to the demand of the Congress. During the mid-
60s, the Congress became increasingly concerned about the effectiveness of the Great Society programs
initiated by President Johnson. The shared power structure played its role and the Congress, as it
appropriated the money for these programs decided to analyze the effectiveness of these programs. In
1967, the Congress passed Economic Opportunity Act of 1967 and this act included a provision which
required the GAO to assess and report on the effectiveness of the major poverty programs. In addition
to that, in 1970, the Congress passed the Legislative Autho izatio A t of hi h ga e the GAO "a
very important statutory mission to perform evaluations of government programs and not sheer
financial management" (GAO, 1990: 21).

The introduction of program evaluation served two basic purposes- first, it helped the GAO to become
an expert organization and allowed it to establish itself as an authoritative figure for ensuring
accountability. At the same time, by focusing on program evaluation, the GAO started to move away
from traditional audit functions. Mosher (1979) explains it in the following way- "The bulk of the GAO's
work can be described as problem-oriented, applied research, as expression that many would find more
accurate than 'auditing'" (Mosher, 1979: 247). Therefore, GAO established itself as an organization
hi h as ot o l elia le ut also i sisted that it ust e "la gel i depe de t i the sele tio ,
conduct, and products of its work" (Mosher, 1979: 245). Second, as indicated earlier, GAO started
conducting program evaluation as the Congress wanted it to move towards this particular direction.
Therefore, during this time-frame, the Congress started to send requests to the GAO and also focused
on utilizing the institution to attain the specific policy goals.

When Staats came into office, he concentrated on two things. First, during that period, the agency was
completely unprepared to perform the job of program evaluation. Most of the employees of the agency
were accountants and they had very little idea about program evaluation. As a result, Staats started
hiring new people as program evaluation required people from multiple disciplines. At the same time,
he focused on increasing the expertise of the existing employees.

Second, until then, the relationship between the Congress and GAO was fragmentary and occasional and
neither of the two was interested in developing a long standing relationship. Staats made a conscious
effort to change this trajectory. As Staats explained, "The other thing I did was to ask Larry Powers, who
was an assistant to Mr. Campbell who preceded me, to give me a rundown on the extent to which GAO
was responding to congressional requests for audits. Larry said we did not have that kind of information
here in GAO. I said, well, let's do the best you can and let's get a picture of it. He came back and said 8
pe e t, oughl as ea as he ould dete i e ell, ou k o hat the sto is toda " GAO, : -
7). During this time frame, GAO decided to pay more attention to the Congressional requests and
demands and in 1973, the Office of Legislative Liaison was renamed as Office of Congressional Relations
(OCR) and its main purpose became to provide assistance to the Congressional committees and
individual members. According to one GAO official, "our job really became a public relations activity to
sell the GAO product up on the hill". From this perspective, Staats was probably the first Comptroller
General who considered the Congress as their clients and concentrated on making the work of the
agencies more responsive to the interest of the Congress.

In fact, the annual reports produced by the institution during this period also reflect that. According to
the 1979 annual report prepared by the GAO, whereas in 1969, the institutions' officials testified before
the committee only on 24 occasions, this increased a lot in the mid-70s and in the 1978 fiscal year, the

16
officials testified on 164 occasions. Furthermore, in 1979, "the Comptroller General and his principal
assistants testified before the Congress on 188 occasions" (GAO, 1979: 3). The 1982 annual report also
confirmed that the continuation of this particular trend and according to this, "The Comptroller General
and his principal assistants testified before the Congress on 177 occasions. This compares to 111
occasions five years ago and only 38 occasions 10 years ago" (GAO, 1982: 3).

These initiatives taken by Staats helped the agency in a number of ways. The recruitment of non
accountants which he started in 1968 increased almost every year and by the mid-80s almost 40% of the
total manpower of the agency were non-accountants having academic background in economics, public
administration, law, business, medicine etc. he also concentrated on specialization of the personnel in
specific areas. As a result, the credibility of the GAO reports increased over time and so did the
institutional knowledge. Moreover, Staats was right in assuming that in near future, most of the reports
produced by the GAO would be on program evaluation and by mid-80s about 50% of the studies
undertaken by the agency was on evaluating programs (GAO, 1987).

