Circular No.
A-94 Revised (Transmittal Memo No. 64)
October 29,
1992
MEMORANDUM FOR
HEADS OF EXECUTIVE DEPARTMENTS AND ESTABLISHMENTS
SUBJECT: Guidelines and Discount Rates for
Benefit-Cost Analysis of
Federal Programs
Table of
Contents
- Purpose
- Rescission
- Authority
- Scope
- General
Principles
- Net Present
Value and Related Outcome Measures
- Cost-Effectiveness Analysis
- Elements of
Benefit-Cost or Cost-Effectiveness Analysis
- Identifying
and Measuring Benefits and Costs
- Identifying
Benefits and Costs
- b. Measuring
Benefits and Costs
- Treatment
of Inflation
- Real or Nominal
Values
- Recommended
Inflation Assumption
- Discount
Rate Policy
- Real versus
Nominal Discount Rates
- Public
Investment and Regulatory Analyses
- Cost-Effectiveness, Lease-Purchase,Internal Government
Investment, and Asset Sale Analyses
- Treatment
of Uncertainty
- Characterizing
Uncertainty
- Expected Values
- Sensitivity
Analysis
- Other
Adjustments for Uncertainty
- Incidence
and Distributional Effects
- Alternative
Classifications
- Economic
Incidence
- Special
Guidance for Public Investment Analysis
- Analysis of
Excess Burdens
- Exceptions
- Special
Guidance for Regulatory Impact Analysis
- Special
Guidance for Lease-Purchase Analysis
- Coverage
- Required
Justification for Leases
- Analytical
Requirements and Definitions
- Related
Guidance
- Implementation
- Effective
Date
- Interpretation
Appendix
A: Definitions of Terms Appendix
B: Additional Guidance for Discounting Appendix
C: Discount Rates for Cost-Effectiveness, Lease-Purchase, and Related
Analyses
Other
Documents
1.
Purpose. The goal of this Circular is to promote efficient resource
allocation through well-informed decision-making by the Federal
Government. It provides general guidance for conducting benefit-cost and
cost-effectiveness analyses. It also provides specific guidance on the
discount rates to be used in evaluating Federal programs whose benefits
and costs are distributed over time. The general guidance will serve as a
checklist of whether an agency has considered and properly dealt with all
the elements for sound benefit-cost and cost-effectiveness
analyses.
2.
Rescission. This Circular replaces and rescinds Office of
Management and Budget (OMB) Circular No. A-94, "Discount Rates to Be Used
in Evaluating Time-Distributed Costs and Benefits," dated March 27, 1972,
and Circular No. A-104, "Evaluating Leases of Capital Assets," dated June
1, 1986, which has been rescinded. Lease-purchase analysis is only
appropriate after a decision has been made to acquire the services of an
asset. Guidance for lease-purchase analysis is provided in Section 8.c.(2)
and Section 13.
3.
Authority. This Circular is issued under the authority of 31 U.S.C.
Section 1111 and the Budget and Accounting Act of 1921, as amended.
4. Scope.
This Circular does not supersede agency practices which are prescribed by
or pursuant to law, Executive Order, or other relevant circulars. The
Circular's guidelines are suggested for use in the internal planning of
Executive Branch agencies. The guidelines must be followed in all analyses
submitted to OMB in support of legislative and budget-programs in
compliance with OMB Circulars No. A-11, "Preparation and Submission of
Annual Budget Estimates," and No. A-19, "Legislative Coordination and
Clearance." These guidelines must also be followed in providing estimates
submitted to OMB in compliance with Executive Order No. 12291, "Federal
Regulation," and the President's April 29, 1992 memorandum requiring
benefit-cost analysis for certain legislative proposals.
a. Aside from the
exceptions listed below, the guidelines in this Circular apply to any
analysis used to support Government decisions to initiate, renew, or
expand programs or projects which would result in a series of measurable
benefits or costs extending for three or more years into the future. The
Circular applies specifically to:
- Benefit-cost or
cost-effectiveness analysis of Federal programs or policies.
- Regulatory impact
analysis.
- Analysis of
decisions whether to lease or purchase.
- Asset valuation
and sale analysis.
b. Specifically
exempted from the scope of this Circular are decisions concerning:
- Water resource
projects (guidance for which is the approved Economic and
Environmental Principles and Guidelines for Water and Related Land
Resources Implementation Studies).
- The acquisition of
commercial-type services by Government or contractor operation (guidance
for which is OMB Circular No. A-76).
- Federal energy
management programs (guidance for which can be found in the Federal
Register of January 25, 1990, and November 20, 1990).
c. This Circular
applies to all agencies of the Executive Branch of the Federal Government.
It does not apply to the Government of the District of Columbia or to
non-Federal recipients of loans, contracts or grants. Recipients are
encouraged, however, to follow the guidelines provided here when preparing
analyses in support of Federal activities.
d. For small projects
which share similar characteristics, agencies are encouraged to conduct
generic studies and to avoid duplication of effort in carrying out
economic analysis.
5. General
Principles. Benefit-cost analysis is recommended as the
technique to use in a formal economic analysis of government programs or
projects. Cost-effectiveness analysis is a less comprehensive
technique, but it can be appropriate when the benefits from competing
alternatives are the same or where a policydecision has been made that the
benefits must be provided. (Appendix A provides a glossary of technical
terms used in this Circular; technical terms are italicized when they
first appear.)
a. Net Present
Value and Related Outcome Measures. The standard criterion for
deciding whether a government program can be justified on economic
principles is net present value -- the discounted monetized value
of expected net benefits (i.e., benefits minus costs). Net present value
is computed by assigning monetary values to benefits and costs,
discounting future benefits and costs using an appropriate discount rate,
and subtracting the sum total of discounted costs from the sum total of
discounted benefits. Discounting benefits and costs transforms gains and
losses occurring in different time periods to a common unit of
measurement. Programs with positive net present value increase social
resources and are generally preferred. Programs with negative net present
value should generally be avoided. (Section 8 considers discounting issues
in more detail.)
