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GAO-10-685R: 

United States Government Accountability Office: 
Washington, DC 20548: 

September 21, 2010: 

The Honorable Richard Durbin:
Chairman:
The Honorable Susan Collins:
Ranking Member:
Subcommittee on Financial Services and General Government: 
Committee on Appropriations: 
United States Senate: 

The Honorable Charles E. Schumer:
Chairman:
Committee on Rules and Administration:
United States Senate: 

Subject: House and Senate Campaign Expenditures: Available Historical 
Data Limited, but Range of Limited Estimates for Reported Media-
Related Expenditures Possible: 

This letter formally transmits the enclosed briefing in response to 
congressional direction in a Senate Appropriations Committee Report 
(S. Rep. No. 110-129) to report on the 10-year trend in House and 
Senate campaign costs and the percentage of those costs incurred due 
to rising broadcast advertising rates.[Footnote 1] Specifically, we 
are reporting on the extent to which data on House and Senate campaign 
operating expenditures, especially media-related expenditures, are 
available and what the data show about the range of estimates of media-
related expenditures as a proportion of itemized operating 
expenditures. For a summary of the results of our work, see enclosure 
1, slide 9. On the basis of the results of our review, we are not 
making any recommendations for congressional consideration or agency 
action. 

We are sending copies of this report to the Chairman of the Federal 
Election Commission, as the commission provided the data on which we 
based our analysis; appropriate congressional committees; and other 
interested parties. This report will also be available at no charge on 
our Web site at [hyperlink, http://www.gao.gov]. Should you or your 
staff have questions concerning this report, please contact me at 
(202) 512-8777 or jenkinswo@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Key contributors to this report were Mary 
Catherine L. Hult, Assistant Director; Barbara A. Stolz, Analyst-in-
Charge; Jeffery M. Tessin; Amanda K. Miller; Geoffrey R. Hamilton; and 
Carolyn S. Blocker. 

Signed by: 

William O. Jenkins:
Director, Homeland Security and Justice Issues: 

Enclosures - 2: 

Enclosure 1: House and Senate Campaign Expenditures: Available 
Historical Data Limited, but Range of Limited Estimates for Reported 
Media-Related Expenditures Possible: 

House and Senate Campaign Expenditures: Available Historical Data 
Limited, but Range of Limited Estimates for Reported Media-Related 
Expenditures Possible: 

Briefing for the Subcommittee on Financial Services and General 
Government, Committee on Appropriations: 

September 2, 2010: 

For more information, contact William 0. Jenkins at (202) 512-8777 or 
jenkinswo©gao.gov. 

Briefing Overview: 
* Introduction; 
* Objectives, Scope, and Methodology; 
* Summary; 
* Background; 
* Findings; 
* Agency Comments. 

Introduction: 

Pursuant to its authority to regulate federal elections, Congress has 
passed legislation: 

* requiring House and Senate campaign committees to disclose publicly 
the campaign funds that they raise and spend, and, 

* establishing the Federal Election Commission (FEC) as an independent 
regulatory agency to administer and enforce federal campaign finance 
laws. 

Debates about campaign finance often point to television advertising 
as a major reason for the high cost of campaigns. 

To help Congress better understand the impact of the cost of political 
advertising on the overall escalation of the costs of House and Senate 
campaigns, a Senate Appropriations Committee Report (S. Rep. No. 110-
129) directed GAO to report on the 10-year trend in the cost of House 
and Senate campaigns and the percentage of those costs incurred due to 
rising broadcast advertising rates.[Footnote 2] 

Objectives, Scope, and Methodology: 

Objectives: 

As agreed with your offices, this report addresses the following 
questions: 

* To what extent are data available on the cost of U.S. House and 
Senate campaigns from 1998 through 2008 and the costs incurred due to 
broadcast advertising rates? 

* What are the trends in reported U.S. House and Senate candidate 
campaign expenditures over the past 10 years, and what proportion of 
these expenditures are media-related? 

Scope and Methodology: 

To answer the first objective, we identified possible federal, 
academic, and commercial data sources on House and Senate campaign 
expenditures and broadcast advertising rates by: 

* Reviewing relevant documents, such as congressional campaign 
committee financial reporting forms and guidance, from the FEC to 
which House and Senate principal campaign committees are required to 
report contributions and expenditures;[Footnote 3] 

* Reviewing academic studies; 

* Interviewing FEC officials responsible for managing and maintaining 
campaign disclosure systems that include expenditure data; and; 

* Interviewing: 

- five media consultants, selected on the basis of party affiliation 
(Democratic, Republican, and nonpartisan), years of experience, and 
breadth of political clients (e.g., House, Senate, state, and local 
candidates in several states), and; 

- five academic experts in campaign finance and campaign media 
advertising, selected from our review of the literature and 
recommendations of experts. 

