Resistance Survival Guide #328
Interagency programs sound impressively coordinated when officials announce them. Several departments will combine expertise, share resources, eliminate duplication, and deliver one seamless government response. There may even be a diagram featuring circles, arrows, and the word synergy behaving suspiciously.
Then something fails.
Suddenly, the lead agency was only coordinating. The funding agency did not manage implementation. The implementing agency followed somebody else’s guidance. The working group never maintained the complete project data. Everyone attended meetings, but nobody remembers owning the result.
This Resistance Survival Guide explains how to investigate an interagency program by identifying its legal authority, decision makers, participating agencies, transferred funds, agreements, contractors, performance measures, and missing records. The objective is to replace a foggy collection of agency logos with a documented chain of responsibility.
What Is an Interagency Program
An interagency program involves two or more federal agencies, departments, bureaus, offices, or overseas posts working toward a shared objective. The arrangement may be established by a statute, executive order, presidential memorandum, agency agreement, annual appropriations language, national strategy, working group charter, or informal administrative process.
One agency may receive the appropriation. Another may write the guidance. A working group may select projects. A third agency may administer awards. Overseas posts or regional offices may manage implementation. Contractors and nonprofit recipients may perform the visible work. Additionally, in this administration, Marco Rubio often is put in charge of them (snicker).
That arrangement is not automatically improper. Complex problems often require several agencies. Disaster response, cybersecurity, public health, foreign assistance, financial enforcement, infrastructure, intelligence, and environmental protection do not fit politely inside one organizational box.
The accountability problem begins when authority, money, records, and performance are divided without a clear owner for the complete program.
Why Shared Responsibility Can Become No Responsibility
An interagency program creates several opportunities for accountability to fall between the furniture.
The office making funding recommendations may not maintain award records. The agency issuing a contract may not understand the program’s policy objective. The working group may approve proposals without tracking the final projects. Participating agencies may use different project names, account numbers, reporting periods, and performance measures.
Officials can truthfully describe only their small portion while avoiding responsibility for the whole. That does not require a conspiracy. A sufficiently complicated bureaucracy can produce the same result through habit, fragmentation, and an almost artistic devotion to spreadsheets that refuse to communicate.
Your investigation must therefore separate four functions: legal authority, financial control, operational control, and performance accountability.
A Current Example of the Accountability Problem
A June 2026 Government Accountability Office investigation examined State Department and United States Agency for International Development projects intended to counter Chinese influence.
Congress had directed State and USAID to spend at least $1.6 billion on these efforts beginning in fiscal year 2020. The agencies reported funding approximately 470 projects worth about $1.2 billion from fiscal years 2020 through 2023.
An interagency working group oversaw the proposal process and determined which projects received funding. However, GAO found that officials did not have readily available and reliable data on the complete portfolio.
Officials could not identify the specific projects funded through nearly one third of the approved proposals. Time frames were missing for 129 projects, while the applicable line of effort was missing for 38 projects. The working group had also not assessed results across the complete portfolio.
The agencies could describe the process. They could estimate the number of projects. They could provide a large dollar figure. What they could not readily produce was a reliable account of precisely what had been funded and whether the combined effort had worked.
That is the interagency accountability problem in one beautifully upholstered nutshell.
The Four Ownership Questions
Every investigation should begin with four ownership questions.
- Who possessed the legal authority to create or operate the program?
- Who controlled the money?
- Who controlled project selection and implementation?
- Who was responsible for measuring results?
Do not accept “the working group” as a complete answer. A working group cannot sign an agreement, obligate an appropriation, supervise an employee, or respond to Congress unless actual officials and agencies possess the underlying authority.
Find those people and offices.
Step by Step Guide
Step One: Define the Program in Plain Language
Write a one paragraph description of what the program claims to do. Identify the policy objective, geographic area, intended beneficiaries, participating agencies, announced funding, and expected result.
Record every official name, abbreviation, initiative title, fund name, task force name, and line of effort connected to the program. Interagency initiatives frequently acquire several names as they move through appropriations documents, agency guidance, contracts, press releases, and congressional testimony.
Search each variation separately. The press office may call it an initiative while the budget office calls it an account and the implementing bureau calls it a portfolio.
If you search only the polished public name, you may find the ribbon cutting and miss the machinery.
Step Two: Find the Original Legal Authority
Locate the statute, appropriations provision, executive order, agency directive, memorandum, or other document that established the program.
Record the precise language describing its purpose. Note whether Congress required the agencies to spend money, authorized them to spend money, or merely encouraged coordination. Those words create different obligations.
Identify every agency named in the authority. Record any reporting requirements, spending conditions, deadlines, consultation duties, geographic restrictions, and required performance measures.
Do not assume the document announcing the program created it. The press release is public relations. The legal authority is the instruction manual.