Although net present
value is not always computable (and it does not usually reflect effects on
income distribution), efforts to measure it can produce useful insights
even when the monetary values of some benefits or costs cannot be
determined. In these cases:
- A comprehensive
enumeration of the different types of benefits and costs, monetized
or not, can be helpful in identifying the full range of program effects.
- Quantifying
benefits and costs is worthwhile, even when it is not feasible to assign
monetary values; physical measurements may be possible and
useful.
Other summary
effectiveness measures can provide useful supplementary information to
net present value, and analysts are encouraged to report them also.
Examples include the number of injuries prevented per dollar of cost (both
measured in present value terms) or a project's internal rate of return.
b.
Cost-Effectiveness Analysis. A program is cost-effective if, on the
basis of life cycle cost analysis of competing alternatives, it is
determined to have the lowest costs expressed in present value terms for a
given amount of benefits. Costeffectiveness analysis is appropriate
whenever it is unnecessary or impractical to consider the dollar value of
the benefits provided by the alternatives under consideration. This is the
case whenever (i) each alternative has the same annual benefits expressed
in monetary terms; or (ii) each alternative has the same annual affects,
but dollar values cannot be assigned to their benefits. Analysis of
alternative defense systems often falls in this category.
Cost-effectiveness
analysis can also be used to compare programs with identical costs but
differing benefits. In this case, the decision criterion is the discounted
present value of benefits. The alternative program with the largest
benefits would normally be favored.
c. Elements of
Benefit-Cost or Cost-Effectiveness Analysis.
- Policy
Rationale. The rationale for the Government program being examined
should be clearly stated in the analysis. Programs may be justified on
efficiency grounds where they address market failure, such as public
goods and externalities. They may also be justified where they improve
the efficiency of the Government's internal operations, such as
cost-saving investments.
- Explicit
Assumptions. Analyses should be explicit about the underlying
assumptions used to arrive at estimates of future benefits and costs. In
the case of public health programs, for example, it may be necessary to
make assumptions about the number of future beneficiaries, the intensity
of service, and the rate of increase in medical prices. The analysis
should include a statement of the assumptions, the rationale behind
them, and a review of their strengths and weaknesses. Key data and
results, such as year-by-year estimates of benefits and costs, should be
reported to promote independent analysis and review.
- Evaluation of
Alternatives. Analyses should also consider alternative means of
achieving program objectives by examining different program
scales, different methods of provision, and different
degrees of government involvement. For example, in evaluating a
decision to acquire a capital asset, the analysis should generally
consider: (i) doing nothing; (ii) direct purchase; (iii) upgrading,
renovating, sharing, or converting existing government property; or (iv)
leasing or contracting for services.
- Verification. Retrospective studies to determine whether
anticipated benefits and costs have been realized are potentially
valuable. Such studies can be used to determine necessary corrections in
existing programs, and to improve future estimates of benefits and costs
in these programs or related ones.
Agencies should
have a plan for periodic, results-oriented evaluation of program
effectiveness. They should also discuss the results of relevant
evaluation studies when proposing reauthorizations or increased program
funding.
6.
Identifying and Measuring Benefits and Costs. Analyses should
include comprehensive estimates of the expected benefits and costs to
society based on established definitions and practices for program
and policy evaluation. Social net benefits, and not the benefits and costs
to the Federal Government, should be the basis for evaluating government
programs or policies that have effects on private citizens or other levels
of government. Social benefits and costs can differ from private benefits
and costs as measured in the marketplace because of imperfections arising
from: (i) external economies or diseconomies where actions by one
party impose benefits or costs on other groups that are not compensated in
the market place; (ii) monopoly power that distorts the relationship
between marginal costs and market prices; and (iii) taxes or subsidies.
a. Identifying
Benefits and Costs. Both intangible and tangible benefits and costs
should be recognized. The relevant cost concept is broader than
private-sector production and compliance costs or government cash
expenditures. Costs should reflect the opportunity cost of any resources
used, measured by the return to those resources in their most productive
application elsewhere. Below are some guidelines to consider when
identifying benefits and costs.
- Incremental
Benefits and Costs. Calculation of net present value should be based
on incremental benefits and costs. Sunk costs and realized benefits
should be ignored. Past experience is relevant only in helping to
estimate what the value of future benefits and costs might be. Analyses
should take particular care to identify the extent to which a policy
such as a subsidy program promotes substitutes for activities of a
similar nature that would occur without the policy. Either displaced
activities should be explicitly recorded as costs or only incremental
gains should be recorded as benefits of the policy.
- Interactive
Effects. Possible interactions between the benefits and costs being
analyzed and other government activities should be considered. For
example, policies affecting agricultural output should reflect real
economic values, as opposed to subsidized prices.
- International
Effects. Analyses should focus on benefits and costs accruing to the
citizens of the United States in determining net present value. Where
programs or projects have effects outside the United States, these
effects should be reported separately.
- Transfers.
There are no economic gains from a pure transfer payment because
the benefits to those who receive such a transfer are matched by the
costs borne by those who pay for it. Therefore, transfers should be
excluded from the calculation of net present value. Transfers that arise
as a result of the program or project being analyzed should be
identified as such, however, and their distributional effects discussed.