Although the views of the media consultants and academic experts are 
not representative, they provided general information on the 
availability and limitations of data to address the mandate. 

To address the second objective, we obtained and analyzed 
electronically available FEC data for operating expenditures[Footnote 
4] for House and Senate principal campaign committees from 1997 
through 2008.[Footnote 5] 

As part of this analysis, we took the following actions to assess the 
reliability, completeness, and logical consistency of the data for 
purposes of this objective: 

* Reviewed FEC documents on the development and maintenance of its 
electronic data system, such as specification requirements for its 
electronic data system and candidate reporting forms, and interviewed 
FEC officials to determine how the data were collected and verified; 

* Ascertained the extent to which the data provided were complete and 
logically consistent; 

* Discussed any anomalies and instances of missing data with FEC 
officials responsible for managing and maintaining the disclosure 
systems to identify possible data entry errors, and, as appropriate, 
adjusted our analysis. 

We found the FEC data to be sufficiently reliable for presenting 
overall trends in total operating expenditures and developing ranges 
of estimated media-related expenditures for House and Senate principal 
campaign committees. 

* Because the FEC data were self-reported by the committees and no 
standardized reporting requirements exist, the estimates are subject 
to imprecision and require numerous caveats. 

* Limitations of the estimates and related data reliability and 
methodological issues are discussed throughout the report; key 
limitations are highlighted on slides 14 and 15. 

We conducted our work from December 2009 through July 2010 in 
accordance with all sections of GAO's Quality Assurance Framework that 
are relevant to our objectives. The framework requires that we plan 
and perform the engagement to obtain sufficient and appropriate 
evidence to meet our stated objectives and to discuss any limitations 
in our work. We believe that the information and data obtained, and 
the analysis conducted, provide a reasonable basis for any findings 
and conclusions in this product. 

Summary: 

Using FEC data on itemized operating expenditures by principal 
campaign committees, it was possible to develop a range of estimates 
for media-related expenditures, but data were not available to 
determine the House and Senate campaign costs that were attributable 
to broadcast advertising rates. 

FEC compiled and provided to GAO electronic databases that included 
total operating expenditures reported by House and Senate principal 
campaign committees from 1997 through 2008, and itemized operating 
expenditures for House candidate committees for the 2004, 2006, and 
2008 election cycles and Senate candidate committees for 2007 through 
2008.[Footnote 6] Using these data: 

* Total reported operating expenditures nearly tripled for House 
candidate committees and approximately doubled for Senate candidate 
committees during the reporting periods we reviewed. 

* Estimates for total media-related expenditures, as a proportion of 
total itemized operating expenditures, varied depending on the 
specific media-related terms used to generate estimates. For all House 
campaigns,. the range of estimates was from 8 to 38 percent for the 
2004, 2006, and 2008 election cycles and for all Senate campaigns the 
range was from 6 to over 40 percent for 2007 through 2008. 

* Estimates of media-related expenditures as a proportion of each 
campaign's total itemized operating expenditures varied across House 
and Senate campaigns, using the same media-related terms to generate 
the estimate. 

Background: 

House and Senate Campaign Expenditure Reporting Requirements: 

Federal election campaign law and regulations require the principal 
campaign committees for House and Senate seats to file reports on 
contributions and expenditures, but do not require the use of 
standardized terms to report the purpose of expenditures. 

House and Senate candidate committees must file reports with the FEC. 
Since 1987, FEC has maintained total operating expenditure data 
electronically. 

* Since 2001, House candidate committees have been required to use an 
electronic format for filing with the FEC if either contributions or 
expenditures exceed or are expected to exceed $50,000 during the 
calendar year. 

* Senate candidate committees file on paper with the Secretary of the 
Senate who forwards a copy to the FEC. Since September 2005, FEC has 
had itemized expenditure data entered into its electronic data system. 

Campaign finance reports must itemize operating expenditures exceeding 
$200 in an election cycle and provide a brief description of the 
purpose of the expenditure, which, when considered with the identity 
of the expenditure recipient, should, according to FEC guidance, be 
sufficiently specific to make its purpose clear. 

