The National Strategy for the Efficient Use of Real Property: Part 4 - the Who

US Government Efficiency Solution for Real Property Management Miniseries

Jun 10, 2025

Introduction

This article concludes a four-part mini series on the National Strategy for Efficient Use of Real Property, as detailed in OMB Memorandum M-20-10, which issued an addendum to the strategy first established in 2015. Previous articles in this series addressed the "how," "why," and "what" of the strategy, available at:

These articles collectively highlight that no coherent strategy has emerged in the more than two decades since efficient real property management became a national priority. For progress to occur, action is required. This article identifies who is responsible and what actions they must take to advance the strategy.

Background

The origins of this issue trace back to 1988, when the National Council on Public Works Improvement issued Fragile Foundations: A Report on America’s Public Works to the President and Congress. The reasons for this report were discussed in Part 2 of this series. It included the first national report card on public infrastructure, shown below:

A close-up of a list of information

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This report was highly influential. The National Academies followed with Committing to the Cost of Ownership (1990), which established a target investment rate of 2–4% of a real property’s current replacement value to sustain built infrastructure assets over their life cycle. The National Academies further advanced this agenda in Stewardship of Federal Facilities: A Proactive Strategy for Managing the Nation’s Public Assets (1998), recommending the establishment of an executive-level advisory group to develop policies and strategies for fostering accountability and strategically allocating resources for facility maintenance and repair.

This recommendation directly influenced Executive Order 13327—Federal Real Property Asset Management (2004), which created the Senior Real Property Officer (SRPO) position for agencies required to report financial data under the Chief Financial Officers Act of 1990. This EO also established the Federal Real Property Council (FRPC) within the Office of Management and Budget (OMB). The FRPC’s purpose is to assist SRPOs in developing and implementing agency Asset Management Plans (AMPs). The FRPC was later codified by the Federal Property Management Reform Act of 2016 (Public Law 114-318). This places OMB through the FRPC as the source responsible for generating the National Strategy for the Efficient Use of Real Property.

Accountability for the Efficient Use of Real Property

Many organizations use a Responsible, Accountable, Consulted, Informed (RACI) matrix to define roles and responsibilities. Key definitions include:

Responsible: The entity who performs the task or activity, responsible for completing the work.
Accountable: The entity ultimately answerable for the task’s completion, ensuring it is done correctly. Only one entity should ever be accountable to complete a task.

For the development and implementation of the National Strategy for the Efficient Use of Real Property, OMB is responsible for delivering the strategy, while Congress is accountable for ensuring its delivery. Despite OMB’s efforts to improve real property management, a comprehensive strategy has not materialized due to complex challenges. Without clear congressional direction or prioritization, OMB’s ability to effect change is limited.

What Congress Needs to Do

The National Academies’ report Strategies to Renew Federal Facilities addresses this issue directly. While critical of OMB and the FRPC’s limited success in generating a national strategy, the report supports their efforts and policies. It details a pathway through five recommendations that should be enacted to overcome past failures and limitations, such as through an amendment to the Federal Property Management Reform Act of 2016. The proposed amendment is as follows:

H.R. ___ / S. ___

To amend the Federal Property and Administrative Services Act of 1949 to incorporate recommendations from the National Academies of Sciences, Engineering, and Medicine for improved federal facility asset management, capital planning, and renewal strategies.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

This Act may be cited as the "Federal Facilities Renewal and Management Enhancement Act of 2025."

SECTION 2. AMENDMENTS TO THE FEDERAL PROPERTY AND ADMINISTRATIVE SERVICES ACT OF 1949.

The Federal Property and Administrative Services Act of 1949 (40 U.S.C. 101 et seq.), as amended by the Federal Property Management Reform Act of 2016 (Public Law 114-318), is further amended by adding at the end of subtitle I the following new sections:

SEC. 547. FEDERAL FACILITY ASSET MANAGEMENT SYSTEM.

(a) Updates to OMB Circulars. Not later than 180 days after the date of enactment of this Act, the Director of the Office of Management and Budget (OMB), in coordination with the Federal Real Property Council, shall update OMB Circulars A-11 and A-123 to require:

(1) Adoption of a comprehensive, principle-based facility asset management framework that conforms with International Organization for Standardization (ISO) 55000—Asset Management System standards to guide federal facility renewal strategies.

(2) Clarification of the integration of enterprise risk management and internal controls to support facility renewal strategies, including policies to enhance risk assessment and mitigation in federal facility management.

(3) Definition of the fiduciary responsibilities of agency senior real property officers to ensure efficient and effective portfolio management, with performance metrics reported under OMB Circular A-136—Financial Reporting Requirements, fully accounting for risks caused by underfunding facility portfolios and assets.

(4) Use of whole asset life-cycle cost analysis, whole asset portfolio management, and whole benefit analysis in resource allocation and investment decision-making.

(5) Revision of OMB Circular A-11, Section 83 (Object Classification), to eliminate fragmentation and many-to-many relationships in real property performance-budget data, enabling integrated and auditable management balance sheets.

(b) Implementation. Each federal agency shall fully implement the updated guidance not later than 1 year after the date of issuance of revised OMB Circulars A-11 and A-123.

SEC. 548. REAL PROPERTY CAPITAL PLAN.

(a) Capital Planning Requirements. Not later than 180 days after the date of enactment of this Act, the Director of OMB shall revise the OMB Circular A-11 Supplement—Capital Programming Guide and OMB Memorandum M-20-03 to require:

(1) Development and publication by each agency of a single, integrated real property capital plan through use of the asset management framework defined in the previous section as a component of the agency’s capital plan, consistent with the Capital Programming Guide.