It should also be recognized that a transfer program may have benefits
that are less than the program's real economic costs due to
inefficiencies that can arise in the program's delivery of benefits and
financing.
b. Measuring
Benefits and Costs. The principle of willingness-to-pay
provides an aggregate measure of what individuals are willing to forego to
obtain a given benefit. Market prices provide an invaluable starting point
for measuring willingness-to-pay, but prices sometimes do not adequately
reflect the true value of a good to society. Externalities, monopoly
power, and taxes or subsidies can distort market prices.
Taxes, for example,
usually create an excess burden that represents a net loss to
society. (The appropriate method for recognizing this excess burden in
public investment analyses is discussed in Section 11.) In other cases,
market prices do not exist for a relevant benefit or cost. When market
prices are distorted or unavailable, other methods of valuing benefits may
have to be employed. Measures derived from actual market behavior are
preferred when they are available.
- Inframarginal
Benefits and Costs. Consumers would generally be willing to pay more
than the market price rather than go entirely without a good they
consume. The economist's concept of consumer surplus measures the
extra value consumers derive from their consumption compared with the
value measured at market prices. When it can be determined, consumer
surplus provides the best measure of the total benefit to society from a
government program or project. Consumer surplus can sometimes be
calculated by using econometric methods to estimate consumer demand.
- Indirect
Measures of Benefits and Costs. Willingness-to-pay can sometimes be
estimated indirectly through changes in land values, variations in wage
rates, or other methods. Such methods are most reliable when they are
based on actual market transactions. Measures should be consistent with
basic economic principles and should be replicable.
- Multiplier
Effects. Generally, analyses should treat resources as if they were
likely to be fully employed. Employment or output multipliers that
purport to measure the secondary effects of government expenditures on
employment and output should not be included in measured social benefits
or costs.
7. Treatment
of Inflation. Future inflation is highly uncertain. Analysts should
avoid having to make an assumption about the general rate of inflation
whenever possible.
a. Real or Nominal
Values. Economic analyses are often most readily accomplished using
real or constant-dollar values, i.e., by measuring benefits
and costs in units of stable purchasing power. (Such estimates may reflect
expected future changes in relative prices, however, where there is a
reasonable basis for estimating such changes.) Where future benefits and
costs are given in nominal terms, i.e., in terms of the future
purchasing power of the dollar, the analysis should use these values
rather than convert them to constant dollars as, for example, in the case
of lease-purchase analysis.
Nominal and real
values must not be combined in the same analysis. Logical consistency
requires that analysis be conducted either in constant dollars or in terms
of nominal values. This may require converting some nominal values to real
values, or vice versa.
b. Recommended
Inflation Assumption. When a general inflation assumption is needed,
the rate of increase in the Gross Domestic Product deflator from the
Administration's economic assumptions for the period of the analysis is
recommended. For projects or programs that extend beyond the six-year
budget horizon, the inflation assumption can be extended by using the
inflation rate for the sixth year of the budget forecast. The
Administration's economic forecast is updated twice annually, at the time
the budget is published in January or February and at the time of the
Mid-Session Review of the Budget in July. Alternative inflation estimates,
based on credible private sector forecasts, may be used for sensitivity
analysis.
8. Discount
Rate Policy. In order to compute net present value, it is necessary to
discount future benefits and costs. This discounting reflects the time
value of money. Benefits and costs are worth more if they are experienced
sooner. All future benefits and costs, including nonmonetized benefits and
costs, should be discounted. The higher the discount rate, the lower is
the present value of future cash flows. For typical investments, with
costs concentrated in early periods and benefits following in later
periods, raising the discount rate tends to reduce the net present value.
(Technical guidance on discounting and a table of discount factors
are provided in Appendix B.)
a. Real versus
Nominal Discount Rates. The proper discount rate to use depends on
whether the benefits and costs are measured in real or nominal terms.
- A real discount
rate that has been adjusted to eliminate the effect of expected
inflation should be used to discount constant-dollar or real benefits
and costs. A real discount rate can be approximated by subtracting
expected inflation from a nominal interest rate.
- A nominal discount
rate that reflects expected inflation should be used to discount nominal
benefits and costs. Market interest rates are nominal interest rates in
this sense.
b. Public
Investment and Regulatory Analyses. The guidance in this section
applies to benefit-cost analyses of public investments and regulatory
programs that provide benefits and costs to the general public. Guidance
related to cost-effectiveness analysis of internal planning decisions of
the Federal Government is provided in Section 8.c.
In general, public
investments and regulations displace both private investment and
consumption. To account for this displacement and to promote efficient
investment and regulatory policies, the following guidance should be
observed.
- Base-Case
Analysis. Constant-dollar benefit-cost analyses of proposed
investments and regulations should report net present value and other
outcomes determined using a real discount rate of 7 percent. This rate
approximates the marginal pretax rate of return on an average investment
in the private sector in recent years. Significant changes in this rate
will be reflected in future updates of this Circular.
- Other Discount
Rates. Analyses should show the sensitivity of the discounted net
present value and other outcomes to variations in the discount rate. The
importance of these alternative calculations will depend on the specific
economic characteristics of the program under analysis. For example, in
analyzing a regulatory proposal whose main cost is to reduce business
investment, net present value should also be calculated using a higher
discount rate than 7 percent.
Analyses may
include among the reported outcomes the internal rate of return
implied by the stream of benefits and costs. The internal rate of return
is the discount rate that sets the net present value of the program or
project to zero. While the internal rate of return does not generally
provide an acceptable decision criterion, it does provide useful
information, particularly when budgets are constrained or there is
uncertainty about the appropriate discount rate.