Step Three: Identify the Lead, Funding, Performing, and Oversight Agencies
Create a separate entry for every agency involved. For each one, record its role as lead agency, coordinating agency, funding agency, ordering agency, performing agency, award administrator, data custodian, or oversight body.
Then identify the specific bureau, office, mission, program unit, and official performing that role. A cabinet department is too broad to be a useful answer.
A program may have several forms of leadership. One agency may chair the working group while another controls the appropriation. A third may administer the contracts. A fourth may possess the technical expertise required to evaluate results.
The word “lead” means very little until you define what the agency actually controls.
Step Four: Locate the Working Group Charter and Membership
Search for a charter, terms of reference, governance plan, operating procedure, membership roster, delegation memorandum, decision protocol, or annual guidance.
Record who chairs the group, who votes, who attends, who provides technical advice, and who approves final recommendations. Determine whether members participate in their individual authority or merely represent their agencies.
Look for changes in membership. A working group may continue using the same name while losing the officials, offices, or expertise that originally shaped it.
Request meeting agendas, minutes, attendance records, briefing materials, proposal rankings, decision memoranda, action items, and membership lists. If officials claim the group kept no minutes, ask how decisions worth millions of dollars were recorded and communicated.
Apparently, some of the most consequential government meetings operate with the documentary discipline of brunch.
Step Five: Reconstruct the Decision Process
Determine how ideas became funded projects. Locate the annual guidance, application instructions, proposal templates, evaluation criteria, scoring sheets, review panels, recommendations, final approvals, and rejection notices.
Record who could submit proposals and whether participation was open to every relevant bureau or limited to invited offices. Identify the submission period and the amount of time applicants had to prepare proposals.
Compare the published criteria with the criteria officials actually used. Look for late additions, leadership priorities, expedited reviews, direct allocations, and projects funded outside the normal process.
A process can be technically competitive while the important money enters through a side door wearing an urgent label.
Step Six: Trace the Appropriation
Find the congressional appropriation that supplied the money. Record the fiscal year, appropriation account, amount, period of availability, purpose restrictions, and agency receiving the funds.
Use the Treasury Department’s Federal Account Symbols and Titles reference to identify the relevant Treasury account symbols. These symbols can help connect appropriations, obligations, awards, and agency financial reports.
Determine whether the money remained with the receiving agency or moved through transfers, reimbursements, allocations, working capital funds, or other accounts.
Do not treat the announced program total as money actually spent. Separate budget authority, allocations, obligations, outlays, transfers, cancellations, and unobligated balances.
Government officials adore announcing the largest available number and reporting results using whichever smaller number looks least alarming.
Step Seven: Obtain the Interagency Agreements
Request every interagency agreement, memorandum of understanding, memorandum of agreement, service agreement, reimbursable agreement, funding authorization, and amendment connected to the program.
Some interagency transactions operate under the Economy Act. A Government Accountability Office decision on Economy Act transfers explains that 31 U.S.C. section 1535 authorizes reimbursable agreements for one agency to provide goods or services to another.
Other programs use separate statutory authority. Record the specific authority cited in every agreement because it affects how funds may be obligated, reimbursed, retained, or returned.
The General Services Administration explains that many interagency agreements are processed through G Invoicing and related systems. Ask for the general terms and conditions, order documents, funding information, performance period, billing records, modifications, and closeout materials.
An agreement’s title may sound administrative. Its payment terms will tell you who expected whom to do what.
Step Eight: Follow the Money Into Awards
Search the USAspending advanced award database using the program name, agency, recipient, award identification number, appropriation account, Treasury account symbol, contract description, and relevant dates.
Download award and transaction data instead of relying only on the website summary. An award can contain multiple transactions, modifications, funding agencies, awarding agencies, and recipient names.
Search contracts, grants, cooperative agreements, direct payments, and subawards. The agency managing the program may differ from the agency appearing as the awarding agency.
Record the prime recipient, parent organization, subrecipients, award amount, obligated amount, period of performance, place of performance, award description, and funding office.
If the official project list cannot be matched to federal award records, document the mismatch. Either you have not found the complete identifier or the government has not maintained a usable connection between the proposal and the award.
Neither possibility deserves a celebratory brochure.
Step Nine: Match Every Proposal to a Real Project
Create a project register with one row for every proposal, allocation, award, and reported project.
Include the proposal title, approved amount, appropriation account, decision date, approving body, implementing agency, managing office, award identification number, recipient, location, start date, end date, project status, and stated objective.
Assign your own unique identifier when the agencies do not provide one. Preserve every original identifier used by participating agencies.
Then test whether each approved proposal produced one award, several awards, an internal agency activity, or no identifiable project at all.
