The Finding
In February 2026, GAO published its review of federal shared services, GAO-26-108014 (opens in a new tab). Shared services, in GAO's words, are "the delivery of common services to federal agencies through consolidated, standardized capabilities offered through designated lead provider agencies." Four Quality Service Management Offices (QSMOs) run the marketplaces: CISA for cybersecurity, Treasury for financial management, HHS for grants management, and OPM for human resources.
GSA coordinates the program. GAO found that GSA and agencies do not have comprehensive data on how well shared services are meeting agencies' needs. GSA and the QSMOs track basic service measures and customer experience data, but GSA had not collected all of its performance management framework data outside a pilot with one provider, and had yet to collect data on the actual costs of shifting to shared services.
GAO's fourth recommendation reads: GSA should, "in coordination with the four QSMOs, establish and implement a revised plan and time frame for collecting data outlined in its performance management framework, including cost data." In July 2026, GAO's priority letter to GSA (opens in a new tab) (GAO-26-108996) named it one of 11 priority recommendations among GSA's 38 open ones.
Why It Keeps Happening
GSA paused the work. According to GSA officials quoted in the report, the agency put further development of the framework methodology on hold in early 2025 "due to resource constraints and changing priorities," and had not set a new timeline when GAO reported.
The structure spreads the data across agencies. Under OMB M-19-16 (opens in a new tab), a non-GAO memo from April 2019, QSMOs manage marketplaces of solutions in their functional areas, while GSA performs the program management functions for the whole process. Cost and performance data sit with the providers and the QSMOs. GSA has to assemble it from four lead agencies that each run their own marketplace.
Agencies feel the gap at the decision point. Of the eight agencies GAO surveyed, four said they lacked the data needed to make clear decisions about whether to adopt a shared service from a specific provider. Five cited issues with existing providers' performance. Without comparable cost and performance figures, an agency weighing a provider is comparing marketing claims against its own legacy system.
Why It Matters to Your Bid
Financial management, HR, payroll, and grants modernizations can start with a choice: move to a provider on a QSMO marketplace, or modernize in place. GAO's report says the government-wide data to inform that choice doesn't exist yet, and GSA's own target for cost data collection is March 2027.
That gap lands on the offeror. An evaluator reading a migration or modernization proposal for a mission-support system wants to see how the solution chose its destination. A proposal that names a provider without a scored comparison and a cost basis reads as assumption. One that shows the comparison criteria, the cost model, and how actual cost will be tracked after the move reads as understanding of the requirement.
Recompetes add a second test. An agency already on a shared provider may be reconsidering it, since five of the eight surveyed agencies reported provider performance issues. Exit terms and portability then become technical volume content, not boilerplate.
The same discipline shows up in cloud work generally. Our brief on cloud cost control at 17 of 24 agencies covers the consumption side.
Technical Approach
The method below comes from Avalon's Gov-Shared Cloud Services work. It is described at the methodology level, for civilian destinations at FedRAMP Moderate or below.
- Inventory the function and its data. List the workloads, interfaces, and data types (PII, CUI) the mission-support function carries today. The inventory sets the impact level and the control baseline any candidate provider has to meet, and it gives every later cost figure a defined scope.
- Score candidate providers on the same five criteria. Compare each marketplace option, and the stay-in-place option, on impact level support, the controls the program can inherit, the cost model, onboarding lead time, and exit terms. Read inheritable controls from each provider's Customer Responsibility Matrix against the program's NIST SP 800-53 Rev 5 baseline. The output is a scoring workbook and a written decision record the program can defend to its CIO, its assessor, and its budget office, including when the answer is that no shared option fits.
- Run onboarding on a dated plan. Work the provider's intake process, including interagency agreement mechanics and sponsor and funding coordination. Date-stamp every agency- and provider-dependent step in the plan, so planned versus actual lead time is recorded rather than remembered.
- Make the cost of the shared service visible. Set a tagging standard and tag dictionary, and a consumption and chargeback or showback model, so the program sees what the shared service actually costs it each period. That record is the program-level version of the cost data GAO wants collected.
- Write the exit before it's needed. Hand off a service-request runbook, a roles and permissions model, and exit and portability notes for the provider's next recompete.
This work produces decision and cost records for a program. It does not build GSA's performance framework, and it does not authorize a system. The agency's authorizing official makes that decision.
What "Fixed" Looks Like
GAO has not published closure evidence for this recommendation. Its April 2026 status note says GSA planned to implement a standardized approach to collecting cost data by March 30, 2027.
Targets, written as targets:
- Framework data collected for providers in all four QSMO areas, beyond the single-provider pilot.
- Cost data on the actual cost of moving to shared services, collected on a set cycle.
- At program level: a scored decision record for every shared service adoption, and actual cost tracked against the cost basis used to choose.
Status Check
Recommendation 4 of GAO-26-108014 is a priority recommendation and was open as of GAO's last update, April 2026. GAO's July 2026 priority letter lists it among GSA's 11 open priority recommendations as of June 2026. The other three, to OMB and GSA, were open too.
Teaming Fit
| Field | Detail |
|---|
| NAICS | 541512, 541611 |
| Avalon's sub role | Shared service provider fit scoring with a written decision record, dated onboarding plan, and a tagging and chargeback model that tracks actual cost after the move, under the prime's modernization or migration task order |
| Small-business status | Small business; HUBZone (in progress) |
| Likely vehicles | GSA MAS (SIN 518210C Cloud Computing and Cloud Related IT Professional Services); GSA MAS (SIN 54151S IT Professional Services); GSA Alliant 3 |
If a civilian agency's move to a shared financial management, HR, or grants provider is in your capture plan, Avalon teams as the sub that scores the providers, documents the decision, and tracks what the shared service actually costs after the move.