FEC has guidance on adequate and inadequate descriptions of 
expenditures. 

Examples of descriptions of purposes with sufficient detail include: 

* "Media" for an expenditure to a television or radio communication 
company or; 

* "Polling" for an expenditure to a research/communications company. 

Examples of descriptions of purposes lacking sufficient detail 
include: administrative expenses, campaign expenses, or consulting. 

According to FEC, expenditures are subject to fewer and less complex 
requirements than contributions under the Federal Election Campaign 
Act. 

* However, FEC campaign finance analysts review and evaluate every 
reported itemized House and Senate campaign operating expenditure. 

* Analysts review reported purposes of expenditures to determine 
whether they are sufficiently specific, per FEC guidance (See slide 
10). If found to be insufficiently specific, a campaign committee may 
amend its report. 

* In the appropriate circumstances, FEC can conduct a separate review 
of the sufficiency of the description of purpose to determine whether 
it meets the statutory and regulatory requirements. 

Objective 1: Data Limited; Range of Media-related Estimates Possible: 

Campaign Operating and Media-Related Expenditure Data Available, But 
Costs That Were Incurred Due to Broadcast Advertising Rates Could Not 
Be Determined: 

Data were available on the operating expenditures reported by House 
and Senate candidate committees from 1997-through 2008, but not in a 
way that separates the costs that were incurred due to broadcast 
advertising rates. 

The FEC compiled and provided to GAO electronic databases that 
included operating expenditure data reported by House and Senate 
candidate committees from 1997 through 2008 and limited data 
describing the purpose of these expenditures (e.g., media-related 
expenses). However, the FEC data do not provide information on 
broadcast rates. 

The Campaign Media Analysis Group (CMAG) and Wisconsin Advertising 
Project reported estimates of paid televised political advertising 
costs, but estimates: 

* did not include all media markets and, therefore, not all campaigns, 
for the entire 10-year period we reviewed,[Footnote 7] and; 

* were based on average, not actual, campaign advertising expenditures. 

Information on broadcast time purchase requests by political 
candidates are not centrally located, but maintained at stations 
across the country.[Footnote 8] 

FEC Maintained Limited Itemized Expenditure Data: 

From electronically available FEC itemized campaign committee data, it 
is possible to develop a range of estimates for media-related 
expenditures for House and Senate principal campaign committees. 
[Footnote 9] These estimates are subject to imprecision and require 
numerous caveats because of the limitations of these data (See slides 
14 and 15). 

FEC compiled and provided GAO with electronic data bases that included 
itemized operating expenditure data for: 

* House principal campaign committees for the 2004, 2006, and 2008 
election cycles, and; 

* Senate principal campaign committees from 2007 through 2008. 

Despite Limitations of FEC Itemized Campaign Expenditure Data, A Range 
of Estimates of Campaign Media-related Expenditures Can Be Developed: 

Despite the limitations of FEC itemized expenditure data, a range of 
estimates of media-related expenditures can be developed using the 
purpose of itemized expenditures to create lists of media-related 
expenditure terms and applying the lists to House and Senate 
expenditure data.[Footnote 10] 

According to FEC officials, no standard reporting requirements exist 
and itemized expenditure descriptions are self-reported in response to 
an open-ended question. 

* Federal election campaign law requires the identification of the 
purpose of expenditures, while regulations specify that the "purpose" 
means a "brief description of why the expenditure was made." 

* Neither the law nor the regulations require the use of standardized 
terms to report expenditures. Examples of descriptions that meet such 
requirements include, for example, dinner expenses, media, salary, 
polling, and travel. 

FEC itemized expenditure data, therefore, have the following 
limitations: 

* The specificity of terms used to report media-related expenditures 
varies. Terms may be as precise as "television ad" or as general as 
"media services." 

* The consistency of the description of an itemized expenditure 
reported by campaign committees may vary across committees or for the 
same committee over time. 

* Campaign committee reports may combine different types of 
advertising costs (e.g., "media buy, direct mail and postage") into a 
single expenditure, depending on the nature of the campaign's 
relationship with its vendors. However,-because the cost of each item 
reported in combination cannot be determined, it is impossible to 
identify specific broadcast or advertising costs. 

* Estimates generated from these data will under or over report media-
related expenditures, but it is not possible to determine the amount 
or direction of such under or over reporting. 

To develop a range of media-related campaign expenditure estimates, we 
created the following three lists of media-related terms: 

* All media-related expenditures: includes all media-related 
advertising and production terms, such as television, radio, cable, 
newspaper, event, ad buys, signage, and Internet advertising. 

