OMB Circular A-11: Formulation, Apportionment, and Antideficiency

OMB Circular A-11 is the Office of Management and Budget’s master instruction manual for how every Executive Branch agency prepares, submits, and carries out the federal budget.¹ Updated each year, it sets the format for funding requests, the deadlines for submitting them, the rules for spending money after Congress appropriates it, and the performance data agencies must attach to their numbers. The current edition guides agencies through formulation of the Fiscal Year 2027 President’s Budget.

Where the Circular’s Authority Comes From

The Circular’s power traces to the Budget and Accounting Act of 1921, which created the Bureau of the Budget (now OMB) and charged it with assembling the President’s annual budget. Section 207 of that Act gave the Bureau authority to “assemble, correlate, revise, reduce, or increase” agency appropriation requests on behalf of the President.² That mandate is why OMB can dictate to agencies what data to submit, in what format, and by what deadline.

Federal law also requires the President to deliver a budget to Congress no later than the first Monday in February each year.³ Circular A-11 is the operational tool that makes that deadline achievable, converting a legal duty into a workflow that hundreds of agencies can follow in parallel.

The Budget Formulation Cycle

The cycle runs roughly 18 months from the earliest planning to the President’s transmittal to Congress. OMB orchestrates each phase through the Circular.

Spring Planning

Formulation begins in spring, when OMB issues high-level policy guidance outlining the President’s priorities for the upcoming fiscal year. Agencies use those signals to develop internal proposals, identify programmatic changes, and start drafting funding requests. The focus at this point is strategic direction rather than precise dollar amounts.

Fall Submissions to OMB

In the fall, agencies formally send detailed budget requests and supporting materials to OMB. The Circular specifies the exact data elements, financial tables, and narrative justifications each submission must contain. OMB analysts then review the requests against the President’s priorities and identify areas where proposed spending exceeds targets or lacks adequate justification.

Passback and Appeals

In late November, OMB sends its funding decisions back to all Executive Branch agencies at once, a step known as “passback.” If an agency head disagrees, they may formally appeal, and OMB and the agency typically work through disputes in December. Anything unresolved goes to the President.⁴ Passback is where actual funding levels get decided before the public sees a number.

The President’s Budget

Once appeals close, agencies finalize their submissions and OMB compiles the President’s Budget for transmittal to Congress by the first Monday in February.⁵ The final product includes the Budget Appendix with detailed financial data and proposed appropriations language for every account, plus analytical volumes and special analyses.

What Agencies Have to Submit

The Circular does not leave agencies guessing about formatting. It dictates the structure of every schedule, table, and justification that flows into the budget.

A core requirement is the object class schedule, which categorizes spending by what an agency buys rather than which program spends the money. The Circular defines five major object classes:

Personnel compensation and benefits (class 10): salaries for full-time, part-time, and military personnel, plus civilian and military benefits.
Contractual services and supplies (class 20): travel, rent, communications, advisory services, research contracts, and supplies.
Acquisition of assets (class 30): equipment, land, structures, and investments.
Grants and fixed charges (class 40): grants, subsidies, insurance claims, and interest payments.
Other (class 90): financial transfers and undistributed amounts.

Each class breaks down into detailed subcategories, which lets Congress and OMB compare spending patterns across agencies on a consistent basis.¹

Agencies enter their data into MAX A-11 DE, OMB’s web-based application for collecting and processing budget information.⁶ Every account must exist in OMB’s database before an agency can submit data for it, giving OMB structural control over how information flows in.

Spending the Money: Apportionment

Getting funds appropriated is only half the equation. The Circular also governs how agencies spend money once Congress passes an appropriations act, and the central mechanism is apportionment.

Before an agency can obligate funds, OMB must apportion them. An apportionment divides available budget authority by time period, program, or activity and sets a legally binding ceiling on how much the agency can spend. Requests go through OMB’s web-based apportionment system with detailed header information, properly formatted financial columns, and footnotes where applicable, and an authorized agency official must sign off before submission.¹

The point of apportionment is to prevent agencies from spending too much, too fast. By releasing budget authority in controlled increments, OMB keeps agencies from exhausting annual funding halfway through the fiscal year or spending in ways that conflict with congressional intent.