(2) A process to verify that real property capital plans inform annual budget and investment decisions, prioritizing urgent and compelling facility renewal needs.

(3) Documentation and communication of the role of the real property capital plan in reconciling agency objectives, budgets, and real property program execution as part of agency budget submission.

(b) Agency Responsibilities. Not later than 2 years after the date of enactment of this Act, each agency senior real property officer shall implement OMB M-20-03 guidance to establish a strategy for integrating requirements, objectives, budgets, and real property program execution.

SEC. 549. NATIONAL STRATEGY FOR EFFICIENT USE OF REAL PROPERTY.

(a) Strategy Updates. Not later than 180 days after the date of enactment of this Act, the Director of OMB shall update the National Strategy for the Efficient Use of Real Property and OMB Memorandum M-20-10 to include:

(1) Guidance for agencies to use the National Strategy to establish priorities and objectives for efficient real property management, including addressing Government Accountability Office (GAO) high-risk real property issues and findings in the National Academies’ Strategies to Renew Federal Facilities report.

(2) Requirements to link performance reporting of budget execution for real property capital plans to National Strategy objectives, with annual review through agency strategic plan reporting through incorporation of the Operational Readiness Principle as defined in the National Academies’ Strategies to Renew Federal Facilities report.

(b) Coordination. Not later than 1 year after the issuance of updated guidance, agency chief management officers and chief budget officers shall coordinate responses to OMB M-20-10 and OMB M-20-03, as amended, to ensure alignment of real property capital planning and National Strategy objectives.

SEC. 550. FEDERAL FACILITY MODELS, DATA, AND MEASURES.

(a) Cost Estimation Models. Not later than 180 days after the date of enactment of this Act, the Director of OMB shall issue guidance requiring agency senior real property officers to:

(1) Adopt an economic depreciation approach for estimating facility renewal costs, tailored to each agency’s portfolio, using simplified cost factors by facility type, modeled after the Department of Defense Facility Sustainment Model.

(2) Guide improvement of depreciation rates and service lives maintained by the Department of Commerce’s Bureau of Economic Analysis and use this data to forecast future budgetary requirements and liabilities.

(b) Component Inventory Database. Not later than 2 years after the date of enactment of this Act, the Administrator of the General Services Administration (GSA), in coordination with the Federal Real Property Council under OMB direction, shall direct the establishment of an independent, centralized database of federal facility component inventories. The database shall:

(1) Incorporate data from the GSA Federal Real Property Profile and the U.S. Army Corps of Engineers’ Electronic Sustainment Management System.

(2) Be accessible to qualified users for research and development and be compatible with popular capital planning and facility management systems.

(3) Require all agencies to submit component inventory data as directed by executive requirement under the Federal Real Property Council to inform analysis and improvement of the models, data, and measures used to inform federal real property resource and investment decision making.

SEC. 551. FEDERAL FACILITY RENEWAL BUDGETING STRATEGIES.

(a) Budgeting Mechanisms. Not later than 180 days after the date of enactment of this Act, the Director of OMB shall issue guidance requiring federal agencies to incorporate the following in annual Real Property Capital Plans and use this information to justify budget submissions:

(1) Develop legislative proposals for expanded use of working capital funds or revolving funds to aggregate funding for capital investments into consolidated, agency-wide budget accounts to support multiyear life-cycle spending. These recommendations will be submitted by the FRPC through OMB and updated annually.

(2) Implement user-pays models for all federal facilities to fund sustainable operation, maintenance, repair, and renewal.

(3) Establish execution plans to maximize use of revenue collected in the Federal Buildings Fund for the repair, renewal, or replacement of facilities managed by the Public Buildings Service.

(4) Identify non-inherently governmental facilities and services with active private markets for potential privatization, outsourcing, or public-private partnerships.

(5) Utilize expedited disposal authorities under the Federal Assets Sale and Transfer Act (FASTA) (Public Law 114-287) or seek additional disposal authorities for properties not covered by FASTA.

(6) Permit the use of operating leases as an alternative to ownership when budget scoring indicates ownership costs are not feasible in the near-term budget outlook.

(b) Implementation. Not later than 1 year after the issuance of guidance, agencies shall incorporate these requirements into their Real Property Capital Plans and budget justifications submitted to OMB, with full implementation not later than 3 years after the date of enactment of this Act.

SEC. 552. REPORTING AND OVERSIGHT.

(a) Annual Reporting. Each agency shall, as a component of its Real Property Capital Plan, include in its annual financial report under OMB Circular A-136 a section detailing compliance with this Act, including progress on facility asset management systems, real property capital plans, and budgeting strategies.

(b) GAO Review. The Comptroller General of the United States shall conduct a review of agency compliance with this Act every 3 years, with the first report due to Congress not later than December 31, 2028.

SECTION 3. EFFECTIVE DATE.

This Act and the amendments made by this Act shall take effect on the date of enactment.

Conclusion

This series examines the development and implementation of the National Strategy for the Efficient Use of Real Property pursuant to OMB M-20-10. Despite over two decades of efforts, the federal government has failed to produce a comprehensive strategy. OMB is responsible for generating the strategy, but Congress is accountable for its absence. Congress must now act to establish a responsible and responsive approach to managing federal real property efficiently and effectively.

The National Academies’ Strategies to Renew Federal Facilities provides five recommendations that form the framework for this strategy. By enacting these recommendations, Congress can ensure better risk management, transparency, and accountability. These outcomes will optimize the use of appropriated budgets to achieve agency missions and objectives. The National Strategy for the Efficient Use of Real Property is not merely a plan for meeting performance targets but a risk-informed framework to maximize benefits related through execution of agency missions.

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Written by Jack Dempsey | June 10, 2025

AMP Newsletter #126