- Using the
shadow price of capital to value benefits and costs is the
analytically preferred means of capturing the effects of government
projects on resource allocation in the private sector. To use this
method accurately, the analyst must be able to compute how the benefits
and costs of a program or project affect the allocation of private
consumption and investment. OMB concurrence is required if this method
is used in place of the base case discount rate.
c.
Cost-Effectiveness, Lease-Purchase, Internal Government Investment, and
Asset Sales Analyses. The Treasury's borrowing rates should be used as
discount rates in the following cases:
- Cost-Effectiveness Analysis. Analyses that involve
constant-dollar costs should use the real Treasury borrowing rate on
marketable securities of comparable maturity to the period of analysis.
This rate is computed using the Administration's economic assumptions
for the budget, which are published in January of each year. A table of
discount rates based on the expected interest rates for the first year
of the budget forecast is presented in Appendix C of this Circular.
Appendix C is updated annually and is available upon request from OMB.
Real Treasury rates are obtained by removing expected inflation over the
period of analysis from nominal Treasury interest rates. (Analyses that
involve nominal costs should use nominal Treasury rates for discounting,
as described in the following paragraph.)
- Lease-Purchase
Analysis. Analyses of nominal lease payments should use the nominal
Treasury borrowing rate on marketable securities of comparable maturity
to the period of analysis. Nominal Treasury borrowing rates should be
taken from the economic assumptions for the budget. A table of discount
rates based on these assumptions is presented in Appendix C of this
Circular, which is updated annually. (Constant dollar lease-purchase
analyses should use the real Treasury borrowing rate, described in the
preceding paragraph.)
- Internal
Government Investments. Some Federal investments provide "internal"
benefits which take the form of increased Federal revenues or decreased
Federal costs. An example would be an investment in an energy-efficient
building system that reduces Federal operating costs. Unlike the case of
a Federally funded highway (which provides "external" benefits to
society as a whole), it is appropriate to calculate such a project's net
present value using a comparable-maturity Treasury rate as a discount
rate. The rate used may be either nominal or real, depending on how
benefits and costs are measured.
Some Federal
activities provide a mix of both Federal cost savings and external
social benefits. For example, Federal investments in information
technology can produce Federal savings in the form of lower
administrative costs and external social benefits in the form of faster
claims processing. The net present value of such investments should be
evaluated with the 7 percent real discount rate discussed in Section
8.b. unless the analysis is able to allocate the investment's costs
between provision of Federal cost savings and external social benefits.
Where such an allocation is possible, Federal cost savings and their
associated investment costs may be discounted at the Treasury rate,
while the external social benefits and their associated investment costs
should be discounted at the 7 percent real rate.
- Asset Sale
Analysis. Analysis of possible asset sales should reflect the
following:
(a) The net
present value to the Federal Government of holding an asset is best
measured by discounting its future earnings stream using a Treasury
rate. The rate used may be either nominal or real, depending on how
earnings are measured.
(b) Analyses of
government asset values should explicitly deduct the cost of expected
defaults or delays in payment from projected cash flows, along with
government administrative costs. Such analyses should also consider
explicitly the probabilities of events that would cause the asset to
become nonfunctional, impaired or obsolete, as well as probabilities of
events that would increase asset value.
(c) Analyses of
possible asset sales should assess the gain in social efficiency that
can result when a government asset is subject to market discipline and
private incentives. Even though a government asset may be used more
efficiently in the private sector, potential private-sector purchasers
will generally discount such an asset's earnings at a rate in excess of
the Treasury rate, in part, due to the cost of bearing risk. When there
is evidence that government assets can be used more efficiently in the
private sector, valuation analyses for these assets should include
sensitivity comparisons that discount the returns from such assets with
the rate of interest earned by assets of similar riskiness in the
private sector.
9. Treatment
of Uncertainty. Estimates of benefits and costs are typically
uncertain because of imprecision in both underlying data and modeling
assumptions. Because such uncertainty is basic to many analyses, its
effects should be analyzed and reported. Useful information in such a
report would include the key sources of uncertainty; expected value
estimates of outcomes; the sensitivity of results to important sources of
uncertainty; and where possible, the probability distributions of
benefits, costs, and net benefits.
a. Characterizing
Uncertainty. Analyses should attempt to characterize the sources and
nature of uncertainty. Ideally, probability distributions of potential
benefits, costs, and net benefits should be presented. It should be
recognized that many phenomena that are treated as deterministic or
certain are, in fact, uncertain. In analyzing uncertain data, objective
estimates of probabilities should be used whenever possible. Market data,
such as private insurance payments or interest rate differentials, may be
useful in identifying and estimating relevant risks. Stochastic simulation
methods can be useful for analyzing such phenomena and developing insights
into the relevant probability distributions. In any case, the basis for
the probability distribution assumptions should be reported. Any
limitations of the analysis because of uncertainty or biases surrounding
data or assumptions should be discussed.
b. Expected
Values. The expected values of the distributions of benefits, costs
and net benefits can be obtained by weighting each outcome by its
probability of occurrence, and then summing across all potential outcomes.
If estimated benefits, costs and net benefits are characterized by point
estimates rather than as probability distributions, the expected value (an
unbiased estimate) is the appropriate estimate for use.