However, in a later interview, Staats admitted that this "too close to Congress" approach adopted by the
GAO raised concern among the employees of the institution. In fact, they were concerned that the
institution might lose its objectivity and "Congress might dictate what went into these reports" (GAO,
1987: 7). As it turns out these concerns had reasonable basis and a review of the GAO documents
indicates that by the late-70s, the GAO started taking initiatives to limit direct assistance to the
Congressional Committee and members to 30-35%. As one ex-official commented, "we were turning
down requests. You had to fight off request" (GAO, 1990: 18).

Therefore, it can be argued that the introduction of this specific form of "auditing" and congressional
demand made the presence of a unique relevance-autonomy tension inevitable. For the first time, GAO
had to face a dilemma- it could either focus on maintaining its independence by evaluating programs as
it deemed fit (which would allow the institution to preserve its autonomy but deprive it from playing any
role in the policy arena) or it could evaluate the programs as requested by the members of the Congress
(which would allow it to be an important actor in the policy area but might jeopardize its autonomous
status). However, it should be pointed out that during this phase, though the Congress made requests to
the GAO, it did not make any effort to force the institution to comply with these requests. In fact,
Mosher's study points out that whereas the Members of the Congress considered the GAO as an "asset"
and were quite satisfied with the accuracy and reliability of its findings, they were unhappy in regard to
its "choice of project"- "Some thought it insufficiently responsive to Congress and thought that the
Comptroller General should be less independent, particularly in the choice and definition of projects".

In fact, my interviews with the GAO officials show that Whereas Staats took the position that even
though o e fo o je ti it as alid, it as ot a " o ern that ought to override the need to be
greater relevance to the needs of the Congress" (GAO, 1987: 7), as an institution, GAO decided to cling
on to its "independent role". As I have pointed out earlier, by the late 70s, GAO started to fight off the
Congressional requests and it became the institutional norm by the mid-80s. According to one GAO
official-

"During my first week at GAO, they told me that we are gonna take you to a meeting at Capitol
Hill. Don't say anything because you don't know anything. Just sit down and we just want to
show you how we work. And we go up there and the people at the Hill ask us can you look at
this, can you do that. And we say, no...we don't think that it's a good idea (laugh). We have a lot
of other work to do. And I thought this is interesting and I was waiting how the people at

17
 Congress react. Well, the Congress said...ok, that's all right, we understand that you are really
busy (laugh). That is how it was used to be."

In fact, despite maintaining a close relationship with the Congress, most of the GAO's work was done on
its own initiative and it did what it wanted to do. Furthermore, not only the institution had functional
independence, to a certain extent, it also enjoyed financial independence-

"When I joined here, I was once told to go to the Hill to attend a meeting of the Appropriations
committee. So I did. And our CG was coming up to testify to one of the sub-committees. And
this was the time when the agencies were getting about 2% increase in budget. Our CG came
and he said- I need a 20% increase in my budget. And I was thinking- these other people are
getting 2% and you are demanding 20...Gosh...they are gonna be mad at you. This was the time
of Chuck Bowsher. He was a really nice man. And they were saying- Chuck, we can't give you
20%. That is just too much. Can you live with 8? And Chuck was like oh...yeah...we will get by.
We had such a good relationship (laugh)....we had more money than we knew what to do with
it."