* Broadcast media expenditures: includes those media-related 
advertising and production terms related to broadcast media, such as 
television, radio, cable advertising, time buy, airtime, and 
commercials. 

* Media consultants: includes the term consult with media-related 
terms such as communications, ad, advertising, television, radio, and 
video. FEC has provided "consulting-media" as an example of an 
acceptable entry for the purpose of an expenditure. Expenditures 
reported using this term may include the cost of producing an ad and 
media buys paid through a consultant, as well as fees paid to a 
consultant. 

From the three lists, we created four categories to generate 
estimates, ranging from broadest to most narrow: 

* All media-related expenditure and media consulting terms, 

* All media-related expenditure terms, 

* Broadcast media expenditure and media consulting terms, and, 

* Broadcast media terms. 

Applying the categories to electronically available itemized operating 
expenditure data, we generated a range of media-related expenditure 
estimates. 

Because the estimates and range of estimates are based on the specific 
terms included in the lists, using other terms would produce different 
estimates and different ranges of estimates. (See appendix 1 for 
further details.) 

Objective 2: House and Senate Campaign Media-related Expenditure 
Estimates: 

Aggregate reported total operating expenditures for House candidate 
committees nearly tripled between the 1998 and 2008 election cycles, 
and for Senate candidate committees approximately doubled during the 
same time period. 

Estimates of media-related expenditures reported by House candidate 
committees for the 2004, 2006, and 2008 election cycles ranged from 8 
to 38 percent of total itemized operating expenditures within each 
cycle. 

Estimates of media-related expenditures reported by Senate candidate 
committees for the 2-year period from 2007 through 2008 ranged from 6 
percent to over 40 percent of total itemized operating expenditures. 

However, for House and Senate candidate committees, media-related 
expenditure estimates, created using the category all media-related 
expenditure and media consultant terms, as a proportion of each 
campaign's total itemized operating expenditures, varied across 
campaigns. 

Media-related Expenditure Estimates: Aggregate Total Operating 
Expenditures Reported by House Principal Campaign Committees Nearly 
Tripled between the 1998 and 2008 Election Cycles: 

Table 1: Aggregate Total Operating Expenditures Reported by House 
Campaign Committees for Each Election Cycle from 1998 through 2008: 

Election cycle: 1998; 
Total operating expenditures: $293,501,133. 

Election cycle: 2000; 
Total operating expenditures: $372,621,860. 

Election cycle: 2002; 
Total operating expenditures: $525,979,829. 

Election cycle: 2004; 
Total operating expenditures: $574,857,230. 

Election cycle: 2006; 
Total operating expenditures: $741,889,182. 

Election cycle: 2008; 
Total operating expenditures: $827,794,776. 

Source: GAO analysis of Federal Election Commission data. 

Note: Two calendar years comprise each election cycle. For example, 
1998 cycle includes expenditures that principal campaign committees 
reported making from January 1, 1997, through December 31, 1998. 

[End of table] 

Estimates of Aggregate Media-related Expenditures Ranged from 8 to 38 
Percent: 

The range of estimates of aggregate media-related expenditures 
reported by House candidate committees, as a proportion of the total 
itemized operating expenditures, were 8 to 33, 10 to 38, and 10 to 36 
percent for the 2004, 2006, and 2008 election cycles, respectively. 

For each category of media-related expenditures, the estimates 
remained stable across the three election cycles. (See slide 21.) 

However, media-related expenditure estimates, created using the 
category all media-related expenditure and media consultant terms, as 
a proportion of each campaign's total itemized operating expenditures 
reported, varied across House campaigns. (See slide 22.) 

* Estimates of the proportion of each House campaign's media-related 
expenditures ranged from an average of 18 percent to 19 percent for 
the 2004, 2006, and 2008 election cycles. 

* Between 37 to 65 percent of House committees did not report an 
itemized expenditure with a media-related purpose in the 2004, 2006, 
and 2008 election cycles. 

Range of Aggregate House Media-Related Expenditure Estimates As a 
Proportion of Itemized Operating Expenditures for the 2004, 2006, and 
2008 Election Cycles: 

Figure 1: Range of Aggregate House Media-Related Expenditure Estimates 
As a Proportion of Itemized Operating Expenditures, 2004 through 2008: 

[Refer to PDF for image: vertical bar graph] 

Election Cycle: 2004; 
All media and media consultants: 33%; 
All media: 32%; 
Broadcast media and media consultants: 10%; 
Broadcast media: 8%. 

