# Cloud Savings Trackers Closed GAO Recs, but Cost Control Is Still Open

> In 2019, GAO told 16 agencies to build a repeatable way to track cloud savings, and 14 have closed the recommendation with dashboards, spreadsheets, and tools. In June 2026, 17 of 24 agencies still said controlling cloud costs required changes in how they manage IT. The trackers are where a cloud contractor's billing data ends up.

- Source: https://avalontechservices.com/news/cloud-savings-trackers-closed-gao-recs-but-cost-control-is-still-open
- Published: 2026-11-12
- Author: [Brandon Ireland](https://avalontechservices.com/author/brandon-ireland)
- Category: Cloud & IT Infrastructure Services
- Topic: Cloud & IT Infrastructure Services
- Publisher: Avalon Technology Services

## Key Takeaways

- GAO-19-58 told 16 agencies to track cloud savings and cost avoidance; 14 have closed it, while DoW disagreed and DOT had not finished.
- OMB said in March 2024 it did not intend to require quarterly cloud savings reporting, so the government-wide figure was never collected.
- GAO-26-107530 (June 2026) found 17 of 24 CFO Act agencies said cost control required management changes, and 22 rely mainly on historical procurement data.
- Migration-savings trackers show whether a move saved money, not why this month's bill grew; GAO's open recommendation asks GSA to require FinOps practices.
- In contractor-operated environments the billing accounts and tags often sit with the prime, so primes should expect spend attribution and realized-savings reporting requirements.

In April 2019, GAO told 16 agencies to establish a consistent and repeatable mechanism to track savings and cost avoidance from moving to cloud. According to the status notes in [GAO-19-58](https://www.gao.gov/products/gao-19-58), 14 have closed it. Seven years later, officials at 17 of 24 CFO Act agencies told GAO that controlling cloud costs required changes in how they manage IT.

Both findings can be true at once, and the gap between them matters to any prime running cloud hosting, migration, or operations work. The trackers agencies built depend on cost data, and much of that data sits in billing accounts a contractor operates.

## What Agencies Built to Close the 2019 Recommendation

GAO's status notes describe what each agency showed to close the recommendation. Several are specific:

| Agency | What GAO accepted | Reported |
| --- | --- | --- |
| Agriculture | A Cloud Broker Office using a dashboard that tracks cloud costs and captures savings per investment each fiscal year | March 2022 |
| DHS | A methodology memo using IT costs allocated to Technology Business Management towers, plus a spreadsheet of actual and planned savings per investment | May 2022 |
| Education | A SharePoint tool that tracks cost savings and avoidance from cloud migration | June 2023 |
| GSA | Data collection guidance plus a savings spreadsheet used in annual budget formulation | February 2021 |
| HHS | A dashboard tracking savings from migrating applications to cloud, each fiscal year | July 2023 |
| State | A tool called iMatrix tracking savings from cloud migration, each fiscal year | February 2023 |
| Treasury | Updated templates for collecting cloud savings data | November 2021 |
| VA | Apptio, plus scorecards showing savings and cost avoidance over time | February 2024 |

Commerce, Energy, Justice, Labor, SBA, and SSA also closed theirs. The wording GAO used explains the shape of these tools: the recommendation asked for savings "from the migration and deployment of cloud services." Most of the trackers count savings per investment, per fiscal year, as workloads move.

## Two Agencies and OMB Never Closed It

DoW (formerly DoD) disagreed with the recommendation. GAO's note says that as of October 2022, DoD's CIO office reported it did not intend to act, and DoD gave no further update as of November 2025.

DOT agreed but hadn't implemented it as of October 2024. In December 2025, a DOT official told GAO the department was working to finalize a cloud strategy and a standard operating procedure, expected by the end of fiscal 2026.

The government-wide number never got collected either. GAO asked OMB to require agencies to report cloud savings and cost avoidance at least quarterly. In March 2024, an OMB official said OMB did not intend to act. GAO still lists the recommendation as open, arguing that without the data, OMB and Congress can't see whether agencies are saving money in cloud.

## Counting Savings Isn't the Same as Controlling Spend

GAO's June 2026 report, [GAO-26-107530](https://www.gao.gov/products/gao-26-107530), shows the next problem. Cost control led the challenges agencies reported. Officials at 22 of 24 agencies said they rely primarily on historical procurement data to make cloud decisions, and GAO notes that providers generally bill for actual usage.

A tracker built to record migration savings by fiscal year shows whether moving an investment saved money. It doesn't tell a program office why this month's bill grew, which system the growth belongs to, or whether a commitment is about to expire. That is ongoing financial management of consumption, and it is what GAO's new recommendation targets. GAO told GSA to require agencies to [use FinOps practices and report the benefits](https://avalontechservices.com/capabilities/digital-transformation/cloud-and-it-infrastructure-services/finops), and the recommendation is open.

Our Technical Brief on [17 of 24 agencies struggling to control cloud costs](https://avalontechservices.com/technical-briefs/17-of-24-agencies-struggle-to-control-cloud-costs) covers that recommendation and the FinOps method behind it.

## The Data Behind the Tracker Comes From the Contractor

Every tracker in the table needs cost data attributed to an investment. In a contractor-operated environment, the billing accounts, the tagging, and the reseller invoices often sit with the prime, so a wrong number on the agency's dashboard usually traces back to the contractor's accounts.

That shows up in three places a capture team can plan for.

**Reporting deliverables.** Expect requirements to report spend by program, system, or investment, in a form that feeds the agency's tracker or its Technology Business Management reporting. An offer that can't attribute spend below the account level will struggle to meet them.

**Savings claims.** Agencies that track savings per investment will ask contractors to separate savings identified from savings realized. A proposal that promises a savings percentage without a measured baseline is hard to defend.

**Transition.** An incoming contractor inherits the incumbent's accounts and the numbers the agency already reported. Reconciling the billing data against what the tracker shows, early in transition, sets a clean starting point before the new contract's costs get mixed in.

Three things are worth pinning down before the draft RFP:

1. The tool the agency uses to track cloud savings, and who feeds it.
2. Whether cloud spend for this contract is allocated to investments today, and by what tagging standard.
3. Whether the agency expects FinOps reporting if GSA acts on GAO's recommendation.

## Where Avalon Fits

Avalon's [FinOps white paper](https://avalontechservices.com/white-papers/finops) describes the work behind those answers. A read-only audit pulls 12 to 24 months of native billing data, normalizes it to the FOCUS specification, reconciles it against reseller or vehicle invoices, and measures how much spend can be attributed to a program or system. The ongoing program enforces a tagging and allocation standard, tracks findings to realization each month, and produces cost allocation that feeds Technology Business Management tower reporting and IT investment data calls.

The work identifies and tracks savings. It does not guarantee them, and it is not a financial audit or attestation.

If cloud hosting, migration, or operations work is in your capture plan, Avalon teams as the sub that turns your contract's billing data into the allocated spend and tracked savings the agency's cloud tracker is waiting for.