Antideficiency Act Consequences

Compliance matters because of the Antideficiency Act. The Act prohibits federal employees from obligating or spending more than the amount available in an appropriation, apportionment, or any administrative subdivision of funds. Because an apportionment is legally binding, exceeding one is a reportable violation.¹

When a violation occurs, the agency head must immediately report all relevant facts and corrective actions to the President (through the OMB Director), Congress, and the Comptroller General.⁷ The individual consequences are serious:

Administrative discipline: an employee who violates the Act is subject to suspension without pay or removal from office.
Criminal penalties: a knowing and willful violation can bring a fine of up to $5,000, imprisonment for up to two years, or both.

The penalties apply to obligations or expenditures that exceed the lower of the amount in the affected account, the apportioned amount, or any agency-designated fund control subdivision. For federal credit programs, the rules extend to direct loan and loan guarantee subsidies.

Tying Budgets to Results

The Circular requires agencies to connect their budget requests to measurable outcomes. That obligation flows from the GPRA Modernization Act of 2010, which overhauled how the federal government links spending to results.⁸

Every agency must publish a multi-year strategic plan with outcome-oriented goals for its major functions. Annual performance plans translate those goals into specific, quantifiable targets, describe how each goal contributes to broader strategic objectives, and identify the official personally responsible for achieving it.⁸

Large agencies also designate roughly four to five Agency Priority Goals every two years. These are high-impact targets that leadership picks to drive near-term improvement. Progress is reviewed quarterly, and results are published on a central government website so Congress and the public can track whether agencies meet their commitments.⁹ The quarterly cadence forces agencies to identify barriers in real time rather than at year end.

Rules for Major Capital Investments

The Circular contains specialized instructions for planning, acquiring, and managing major capital investments, particularly information technology systems and infrastructure projects. These apply a discipline called capital programming, which integrates planning, budgeting, and oversight across an asset’s full life cycle.

Before OMB approves funding for a major capital project, the agency must submit a business case that sets cost, schedule, and performance goals and justifies the investment through a benefit-cost analysis. Life-cycle costing is required, so agencies cannot estimate only acquisition costs; they must calculate total cost of ownership over the asset’s useful life.

For major acquisitions involving development work, contractors must use an Earned Value Management System meeting EIA Standard-748 guidelines. This applies to cost-reimbursement and fixed-price incentive contracts, and to firm-fixed-price contracts with significant development effort. All contracts using earned value management go through an Integrated Baseline Review to finalize the project baseline and identify risks.¹

The Circular sets a concrete performance standard. Agencies are expected to achieve at least 90 percent of the cost, schedule, and performance goals established at contract award. Falling below triggers a senior management review to decide whether the investment continues with modifications or is terminated. Agencies are also encouraged to set their own internal variance thresholds, and as a general guideline, a variance of plus or minus 10 percent should trigger formal reporting while there is still time to course-correct. Once a baseline is set at initial contract award, any change request that breaches the 90 percent threshold requires both agency head review and OMB approval before a new baseline can be incorporated.¹

1
Office of Management and Budget. Circular A-11 – Preparation, Submission, and Execution of the Budget
2
U.S. Government Accountability Office. Budget and Accounting Act of 1921
3
Office of the Law Revision Counsel. 31 USC 1105 – Budget Contents and Submission to Congress
4
The White House. OMB Circular A-11, Section 10 – Overview of the Budget Process
5
The U.S. House Committee on the Budget. Time Table of the Budget Process
6
The White House. OMB Circular A-11, Section 79 – The Budget Data System
7
Office of the Law Revision Counsel. 31 USC Subtitle II, Chapter 13, Subchapter III – Limitations, Exceptions, and Penalties
8
Congress.gov. Public Law 111-352 – GPRA Modernization Act of 2010
9
Performance.gov. Agency Priority Goals