Therefore, even though the GAO was a part of the Congress, it concentrated on preparing self-initiated
report and it had succeeded in managing its finance. However, on the flip side, there was very little
interest in the works performed by the GAO- "we did works which nobody really cared about" and it did
not have any significant impact on the policy. So, a close-to-absolute independent GAO had no influence
on the policy.

d. The "Constructive Engagement" Phase (1985-present)

The interaction between the GAO and Congress started to change again in the mid- s. As di ided
go e e t e a e the o , Co g ess ega to fle its us les i the post Wate gate e a a i g
itself to do battle with a Presidency that had become more public and more politicized. Reflecting the
partisan tensions between President Reagan and the Democratic House, on March 21, 1985, the
Chairman of the House Government Operations Committee Congressman Jack Brooks sent a letter to
the then Comptroller General Chuck Bowsher. In that letter, he questioned, among other things, the
general attitude of the GAO that o g essio al e uest o k is disruptive and not as important as
GAO S self-initiated work (Trask, 1991: 110) and pointed out that the institution was supposed to
respect the requests made by the members of the Congress and the GAO should start acting
accordingly.2 The Brooks letter reflected the opinion of the majority of the Congress members and as
mentioned above, members of the Congress were highly critical of the institution for its choice of audits.
During this phase, GAO started to shift its focus from producing self-initiated reports to responding to
the request of the Congress members.

This refocusing of responsibilities created problems for the institution. First, as mentioned earlier, when
the GAO started conducting program evaluation and concentrated on performance auditing, it
eventually assumed the role of policy advisers. In 1979, Mosher warned, "There are dangers for the GAO
in this role, especially in the controversial areas. Its reputation for neutral, nonpartisan objectivity,
above the political fray, could be threatened were it often to take sides and appear as lobbyist on
disputed issues" (Mosher, 1979: 247). Mosher's concern came true in the early 90s. At that point, it
2
It should be mentioned here that given that no studies had been taken on the GAO in the last 29 years, the
significance of Brook's letter had never been analyzed. However, during my interviews, the GAO officials pointed
out this particular letter indeed changed the mode of operation of the institution.

18
became difficult for the institution to avoid policy controversy and through evaluating the performance
of the programs and/or agencies, the GAO was at the center of the policy limelight. Second, things
became more complicated as it started to respond to the request of the Congress Members. The
institution in general gave priority to the Chairs of the Congressional committees, who belong to the
ajo it pa t a d the egi i g of the s, "a lo g pe iod of De ocratic Party dominance made
the GAO look as if it were supporting Democrats at the expense of the Republicans" (Rubin, 2003: 123).
The Republicans were so angry that in 1993, they introduced a "GAO Reform" bill on the House Floor
which suggested that the GAO should focus only on financial accounting. In other words, it indicated
that the institution had no right of conducting performance evaluation or generating self-initiated
reports. Even though the bill failed, it pointed out the attitude of the Republicans towards this particular
SAI. Consequently, when the Republicans took control of the House in 1995, they showed their
dissatisfaction by cutting 25% budget of the agency. In fact, that was the first time in the history of the
GAO that the agency had to go through a budget cut (Rubin, 2003).

This was probably the most difficult time for the GAO and the institution was facing an odd dilemma- if
it decided to refocus on autonomy by conducting mainly the self-initiated reports, not only it would be
unable to create an impact in the policy arena but also had to face the anger of the Members of the
Congress. On the other hand, if it decided to focus on relevance by responding to the request made by
the political actors, the minority party would be furious at the institution and it might have to face the
consequences. However, Rubin's study indicates that the GAO was able to successfully deal with this
dile a i th ee ea s a d "the ajo a i us agai st the age had died do .the e epu li a
majority learned to use GAO services and realized that the GAO was not partisan, merely responsive to
the Committee Chairs" (Rubin, 2003: 124). Therefore, the question is- how did GAO manage to deal with
this problem? Unfortunately, existing literature does not shed any light on this. My initial findings
indicate that the GAO developed and adopted a number of strategies to guide its interaction with the
Congress which helped it in dealing with the tension. These strategies can be categorized into following
groups