Election Cycle: 2006; 
All media and media consultants: 38%; 
All media: 37%; 
Broadcast media and media consultants: 12%; 
Broadcast media: 10%. 

Election Cycle: 2008; 
All media and media consultants: 36%; 
All media: 34%; 
Broadcast media and media consultants: 12%; 
Broadcast media: 10%. 

Source: GAO analysis of Federal Election Commission data. 

Note: Itemized operating expenditures are not equal to total operating 
expenditures, as itemized operating expenditures may not include 
expenditures of less than $200. 

[End of figure] 

Estimates of All Media-related Expenditures As a Proportion of Each 
House Campaign's Total Itemized Operating Expenditures Vary by 
Campaign: 

Figure 2: Media-related Expenditure Estimates As a Proportion of Each 
House Campaign's Total Itemized Operating Expenditures, 2004 through 
2008 Election Cycles: 

[Refer to PDF for image: 3 vertical bar graphs] 

Percentage of spending on media plotted against number of campaigns 
for 2004, 2006, and 2008. 

Source: GAO analysis of Federal Election Commission data. 

Note: Figure includes data from category all media-related 
expenditures and media consultant expenditures. 

[End of figure] 

Aggregate Total Operating Expenditures Reported by Senate Campaign 
Committees Approximately Doubled between 1997-1998 and 2007-2008: 

Table 2: Aggregate Total Operating Expenditures Reported by Senate 
Campaign Committees from 1997 through 2008, Reported by 2-year Periods: 

Year: 1997-1998; 
Total operating	expenditures: $171,674,293. 

Year: 1999-2000; 
Total operating	expenditures: $233,737,754. 

Year: 2001-2002;
Total operating	expenditures: $241,261,092. 

Year: 2003-2004; 
Total operating	expenditures: $387,207,435. 

Year: 2005-2006; 
Total operating	expenditures: $437,548,365. 

Year: 2007-2008; 
Total operating	expenditures: $355,570,233. 
					
Source: GAO analysis of Federal Election Commission data. 

Note: Each 2-year calendar period includes operating expenditures 
reported by campaign committees for all three Senate classes at each 
stage of the 6-year Senate term, with the same pattern of classes and 
stages reported twice (1997-1998 and 2003-2004, 1999-2000 and 2005-
2006, and 2001-2002 and 2007-2008) during the six 2-year periods. 

[End of table] 

Aggregate total operating expenditures reported by Senate candidate 
committees approximately doubled between 1997-1998 and 2007-2008. 

Aggregate total operating expenditures reported by the Senate classes 
in each comparable 2-year period ranged from about one and a half to 
more than two times greater in the second period than in the first. 

Range of Estimates of Senate Media-Related Expenditures, as a 
Proportion of Total Itemized Operating Expenditures for 2007 through 
2008: 

For 2007 through 2008, the range of estimates of aggregate Senate 
campaign media-related expenditures as a proportion of the total 
itemized operating expenditures reported were as follows:[Footnote 11] 

* All media-related expenditure and media consultant terms--44 percent. 

* All media-related expenditure terms--43 percent. 

* Broadcast media expenditure and media consultant terms--7 percent. 

* Broadcast media terms--6 percent. 

As the Senate media-expenditure estimates were for a single 2-year 
period, no generalizations about such expenditures in other time 
periods can be made. 

Within the 2-year period, media-related expenditure estimates, created 
using the category all media-related expenditure and media consultant 
terms as a proportion of each Senate campaign's total itemized 
operating expenditures, varied across Senate campaigns. (See slide 25.) 

* Estimates of the proportion of each Senate campaign's media-related 
expenditures averaged 15 percent. 

Estimates of Media-related Expenditures As a Proportion of Each Senate 
Campaign's Total Itemized Operating Expenditures Vary across Campaigns: 

Figure 3: Media-related Expenditure Estimates As a Proportion of Each 
Senate Campaign's Total Itemized Operating Expenditures for 2007 
through 2008: 

[Refer to PDF for image: vertical bar graph] 

Percentage of spending on media plotted against number of campaigns. 

Source: GAO analysis of Federal Election Commission data. 

Note: Figure includes data from category all media-related 
expenditures and media consultant expenditures. 

[End of figure] 

Agency Comment: 

We provided a draft of this report to FEC for review of the data and 
comment. 

