The federal government’s civilian landlord, the General Services Administration, has a quality-control system for assessing the condition of federal buildings: one employee conducts the survey, and another approves it, at least in principle.
In practice, a new audit by the General Services Administration’s Office of Inspector General found that hundreds of building assessments were both completed and approved by the same employee — effectively allowing the person conducting the assessment to serve as their own second set of eyes.
GSA’s Public Buildings Service uses its Building Assessment Tool, or BAT, to document building conditions and estimate repair and maintenance liabilities across the federal real-estate portfolio. The OIG examined 2,949 BAT surveys completed between fiscal years 2022 and 2025 and found that 524 — nearly 18 percent — were both completed and approved by the same employee. Those assessments were not financially trivial: together, they represented approximately $5.27 billion in reported repair and maintenance liabilities.
Independent Review, With an Asterisk
Under the BAT process, GSA assigns separate roles to a surveyor and an approver. The surveyor assesses building systems and identifies deficiencies, while the approver is supposed to review that work for completeness and accuracy before the assessment becomes final. On paper, that division provides an obvious internal control: somebody checks the work. In the system as implemented, however, that somebody did not always have to be somebody else.
According to the OIG, PBS guidance did not explicitly prohibit an employee from serving as both surveyor and approver. A GSA frequently asked questions document even addressed the possibility directly.
“Can I be a Surveyor as well as an Approver for a BAT survey?”
The guidance acknowledged that employees could perform both roles, although doing so was “not recommended.” The OIG concluded that allowing employees to approve their own surveys undermined the independence of the review and increased the risk that errors or omissions would go undetected.
The Fix Had a Loophole
PBS eventually attempted to close the loophole. On June 30, 2025, GSA implemented a system control intended to prevent the same employee from being assigned as both surveyor and approver on a BAT assessment. The control, however, came with an exception: administrative and management users could override the restriction.
The OIG subsequently identified 44 surveys in which the same employee completed and approved the assessment even after the new control had been implemented. Auditors also found broader inconsistencies in how survey responsibilities were recorded. Some surveys had no approver assigned; others lacked both an assigned surveyor and approver; and in 106 instances, according to the OIG, the employee who actually completed and approved the survey was not listed as either the assigned surveyor or approver.
The OIG recommended that PBS establish policies explicitly prohibiting employees from approving their own BAT surveys and strengthen system controls to enforce the separation. GSA agreed with the recommendations.
A Much Larger Ledger
The procedural flaw matters because BAT is not merely an inspection checklist. The assessments feed into GSA’s accounting for billions of dollars in federal building repair and maintenance needs, so errors in those surveys can affect the government’s picture of the condition — and cost — of its own real estate.
The same audit concluded that GSA understated repair and maintenance liabilities in dozens of building assessments and identified broader weaknesses in how the agency gathers information about the condition of federal properties. Those findings raise a larger question: how accurately does the federal government’s landlord know what its buildings actually need, and what that will cost?
That question, and the understated liabilities behind it, will be the focus of Part 2. For now, the quality-control problem is more straightforward: the federal government required someone to check the building inspector’s work, and for hundreds of assessments, it was prepared to let the building inspector do it.
Bureaucracy Times 