Continuing the development of internal expertise- Even though the shift towards performance
evaluation started from the time of Elmar Staats, over period, GAO placed more emphasis in
developing its internal expertise. As a result, it started concentrating on strengthening its
methodological foundation and evaluation became a core function of the institute.
Consequently, the GAO established itself as an expert, neutral and un-bias institution and
succeeded to make the Congress realize this role. As one interviewee pointed out, this neutral
role is well-recognized by the Congress and in effect the legislative organ is also in need of

credible information which is provided by GAO.
Making it relevant- Another key strategy adopted by the GAO was to make it more relevant to
the Congress. As one interviewee pointed out, when the Republican Congress decided to cut the
budget of the agency, the GAO did not fight back. Rather, the Comptroller General met with the
House Leadership and made it clear to them that the GAO worked for the Congress. As its main
role is to assist the Congress through providing relevant information, if it fails to do, the
legislative and accountability function of the Congress will be affected. At the same time,
instead of producing self-initiated report, the institution started to be more responsive to the
Congressional requests. In fact, the annual reports produced by the GAO over the years reflect
this trend. For instance, in its 1977 and 1978 annual reports, the institution stated that even
though it had started to respond to congressional requests, most of its work had still remained
self-initiated (GAO, 1977, 1978). As mentioned earlier, during the tenure of Elmar Staats, GAO's
relationship with the Congress tightened but still, "the proportion of GAO's work in response to

19
 direct congressional requests increased from less than 10 percent to close to 40 percent" (Trask,
1991). In contrast, the 2008 annual report of the institution pointed out that 94 percent of its
work was done in response to congressional requests and only six percent of its work was done
under the Comptroller General's authority to self-initiate engagements (GAO, 2008). During my
interview, a current GAO official also confirms this trend- "since that time, I can probably count
on one hand the number of projects that I have done that are self -initiated and I can't count the
number of others". In other words, GAO made conscious efforts to make itself relevant by

sacrificing its substantive autonomy.
Protecting itself from political manipulation- the GAO's experience in 1994 made the institution
realize that as from this time it would work closely with the Congress, it needs to develop some
codes or guidelines to protect itself from political manipulation. Consequently, a detailed
guideline was developed which described- how it would deal with Congressional requests, how
it would modify and/or transform the requests in workable and un-bias research questions, how
it would decide its methodology and how it would publicize the reports. In effect, GAO had
complete freedom in all these sectors. In other words, even though GAO cannot decide what it
would do, it can determine how it will do it. As one interviewee explains-

"When a request comes along, there is a formal process of accepting and we decide and
we do analyze the riskiness and we assign the risk level , i.e. high, medium or low (based
on 3 Cs- Cost, Complexity and Controversy) and they are managed differently depending
on the risk-level...umm...then we go through the design phase of the work...at the end
of that, we have what we call a design matrix as well as a project plan to finish the work.
The design matrix lays out the research questions we are gonna answer, and describes
the methodology we are gonna use to answer the question and then the project plan
actually lays out the time schedule...the milestones for various steps in the work. And
then there is a message agreement meeting after we are done with the analysis...so that
we think we have a message after doing the analysis and that is the meeting that we do
with our stakeholders where we go over the message"

Overall, what the GAO has done is to ensure that it becomes a relevant actor in the policy process
through preserving its procedural autonomy. This is actually a major shift in terms of understanding the
role of the SAI. Whereas in the past, the GAO mainly focused on self-initiated pure research, eventually
it moved towards as one interviewee termed it -"pragmatic research". From this perspective, GAO
concentrated on policy research and through continuous feedback, established itself as a viable actor in
the policy process.

6. Developing the Theoretical Framework

The discussion above points out two key issues- first, it indicates how the GAO has gone through
different degrees of autonomy-relevance dilemma in different phases of time. Second, it points out the
presence of two different factors in all the time-spans and these two are- the degree of political
pressure exerted on the GAO by the legislatures for being responsive and the degree of
professionalization of the SAI. However, the literature also indicates that the impact of these two factors
has varied over time. At times, the political actors belonging to the Congress did not even acknowledge
the existence of GAO and at that time, the extent of political pressure was quite low. On the other hand,
there were certain times in the history of the institution when the political actors not only realized the
significance of the institution but also made some deliberate attempts to make the institution

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responsive to its demands. This was the time when the extent of political pressure remained high.
Therefore, it can be argued that the in case of political pressure, the intensity ranged from low too high.

