We recommend that FMC:
1. Create an overarching policy, following Section 8 of OMB A-25, User Charges, as the overall policy document, to include the following:
a. The policy should address who holds the overall authority over the policy;
b. The policy should establish a working group of all offices involved in the biennial review of the procedures used, including inputs for direct and indirect costs, including collection methods; and
c. The policy should outline the overall approval hierarchy of calculated user fees.
2. Refine the User Fees procedures document to detail the overall processes, procedures, rationale, data inputs/outputs, and systems used in the process, to include the following:
a. The procedures should be reviewed prior to and at the completion of the biennial user fees calculation;
b. The procedures should be updated, as needed during the biennial review;
c. The document should be linked to supporting tables and documents;
d. Documentation supporting the procedures should be readily available for review.