Estimates that differ
from expected values (such as worst-case estimates) may be provided in
addition to expected values, but the rationale for such estimates must be
clearly presented. For any such estimate, the analysis should identify the
nature and magnitude of any bias. For example, studies of past activities
have documented tendencies for cost growth beyond initial expectations;
analyses should consider whether past experience suggests that initial
estimates of benefits or costs are optimistic.
c. Sensitivity
Analysis. Major assumptions should be varied and net present value and
other outcomes recomputed to determine how sensitive outcomes are to
changes in the assumptions. The assumptions that deserve the most
attention will depend on the dominant benefit and cost elements and the
areas of greatest uncertainty of the program being analyzed. For example,
in analyzing a retirement program, one would consider changes in the
number of beneficiaries, future wage growth, inflation, and the discount
rate. In general, sensitivity analysis should be considered for estimates
of: (i) benefits and costs; (ii) the discount rate; (iii) the general
inflation rate; and (iv) distributional assumptions. Models used in the
analysis should be well documented and, where possible, available to
facilitate independent review.
d. Other
Adjustments for Uncertainty. The absolute variability of a risky
outcome can be much less significant than its correlation with other
significant determinants of social welfare, such as real national income.
In general, variations in the discount rate are not the appropriate method
of adjusting net present value for the special risks of particular
projects. In some cases, it may be possible to estimate
certainty-equivalents which involve adjusting uncertain expected
values to account for risk.
10.
Incidence and Distributional Effects. The principle of maximizing
net present value of benefits is based on the premise that gainers could
fully compensate the losers and still be better off. The presence or
absence of such compensation should be indicated in the analysis. When
benefits and costs have significant distributional effects, these effects
should be analyzed and discussed, along with the analysis of net present
value. (This will not usually be the case for cost-effectiveness analysis
where the scope of government activity is not changing.)
a. Alternative
Classification. Distributional effects may be analyzed by grouping
individuals or households according to income class (e.g., income
quintiles), geographical region, or demographic group (e.g., age). Other
classifications, such as by industry or occupation, may be appropriate in
some circumstances.
Analysis should aim
at identifying the relevant gainers and losers from policy decisions.
Effects on the preexisting assignment of property rights by the program
under analysis should be reported. Where a policy is intended to benefit a
specified subgroup of the population, such as the poor, the analysis
should consider how effective the policy is in reaching its targeted
group.
b. Economic
Incidence. Individuals or households are the ultimate recipients of
income; business enterprises are merely intermediaries. Analyses of
distribution should identify economic incidence, or how costs and benefits
are ultimately borne by households or individuals.
Determining economic
incidence can be difficult because benefits and costs are often
redistributed in unintended and unexpected ways. For example, a subsidy
for the production of a commodity will usually raise the incomes of the
commodity's suppliers, but it can also benefit consumers of the commodity
through lower prices and reduce the incomes for suppliers of competing
products. A subsidy also raises the value of specialized resources used in
the production of the subsidized commodity. As the subsidy is incorporated
in asset values, its distributional effects can change.
11. Special
Guidance for Public Investment. This guidance applies only to public
investments with social benefits apart from decreased Federal costs. It is
not required for cost-effectiveness or lease-purchase analyses. Because
taxes generally distort relative prices, they impose a burden in excess of
the revenues they raise. Recent studies of the U.S. tax system suggest a
range of values for the marginal excess burden, of which a reasonable
estimate is 25 cents per dollar of revenue.
a. Analysis of
Excess Burdens. The presentation of results for public investments
that are not justified on cost-saving grounds should include a
supplementary analysis with a 25 percent excess burden. Thus, in such
analyses, costs in the form of public expenditures should be multiplied by
a factor of 1.25 and net present value recomputed.
b. Exceptions.
Where specific information clearly suggests that the excess burden is
lower (or higher) than 25 percent, analyses may use a different figure.
When a different figure is used, an explanation should be provided for it.
An example of such an exception is an investment funded by user charges
that function like market prices; in this case, the excess burden would be
zero. Another example would be a project that provides both cost savings
to the Federal Government and external social benefits. If it is possible
to make a quantitative determination of the portion of this project's
costs that give rise to Federal savings, that portion of the costs may be
exempted from multiplication by the factor of 1.25.
12. Special
Guidance for Regulatory Impact Analysis. Additional guidance for
analysis of regulatory policies is provided in Regulatory Program of
the United States Government which is published annually by OMB. (See
"Regulatory Impact Analysis Guidance," Appendix V of Regulatory Program
of the United States Government for April 1, 1991 to March 31, 1992.)
13. Special
Guidance for Lease-Purchase Analysis. The special guidance in this
section does not apply to the decision to acquire the use of an asset. In
deciding that, the agency should conduct a benefit-cost analysis, if
possible. Only after the decision to acquire the services of an asset has
been made is there a need to analyze the decision whether to lease or
purchase.
a. Coverage.
The Circular applies only when both of the following tests of
applicability are satisfied:
- The lease-purchase
analysis concerns a capital asset, (including durable goods, equipment,
buildings, facilities, installations, or land) which:
(a) Is leased
to the Federal Government for a term of three or more years; or,
(b) Is new, with an
economic life of less than three years, and leased to the Federal
Government for a term of 75 percent or more of the economic life of the
asset; or,
(c) Is built for
the express purpose of being leased to the Federal Government; or,
(d) Is leased to
the Federal Government and clearly has no alternative commercial use
(e.g., a special-purpose government installation).
- The lease-purchase
analysis concerns a capital asset or a group of related assets whose
total fair market value exceeds $1 million.
b. Required
Justification for Leases. All leases of capital assets must be
justified as preferable to direct government purchase and ownership. This
can be done in one of three ways:
- By conducting a
separate lease-purchase analysis. This is the only acceptable method for
major acquisitions. A lease represents a major acquisition if:
(a) The
acquisition represents a separate line-item in the agency's budget;
(b) The agency or
OMB determines the acquisition is a major one; or
(c) The total
purchase price of the asset or group of assets to be leased would exceed
$500 million.
- By conducting
periodic lease-purchase analyses of recurrent decisions to lease similar
assets used for the same general purpose. Such analyses would apply to
the entire class of assets. OMB approval should be sought in determining
the scope of any such generic analysis.