The similar conclusion can be drawn about the degree of professional growth in part of the GAO. As the
literature above indicates when the GAO started functioning, it did not have adequate workforce and
the people working there did not have enough expertise to perform their jobs. This was the phase when
the degree of professionalization at GAO was low. However, over time it started to change and the
successive Comptroller Generals of the institution emphasized on recruiting the competent personnel,
train them adequately and developing an institutional knowledge base. All of these played an important
role in positively affecting the degree of professionalization.

Back in 1939, Talcott Parsons made an important observation about professionalization. According to
him, professionalization requires the establishment of some common institutional pattern and to be
counted as professional, an individual or an institution should follow the norms of scientific
investigation, i.e. it must follow a rational method for performing jobs, must have technical competence,
should concentrate on specialization and in performing duties, it must not show any sign of bias. The
presence of these institutional patterns not only professionalizes a job/occupation but also makes an
individual/institution a legitimate authority in dictating the terms of that job.

In fact, the existing literature indicates that the GAO succeeded in establishing it as a credible institution
of accountability after 1966 and this is when the institution achieved a high degree of
professionalization. However, for the purpose of this paper, I have defined the concept of
professionalization broadly. Based on March & Olsen's (1989) analysis on Institutional Autonomy, I
argue that high degree of professionalization does not only include the capacity of people working

The process through which by following rules and performing duties, a distinct sense of identity
within that institution to perform their roles effectively but also incorporates-

How the members of the institution develop their own sense of duty which creates an
is created among the people working within that institution; and

"established pattern on political mobilization, the "institutional rules of the game and even the
citizens basic way of thinking about the political world" (Pierson, 2004: 2).

Under such conditions, the institutions can become so powerful in structuring politics that they develop
the ability to "resist even in the face of systematic efforts...to uproot prior forms and build new
blueprints" (Arthur, 1994: 2, cited in Gazibo, 2006). At the same time, under these conditions, the
institution gathers the capacity of scanning the political environment within which it is functioning and
adjusts its understanding of the role performed by it accordingly. In fact, this particular aspect of
professional development is also recognized by the GAO officials. Havens (1990), for instance, while
discussing about professional development of the GAO employees, emphasized on acculturating the
"individuals to the agency's core values and missions". According to him, the success of the GAO as an
institution of accountability largely depends on its staff and they have to share a, "common body of
institutional norms relating to such matters as standards of evidence, operating procedures, and rules of
ethical behavior. Thus, the training and staff development function must inculcate in the staff the GAO
ethic of accuracy, independence, and objectivity; an understanding of what those concepts mean in the
GAO environment; and a practical recognition of how to apply them in the day-to-day work of the
office" (Havens, 1990: 16-17).

If we consider the case of the GAO, it can be argued that whereas GAO developed its capacity of
auditing and ensuring accountability throughout three different phases (1921-1985), along the way

21
through incorporating people from different disciplines (economics, political science, public
administration), the institution also succeeded (over the period) to develop the specific type of
professionalization mentioned above. As a result, when the institution was pushed during the post-1985
period and especially after 1994, it was possible for GAO (through its ability of scanning the environment
and adjusting accordingly) to devise new strategies.

Based on the review of the literature and the above discussion, it can be argued that the interaction
between these two factors generated the variation in the autonomy-relevance dilemma.

The following figure shows that-

High Constructive Engagement

(1985-Present)
(Tension between relevance
and autonomy)

Degree of
Political Contested Independence
Pressure (1966-1985)
(Growth of tension)

Legal/Formative Development of Professionalization

(1921-1945) (1945-1966)
(Absence of tension) (Absence of tension)
Low

Low High
Degree of Professionalization

In my research, based on the discussion above, I propose to develop the following assumptions which
will explain why the autonomy-relevance dilemma arises and how the GAO has made effort to deal with
this over time-

Assumption 1: In case of GAO, the interaction between two factors- degree of political pressure and
degree of professionalization determines the degree of autonomy-relevance tension.