Also work in reverse. Begin with every award you can identify and determine which approved proposal authorized it. Unmatched awards and unmatched proposals are equally important findings.
Step Ten: Identify the Actual Decision Makers
Record the names and positions of officials who wrote the guidance, evaluated proposals, recommended selections, approved funding, signed agreements, issued awards, supervised implementation, and certified results.
Search organization charts, delegation orders, leadership biographies, archived webpages, congressional testimony, calendars, meeting records, and award documents.
Determine whether decision makers had the expertise required to evaluate the proposals. GAO’s 2026 investigation found that the State and USAID proposal process did not consistently require documented input from key regional and subject matter experts.
A room full of senior titles is not the same thing as informed review. Sometimes it is merely a very expensive arrangement of lanyards.
Step Eleven: Compare Approved, Rejected, and Directly Allocated Projects
Request the complete applicant pool, not merely the winners. Compare approved proposals, rejected proposals, withdrawn proposals, direct allocations, emergency approvals, and projects considered outside the ordinary process.
Record the scores, reviewer comments, requested amounts, final amounts, policy justifications, and changes required before approval.
Look for projects that bypassed competition because officials described them as urgent, sensitive, strategic, or directed by leadership. Those descriptions may be justified, but they should be supported by records.
Compare whether similar proposals received similar treatment across bureaus, agencies, regions, and fiscal years. A formally uniform process can still produce unequal access if some offices receive advance notice, technical assistance, or extra time.
Step Twelve: Test the Reliability of the Program Data
Do not assume a spreadsheet is reliable because an agency created it.
Check for missing dates, duplicate projects, inconsistent country names, conflicting award amounts, invalid identification numbers, unexplained status codes, and totals that change between reports.
Compare the working group’s project list with award data, agency financial reports, inspector general findings, congressional submissions, and recipient disclosures.
Ask who enters the data, who verifies it, how often it is updated, and whether the participating agencies use common definitions.
GAO found that officials examining the countering Chinese influence portfolio had to ask bureaus and overseas posts to assemble data from several sources. The resulting information contained errors and significant gaps.
When officials cannot readily produce a complete project list, that is not a clerical footnote. It is an internal control finding wearing reading glasses.
Step Thirteen: Examine the Performance Measures
Locate the program’s logic model, performance plan, monitoring framework, milestones, targets, indicators, evaluation reports, and final project assessments.
Separate outputs from outcomes. Meetings held, reports produced, people trained, and grants awarded are outputs. They show activity. They do not prove the program changed the underlying condition.
Determine whether participating agencies use compatible measures. One office may report dollars obligated while another reports projects completed and a third reports people reached. Those numbers cannot be combined into a meaningful judgment without a shared framework.
Ask who was responsible for evaluating the entire portfolio. If every project produced a report but nobody assessed the collective result, the program has documented its motion rather than its effectiveness.
Step Fourteen: Search Every Participating Agency for Records
There is no central federal office that processes every Freedom of Information Act request. The Department of Justice FOIA reference guide explains that each federal department and agency responds to requests for its own records.
Send separate requests to the lead agency, funding agency, performing agencies, working group members, award administrators, and relevant oversight offices.
Tailor each request to the records that office likely created or received. Ask the funding agency for agreements and payment records. Ask the coordinating office for guidance and meeting materials. Ask implementing offices for project files and performance reports.
Do not file the same enormous request everywhere. Precision makes it harder for an agency to claim that searching would require the administrative equivalent of excavating Pompeii with a teaspoon.
Step Fifteen: Track Referrals and Consultations
Interagency records frequently trigger FOIA referrals or consultations because one agency possesses a document created by another.
Department of Justice guidance on referrals and consultations explains that agencies may refer records to their originator or consult another agency before making a disclosure decision.
Record the original request number, referral date, receiving agency, new tracking number, status, and final response for every referral. Ask the original agency to identify where it sent the records.
If an agency refers documents, it should maintain a copy and notify the requester. A referral should not transform a public record into a migratory species that disappears somewhere between departments.
Appeal improper denials, missing searches, unexplained referrals, and responses that ignore named offices or record systems.
Step Sixteen: Build an Accountability Matrix
Create a final matrix showing each important function and the office responsible for it.
Include legal authority, funding control, proposal guidance, project selection, agreement management, award administration, implementation, data maintenance, performance evaluation, public reporting, and oversight.
For every function, cite the record establishing responsibility. Mark areas where responsibility is disputed, undocumented, divided, or absent.
Then compare the matrix with the government’s public statements. If officials claim no single office owned the program, show which offices nevertheless exercised particular powers.
Shared responsibility does not mean invisible responsibility. It means the investigation must identify several responsible actors instead of accepting one convenient spokesperson.