- By adopting a
formal policy for smaller leases and submitting that policy to the OMB
for approval. Following such a policy should generally result in the
same lease-purchase decisions as would conducting separate
lease-purchase analyses. Before adopting the policy, it should be
demonstrated that:
(a) The leases
in question would generally result in substantial savings to the
Government that could not be realized on a purchase;
(b) The leases are
so small or so short-term as to make separate lease-purchase analysis
impractical; and
(c) Leases of
different types are scored consistently with the instructions in
Appendices B and C of OMB Circular No. A-11.
c. Analytical
Requirements and Definitions. Whenever a Federal agency needs to
acquire the use of a capital asset, it should do so in the way that is
least expensive for the Government as a whole.
- Life-Cycle
Cost. Lease-purchase analyses should compare the net discounted
present value of the life-cycle cost of leasing with the full costs of
buying or constructing an identical asset. The full costs of buying
include the asset's purchase price plus the net discounted present value
of any relevant ancillary services connected with the purchase.
(Guidance on the discount rate to use for lease-purchase analysis is in
Section 8.c.)
- Economic
Life. For purposes of lease-purchase analysis, the economic life of
an asset is its remaining or productive lifetime. It begins when the
asset is acquired and ends when the asset is retired from service. The
economic life is frequently not the same as the useful life for tax
purposes.
- Purchase
Price. The purchase price of the asset for purposes of
lease-purchase analysis is its fair market value, defined as the price a
willing buyer could reasonably expect to pay a willing seller in a
competitive market to acquire the asset.
(a) In the case
of property that is already owned by the Federal Government or that has
been donated or acquired by condemnation, an imputed purchase price
should be estimated. (Guidance on making imputations is provided in
Section 13.c.(6).)
(b) If public land
is used for the site of the asset, the imputed market value of the land
should be added to the purchase price.
(c) The asset's
estimated residual value, as of the end of the period of analysis,
should be subtracted from its purchase price. (Guidance on estimating
residual value is provided in Section 13.c.(7).)
- Taxes. In
analyzing the cost of a lease, the normal payment of taxes on the
lessor's income from the lease should not be subtracted from the lease
costs since the normal payment of taxes will also be reflected in the
purchase cost. The cost to the Treasury of special tax benefits, if any,
associated with the lease should be added to the cost of the lease.
Examples of such tax benefits might include highly accelerated
depreciation allowances or tax-free financing.
- Ancillary
Services. If the terms of the lease include ancillary services
provided by the lessor, the present value of the cost of obtaining these
services separately should be added to the purchase price. Such costs
may be excluded if they are estimated to be the same for both lease and
purchase alternatives or too small to affect the comparison. Examples of
ancillary services include:
(a) All costs
associated with acquiring the property and preparing it for use,
including construction, installation, site, design, and management
costs.
(b) Repair and
improvement costs (if included in lease payments).
(c) Operation and
maintenance costs (if included in lease payments).
(d) Imputed
property taxes (excluding foreign property taxes on overseas
acquisitions except where actually paid). The imputed taxes approximate
the costs of providing municipal services such as water, sewage, and
police and fire protection. (See Section (6) below.)
(e) Imputed
insurance premiums. (See Section (6) below.)
- Estimating
Imputed Costs. Certain costs associated with the Federal purchase of
an asset may not involve a direct monetary payment. Some of these
imputed costs may be estimated as follows.
(a) Purchase
Price. An imputed purchase price for an asset that is already owned
by the Federal Government or which has been acquired by donation or
condemnation should be based on the fair market value of similar
properties that have been traded on commercial markets in the same or
similar localities. The same method should be followed in estimating the
imputed value of any Federal land used as a site for the asset.
(b) Property
Taxes. Imputed property taxes may be estimated in two ways.
(i) Determine the
property tax rate and assessed (taxable) value for comparable property
in the intended locality. If there is no basis on which to estimate
future changes in tax rates or assessed values, the first- year tax rate
and assessed value (inflation adjusted for each subsequent year) can be
applied to all years. Multiply the assessed value by the tax rate to
determine the annual imputation for property taxes.
(ii) As an
alternative to step (i) above, obtain an estimate of the current local
effective property tax rate from the Building Owners and Managers
Association's Regional Exchange Reports. Multiply the fair market value
of the government-owned property (inflation adjusted for each year) by
the effective tax rate.
(c) Insurance
Premiums. Determine local estimates of standard commercial coverage
for similar property from the Building Owners and Managers Association's
Regional Exchange Reports.
- Residual
Value. A property's residual value is an estimate of the price that
the property could be sold for at the end of the period of the
lease-purchase analysis, measured in discounted present value terms.
(a) The
recommended way to estimate residual value is to determine what similar,
comparably aged property is currently selling for in commercial markets.
(b) Alternatively,
book estimates of the resale value of used property may be available
from industry or government sources.
(c) Assessed values
of similar, comparably aged properties determined for property tax
purposes may also be used.
- Renewal
Options. In determining the term of a lease, all renewal options
shall be added to the initial lease period.
14. Related
Guidance.
- OMB Circular No.
A-11,"Preparation and Submission of Annual Budget Estimates."
- OMB Circular No.
A-19,"Legislative Coordination and Clearance."
- OMB Circular No.
A-70,"Federal Credit Policy."
- OMB Circular No.
A-76,"Performance of Commercial Activities."
- OMB Circular No.
A-109,"Policies to Be Followed in the Acquisition of Major
Systems."
- OMB Circular No.
A-130,"Management of Federal Information Resources."