Assumption 1A: The tension remained absent when the value of both these factors was low. In this
situation, the institution was trying to develop its autonomy and its role was not well-recognized in the

22
political arena. Henceforth, the Congress also did not feel it necessary to create pressure on the
institution and thus, it rarely interacted with the institution.

This assumption has been developed relying on the literature on GAO which indicates that up to 1966,
the institution was developing its identity, concentrated on traditional auditing and due to this, the
political actors did not make any effort to incorporate it within the policy domain. Therefore, it is
possible that the institution did not have to face the autonomy relevance-dilemma up to that point.

When the GAO started conducting program evaluation as per the request of the Congress Members,
things started to get complicated. However, by then the institution succeeded in establishing itself as an
autonomous institution and it attained the ability of deciding what program it would evaluate and how
it would carry out the evaluation program. In other words, the institution had both substantive (ability
to decide in regard to which programs to evaluate) and procedural (ability to decide the method of
conducting audit) autonomy. However, the development and preservation of this autonomy came at a
price. As Huntington (1973) pointed out, it is extremely difficult for any institution to be both
autonomous and relevant and the GAO of 1966-1985 was an example of that. Even though the
institution's interaction with the Congress tightened and there was some pressure from the
Congressional Members for being responsive, it mostly did self-initiated reports and rarely took under
consideration the requests made by the Congressional Members. As a result, the findings of the GAO
often failed to attract the attention of the actors involved in the policy arena. Furthermore, GAO was
quite conscious in averting controversy. As a professional organization, it relied on strictly scientific
approach in conducting studies and most of the time, consciously refused to perform evaluation which
might raise problem for the institution. Therefore, it can be argued that during this time-frame, there
were demands in part of the Congress for being responsive but the GAO made a conscious effort of
preserving autonomy even at the expense of relevance. Based on this, I propose that-

Assumption 1B: In case of GAO, when the degree of professionalization was high and degree of political
pressure was relatively low (but higher than the previous two time-frames), there were some signs of
tension but it was not significant.

As GAO entered into the fourth stage (1985-present), Congressional interest peeked in using GAO as an
instrument of policy oversight and formation. Consequently, congressional pressure over the GAO
increased extensively and for an institution that worked diligently over the years to establish a
professional pedigree and capacity, this presented autonomy-relevance dilemma. Based on the
framework developed above, I argue that-

Assumption 1C: The tension between autonomy and relevance became evident when both the degree
of political pressure and the degree of professionalization were high.

This last assumption leads to an important question- how did the GAO deal with this tension? As the
GAO became useful to the policymakers and was forced to be relevant in the policy process, it got
difficult for the institution to maintain the autonomy at its absolute form. As a result, it had to find a
middle-way which would allow it to be both relevant and autonomous. The discussion above indicates
that Congress's need for credible information (which encourages it to create pressure on the GAO)
created an opportunity for the institution in finding this middle-way as the ability of an expert based
institution to become useful to policymakers was undergirded by the ability for that institution to
safeguard its autonomy.

23
It can be argued that in order to deal with the tension, i.e. in response to high political pressure, a highly
professionalized GAO has come to a compromise through formal and/or informal negotiation with the
political actors- it will continue playing an important role in the policy process through proving credible
information to the political actors (i.e. the institution will become a relevant actor) and while doing that
it will sacrifice its substantive autonomy (i.e. in choosing programs or policies to evaluate the institution
will rely on the Congress Members instead of its own judgment). In exchange, the institution will
preserve its procedural autonomy, i.e. it will decide the method of evaluation and conduct the
evaluation while remaining free from any political control. The Congress may agree to this as without
having this procedural autonomy, the contribution of the institution will not add any value. I argue that-

Assumption 2: In order to deal with the autonomy-relevance dilemma, the GAO has developed a
strategy which allowed it to preserve its procedural autonomy. In exchange, the GAO has become a
relevant actor in the policy process which resulted in losing its substantive autonomy.