Records Worth Requesting
The most useful records include working group charters, membership lists, annual guidance, meeting agendas, attendance records, minutes, proposal submissions, scoring sheets, reviewer comments, final recommendations, decision memoranda, direct allocation records, interagency agreements, funding authorizations, invoices, award records, project lists, monitoring plans, performance reports, evaluations, risk assessments, audit findings, and correspondence concerning missing data.
Request data in its original electronic format whenever possible. Ask for spreadsheets as spreadsheets, not converted pages trapped inside a PDF where every sortable field has been sentenced to life without parole.
Include the program name, alternate names, relevant offices, fiscal years, appropriation accounts, and known officials in the request. Define the date range and record types clearly.
Red Flags That Deserve Closer Examination
A program deserves deeper scrutiny when no office maintains a complete project list, several agencies report different totals, approved proposals cannot be matched to awards, or officials cannot identify the statutory authority used to transfer funds.
Other warning signs include working groups without charters, missing membership records, undocumented scoring, large direct allocations, projects approved outside the normal process, incomplete award identifiers, performance measures created years after funding began, and portfolio evaluations that were promised but never completed.
Watch for officials who describe accountability differently depending on the question. An office may claim ownership when announcing money and deny ownership when discussing results.
That is not coordination. That is bureaucratic custody sharing without a parenting plan.
How To Use Independent Reporting
Once the evidence is organized, take the findings to an independent newsroom with the capacity to examine federal records.
The nonprofit newsroom ProPublica accepts investigative tips and has experience analyzing federal programs, public data, and government accountability.
The nonprofit transparency organization MuckRock provides public records tools, request examples, and reporting built from government documents.
You can also approach nonprofit state newsrooms, local investigative outlets, public radio stations, subject specific publications, and independent reporters already covering the agencies involved.
Provide the reporter with the legal authority, accountability matrix, project register, key agreements, award matches, unexplained gaps, agency responses, and your methodology. Do not send a digital haystack accompanied by the hopeful instruction “thoughts?”
What a Strong Investigation Should Prove
A responsible investigation should establish who created the program, who controlled its money, who selected the projects, who performed the work, who maintained the records, and who was expected to evaluate the results.
It should distinguish confirmed facts from reasonable inferences. Missing records do not automatically prove corruption. They may demonstrate weak internal controls, fragmented management, poor data standards, hasty implementation, or inadequate oversight.
Those failures still matter. Congress and the public cannot assess a program if the government cannot identify what it funded.
The strongest conclusion may be that no official designed a complete accountability system. That is less cinematic than a secret mastermind, but it can waste just as much money.
Turning the Findings Into Accountability
Send the documented findings to the relevant agency inspectors general, congressional oversight committees, appropriations committees, Government Accountability Office, and independent reporters.
The Council of the Inspectors General on Integrity and Efficiency provides access to the federal inspector general community. When several agencies are involved, send the evidence to each inspector general whose agency controlled a meaningful part of the program.
Ask agencies to designate a publicly identifiable program owner, publish the working group charter, maintain a complete project register, connect proposals to award identification numbers, disclose direct allocations, standardize performance measures, and report results across the entire portfolio.
Recommend that every interagency program establish responsibility for records, spending, implementation, and evaluation before the first project is approved.
Accountability works better when it is built into the program instead of added later as an emotional support spreadsheet.
In Closing
Interagency cooperation can solve problems that no single department can handle alone. It can also divide responsibility so thoroughly that every office possesses part of the answer and nobody can produce the truth.
The solution is not to search for one perfect database. It is to reconstruct the program from its legal authority, agreements, accounts, proposals, awards, decisions, records, and results.
Follow each function to the office that controlled it. Follow each dollar to the agency that obligated it. Follow each approved proposal to the project it produced. Then ask who measured whether any of it worked.
Resistance Kitty supports teamwork. She simply believes the team should include at least one adult carrying the complete project list.
Sources
- Government Accountability Office Report on Projects Countering Chinese Influence, published June 17, 2026.
- Government Accountability Office Decision on Economy Act Transfers, explaining reimbursable interagency agreements and appropriation restrictions.
- Government Accountability Office Decision on Independent Interagency Agreement Authority, explaining the general restriction on transfers and statutory exceptions.
- General Services Administration G Invoicing Guidance, addressing the processing of interagency agreements.
- Treasury Federal Account Symbols and Titles Reference, identifying federal appropriation and fund account symbols.
- USAspending Advanced Award Search, providing federal award and transaction data.
- Department of Justice Freedom of Information Act Reference Guide, explaining how federal agencies process requests for their own records.
- Department of Justice Guidance on FOIA Referrals and Consultations, explaining procedures for records involving multiple agencies.
- Council of the Inspectors General on Integrity and Efficiency, providing access to federal inspector general offices and oversight resources.