- "Joint OMB and
Treasury Guidelines to the Department of Defense Covering Lease or
Charter Arrangements for Aircraft and Naval Vessels."
- Executive Order
12291, "Federal Regulation."
- "Regulatory Impact
Analysis Guidance," in Regulatory Program of the United States
Government.
- "Federal Energy
Management and Planning Programs; Life Cycle Cost Methodology and
Procedures,"
- Federal Register,
Vol. 55, No. 17, January 25, 1990, and Vol. 55, No. 224, November 20,
1990.
- Presidential
Memorandum of April 29, 1992, "Benefits and Costs of Legislative
Proposals."
15.
Implementation. Economic analyses submitted to OMB will be reviewed
for conformity with Items 5 to 13 in this Circular, through the Circular
No. A-11 budget justification and submission process, and Circular No.
A-19,legislative review process.
16.
Effective Date. This Circular is effective immediately.
17.
Interpretation. Questions concerning interpretation of this
Circular should be addressed to the Office of Economic Policy, Office of
Management and Budget (202-395-5873) or, in the case of regulatory issues
and analysis, to the Office of Information and Regulatory Affairs
(202-395-4852).
APPENDIX
A
DEFINITION OF
TERMSBenefit-Cost Analysis -- A systematic quantitative method of
assessing the desirability of government projects or policies when it is
important to take a long view of future effects and a broad view of
possible side-effects.
Capital Asset
-- Tangible property, including durable goods, equipment, buildings,
installations, and land.
Certainty-Equivalent -- A certain (i.e., nonrandom) outcome
that an individual values equally to an uncertain outcome. For a
risk-averse individual, the certainty-equivalent for an uncertain set of
benefits may be less than the mathematical expectation of the outcome; for
example, an individual may value a 50-50 chance of winning $100 or $0 as
only $45. Analogously, a risk-averse individual may have a
certainty-equivalent for an uncertain set of costs that is larger in
magnitude than the mathematical expectation of costs.
Cost-Effectiveness -- A systematic quantitative method for
comparing the costs of alternative means of achieving the same stream of
benefits or a given objective.
Consumer
Surplus -- The maximum sum of money a consumer would be willing to pay
to consume a given amount of a good, less the amount actually paid. It is
represented graphically by the area between the demand curve and the price
line in a diagram representing the consumer's demand for the good as a
function of its price.
Discount Rate
-- The interest rate used in calculating the present value of expected
yearly benefits and costs.
Discount
Factor -- The factor that translates expected benefits or costs in any
given future year into present value terms. The discount factor is equal
to 1/(1 + i)t where i is the interest rate and
t is the number of years from the date of initiation for the
program or policy until the given future year.
Excess Burden
-- Unless a tax is imposed in the form of a lump sum unrelated to economic
activity, such as a head tax, it will affect economic decisions on the
margin. Departures from economic efficiency resulting from the distorting
effect of taxes are called excess burdens because they disadvantage
society without adding to Treasury receipts. This concept is also
sometimes referred to as deadweight loss.
External Economy
or Diseconomy -- A direct effect, either positive or negative, on
someone's profit or welfare arising as a byproduct of some other person's
or firm's activity. Also referred to as neighborhood or spillover effects,
or externalities for short.
Incidence --
The ultimate distributional effect of a tax, expenditure, or regulatory
program.
Inflation --
The proportionate rate of change in the general price level, as opposed to
the proportionate increase in a specific price. Inflation is usually
measured by a broad-based price index, such as the implicit deflator for
Gross Domestic Product or the Consumer Price Index.
Internal Rate of
Return -- The discount rate that sets the net present value of the
stream of net benefits equal to zero. The internal rate of return may have
multiple values when the stream of net benefits alternates from negative
to positive more than once.
Life Cycle
Cost -- The overall estimated cost for a particular program
alternative over the time period corresponding to the life of the program,
including direct and indirect initial costs plus any periodic or
continuing costs of operation and maintenance.
Multiplier --
The ratio between the direct effect on output or employment and the full
effect, including the effects of second order rounds or spending.
Multiplier effects greater than 1.0 require the existence of involuntary
unemployment.
Net Present
Value -- The difference between the discounted present value of
benefits and the discounted present value of costs.
Nominal Values
-- Economic units measured in terms of purchasing power of the date in
question. A nominal value reflects the effects of general price inflation.
Nominal Interest
Rate -- An interest rate that is not adjusted to remove the effects of
actual or expected inflation. Market interest rates are generally nominal
interest rates.
Opportunity
Cost -- The maximum worth of a good or input among possible
alternative uses.
Real or Constant
Dollar Values -- Economic units measured in terms of constant
purchasing power. A real value is not affected by general price inflation.
Real values can be estimated by deflating nominal values with a general
price index, such as the implicit deflator for Gross Domestic Product or
the Consumer Price Index.
Real Interest
Rate -- An interest rate that has been adjusted to remove the effect
of expected or actual inflation. Real interest rates can be approximated
by subtracting the expected or actual inflation rate from a nominal
interest rate. (A precise estimate can be obtained by dividing one plus
the nominal interest rate by one plus the expected or actual inflation
rate, and subtracting one from the resulting quotient.)
Relative Price
-- A price ratio between two goods as, for example, the ratio of the price
of energy to the price of equipment.
Shadow Price
-- An estimate of what the price of a good or input would be in the
absence of market distortions, such as externalities or taxes. For
example, the shadow price of capital is the present value of the social
returns to capital (before corporate income taxes) measured in units of
consumption.
Sunk Cost -- A
cost incurred in the past that will not be affected by any present or
future decision. Sunk costs should be ignored in determining whether a new
investment is worthwhile.