7. Concluding Remarks

In this paper, I have argued that as the Supreme Audit Institutions are now getting involved in program
evaluation and performance auditing, they are now faced with a unique autonomy-relevance dilemma.
Using the case study of the GAO, I have made an effort to show that two factors may contribute to this
dilemma and these two are- degree of political pressure and degree of professionalization. I have tried
to show that the interaction between these two factors eventually determine the degree of autonomy-
relevance. At the same time, analyzing the experiences of the GAO, I have argued that the SAI can
respond to this dilemma by adopting a number of strategies including sacrificing part of its autonomy in
order to remain relevant in the policy arena.

An important question is- can this framework be applied in other political contexts? In other words, can
this framework explain the experiences of other SAIs in terms of dealing with the autonomy-relevance
dilemma? It is extremely difficult to answer this question without conducting a comparative study but I
will argue that it is indeed possible to apply this framework in different political contexts. In case of the
USA, the separation of power system has played a huge role in extending pressure on the GAO. In fact,
as I have explained earlier, the Congress's need for credible information and reliance on the GAO has
been affected by the political system of the country. However, that does not necessarily mean that in a
different political context, such kind of pressure will remain absent. In a parliamentary democracy,
where the SAIs mostly interact with the Public Accounts Committee, it is very much possible for the
political actors to create pressure on the SAIs to deliver information and they may also look for policy
prescriptions which are relevant. Therefore, it can be argued that in a parliamentary democracy, the
political pressure can also be high and when that happens, we will witness the presence of an
autonomy-relevance dilemma in part of the SAI.

However, it is also possible that the political actors may ignore the role played by the SAIs and they can
actually consider these institutions irrelevant. In fact, in a number of developing countries, the political
actors rarely take the help of the SAIs in ensuring accountability. In Bangladesh, the Members of the
Parliament are never interested in discussing the reports submitted to them and in that country the
Public Accounts Committee (PAC) has so far failed to perform its role effectively. For instance, "the
fourth PAC (1991-1996) during its tenure settled only 440 audit objections and could not deal with
70.49% audit objections. The Fifth PAC (1996-2001), out of 1301 audit objections dealt with only 497
objections. The next PAC (2001-2006) resolved only 149 audit objection during its entire tenure" (IGS,
2009). In a situation like this, the autonomy-relevance dilemma will not take place as the political actors

24
will not pay any attention to the role played by the SAI. However, the SAI may or may not try to preserve
its autonomy and it will largely depend on its level of professionalization.

On the other hand, when the autonomy-relevance dilemma exists, the SAIs can respond in a number of
ways-

First, like GAO, they can bargain and reach to a compromised solution, i.e. they can sacrifice substantive
autonomy in order to preserve the procedural autonomy.

Second, if the degree of political pressure is high and the degree of professionalization is low, the SAI
can be forced (or choose) to sacrifice its overall autonomy and may serve as per the direction of the
political actors. The SAI of Mali can be cited as an example of that (Wyne, 2010).

Third, if the political pressure remains low and the institution succeeds in achieving a high degree of
professionalization, the SAI can actually preserve both dimensions of autonomy, while sacrificing its
relevance in the policy process. In a number of developed democracies, the SAIs have adopted such a
role and like the GAO of 1966-1985, they have made conscious efforts in preserving their autonomy. For
instance, in their web-site, the Court of Accounts of the Netherlands has stated that- "We are an
independent institution. That means that we decide what we audit. We often receive requests to carry
out audits from members of parliament, ministers and state secretaries who need an independent
expert opinion on a particular matter. But they cannot order us to do so because the Court of Audit is
i depe de t 3 (The Court of Audit of the Netherlands). In these cases, the SAIs have made a choice-
they have preserved both the substantive and procedural autonomy, while ignoring the possible effect
of their reports in the overall policy process.

However, it is too early to draw any conclusion about the applicability of the model developed here. For
that, it is necessary to conduct a comparative study and that is actually the major goal of my research
project.

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