Transfer
Payment -- A payment of money or goods. A pure transfer is unrelated
to the provision of any goods or services in exchange. Such payments alter
the distribution of income, but do not directly affect the allocation of
resources on the margin.
Treasury Rates
-- Rates of interest on marketable Treasury debt. Such debt is issued in
maturities ranging from 91 days to 30 years.
Willingness to
Pay -- The maximum amount an individual would be willing to give up in
order to secure a change in the provision of a good or service.
APPENDIX
B
ADDITIONAL GUIDANCE
FOR DISCOUNTING1. Sample Format for
Discounting Deferred Costs and Benefits
Assume a 10-year
program which will commit the Government to the stream of real (or
constant-dollar) expenditures appearing in column (2) of the table below
and which will result in a series of real benefits appearing in column
(3). The discount factor for a 7 percent discount rate is shown in column
(4). The present value cost for each of the 10 years is calculated by
multiplying column (2) by column (4); the present value benefit for each
of the 10 years is calculated by multiplying column (3) by column (4). The
present values of costs and benefits are presented in columns (5) and (6)
respectively.
Year since initiation renewal or expansion (1) |
Expected yearly cost (2) |
Expected yearly benefit (3) |
Discount factors for 7% (4) |
Present value of costs Col. 2 x Col. 4 (5) |
Present value of benefits Col. 3 x Col. 4
(6) |
1 |
$10.00 |
$
0.00 |
0.9346 |
$
9.35 |
$0.00 |
2 |
20.00 |
0.00 |
0.8734 |
17.47 |
0.00 |
3 |
30.00 |
5.00 |
0.8163 |
24.49 |
4.08 |
4 |
30.00 |
10.00 |
0.7629 |
22.89 |
7.63 |
5 |
20.00 |
30.00 |
0.7130 |
14.26 |
21.39 |
6 |
10.00 |
40.00 |
0.6663 |
6.66 |
26.65 |
7 |
5.00 |
40.00 |
0.6227 |
3.11 |
24.91 |
8 |
5.00 |
40.00 |
0.5820 |
2.91 |
23.28 |
9 |
5.00 |
40.00 |
0.5439 |
2.72 |
21.76 |
10 |
5.00 |
25.00 |
0.5083 |
2.54 |
12.71 |
Total |
|
|
|
$106.40 |
$142.41 |
NOTE: The
discount factor is calculated as 1/(1 + i)t
where i is the interest rate (.07) and t is the year.
The sum of column (5)
is the total present value of costs and the sum of column (6) is the total
present value of benefits. Net present value is $36.01, the difference
between the sum of discounted benefits and the sum of discounted costs.
2. End-of-Year and
Mid-Year Discount Factors
The discount factors
presented in the table above are calculated on the implicit assumption
that costs and benefits occur as lump sums at year-end. When costs and
benefits occur in a steady stream, applying mid-year discount factors is
more appropriate. For instance, the first cost in the table may be
estimated to occur after six months, rather than at the end of one year to
approximate better a steady stream of costs and benefits occurring over
the first year. Similarly, it may be assumed that all other costs and
benefits are advanced six months to approximate better a continuing steady
flow.
The present values of
costs and benefits computed from the table above can be converted to a
mid-year discounting basis by multiplying them by 1.0344 (the square root
of 1.07). Thus, if the above example were converted to a mid-year basis,
the present value of costs would be $110.06, the present value of benefits
would be $147.31, and the net present value would be $37.25.
3. Illustrative
Discount Factors for Discount Rate of 7 percent
Year since Initiation, Renewal or
Expansion |
Year-end Discount Factors |
Mid-year Discount Factors |
Beginning-of-year Discount Factors |
1 |
0.9346 |
0.9667 |
1.0000 |
2 |
0.8734 |
0.9035 |
0.9346 |
3 |
0.8163 |
0.8444 |
0.8734 |
4 |
0.7629 |
0.7891 |
0.8163 |
5 |
0.7130 |
0.7375 |
0.7629 |
6 |
0.6663 |
0.6893 |
0.7130 |
7 |
0.6227 |
0.6442 |
0.6663 |
8 |
0.5820 |
0.6020 |
0.6227 |
9 |
0.5439 |
0.5626 |
0.5820 |
10 |
0.5083 |
0.5258 |
0.5439 |
11 |
0.4751 |
0.4914 |
0.5083 |
12 |
0.4440 |
0.4593 |
0.4751 |
13 |
0.4150 |
0.4292 |
0.4440 |
14 |
0.3878 |
0.4012 |
0.4150 |
15 |
0.3624 |
0.3749 |
0.3878 |
16 |
0.3387 |
0.3504 |
0.3624 |
17 |
0.3166 |
0.3275 |
0.3387 |
18 |
0.2959 |
0.3060 |
0.3166 |
19 |
0.2765 |
0.2860 |
0.2959 |
20 |
0.2584 |
0.2673 |
0.2765 |
21 |
0.2415 |
0.2498 |
0.2584 |
22 |
0.2257 |
0.2335 |
0.2415 |
23 |
0.2109 |
0.2182 |
0.2257 |
24 |
0.1971 |
0.2039 |
0.2109 |
25 |
0.1842 |
0.1906 |
0.1971 |
26 |
0.1722 |
0.1781 |
0.1842 |
27 |
0.1609 |
0.1665 |
0.1722 |
28 |
0.1504 |
0.1556 |
0.1609 |
29 |
0.1406 |
0.1454 |
0.1504 |
30 |
0.1314 |
0.1359 |
0.1406 |
Appendix
C: Discount Rates for Cost-Effectiveness, Lease-Purchase, and Related
Analyses for OMB Circular No. A-94
|