FEC provided technical comments, which we incorporated into the 
report, as appropriate. 

GAO on the Web: 

Web site: [hyperlink, http://www.gao.gov/] 

Contact: 
Chuck Young, Managing Director, Public Affairs, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: 

Copyright: 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. The published product may be 
reproduced and distributed in its entirety without further permission 
from GAO. However, because this work may contain copyrighted images or 
other material, permission from the copyright holder may be necessary 
if you wish to reproduce this material separately. 

[End of Enclosure I] 

Enclosure 2: Additional Information on the Analysis of Media-Related 
Spending by House and Senate Campaigns: 

This enclosure provides additional details about our methods for 
estimating whether an expenditure reported by a House or Senate 
campaign committee was media-related and provides a broader range of 
media-related spending estimates.[Footnote 12] 

Background: 

The Federal Election Commission (FEC) collects data on the spending of 
U.S. House and Senate candidate campaign committees pursuant to the 
Federal Election Campaign Act.[Footnote 13] Registered campaign 
committees must file a FEC Form 3 to describe their spending in 
defined periods of time, including calendar quarters, 12 days before 
an election, and 30 days after an election. Committees report 
information about spending on the FEC Form 3, and specifically, report 
the itemized amount, recipient, and purpose of any expenditure that 
exceeds $200 on the accompanying Schedule B (Line 17).[Footnote 14] 

The "purpose of disbursement" disclosures on Form 3 provide limited 
information about the products and services that committees purchase. 
Federal election campaign law requires identification of the purpose 
of expenditures, and regulations specify that the "purpose" means a 
"brief description of why the expenditure was made." Examples of 
sufficiently detailed entries, as described by FEC guidance, include 
"media" for an expenditure made to a television or radio communication 
company and "consultant-media" for an expenditure made to a consultant 
or consulting company. The level of detail required for statutory and 
regulatory compliance is not necessarily sufficient to identify 
whether a committee purchased a particular type of advertising. For 
example, a committee could describe an expenditure as "media," without 
specifying whether the advertising appeared on television. Committees 
also can combine expenditures into one entry, such as "consulting and 
media," which cannot be disaggregated by reviewing the Form 3 only. 

Although FEC Form 3 data cannot specifically identify all broadcast 
advertising expenses, they can be used to develop a range of media- 
related expenditures for House and Senate principal campaign 
committees. Because of the ambiguity of the data, we used several 
methods of estimating whether an expenditure was media-related. 

Period and Unit of Analysis: 

We limited our analysis to two-year periods for which the FEC was able 
to provide electronic expenditure data for all principal House and 
Senate campaign committees.[Footnote 15] FEC provided us with 
electronic data for House committees beginning in April 2002 and for 
Senate committees in September 2005. We further limited our analysis 
to the three two-year periods between 2003 and 2008 for House 
committees and to 2007 and 2008 for Senate committees. 

Our time periods of analysis differed from FEC's definition of an 
election cycle. For a particular seat or office, an FEC election cycle 
for reporting purposes begins on the day after the previous general 
election and ends on the day of the next general election. 
Consequently, grouping expenditures within FEC election cycles may not 
measure all spending for a particular election, because committees may 
use goods and services before election day but pay for them in the 
weeks afterward. For example, a committee may report an expenditure in 
December to pay for television advertisements that aired in the first 
week of November. Accordingly, we grouped the data into periods of 2 
calendar years, rather than FEC election cycles, to link expenditures 
that occurred between election day and December 31 to the most 
relevant election. 

A two-year period of analysis also helps standardize spending across 
House and Senate committees, which have two-and six-year election 
cycles, respectively. Although the electronically available Senate 
committee data did not include a full six-year election cycle, we were 
able to analyze spending in the final two years of the 2008 cycle 
(from 2007 through 2008). This period includes Senate committees at 
varying stages of their election cycles, including those running for 
election in 2008, 2010, and 2012. In the attached briefing, we refer 
to our periods of analysis as "election cycles" for House committees. 

We limited our analysis to the principal campaign committees of House 
and Senate candidates in order to describe the spending of a well- 
defined population. Although other groups, such as party and political 
action committees, purchase political advertising, it is more 
difficult to identify all relevant groups that made expenditures on 
behalf of candidates in a particular period of time. In contrast, 
principal campaign committees can be defined and identified easily in 
any election cycle and often continue to exist across multiple cycles. 

For the time period of our analysis, the Form 3 data included a total 
of 1,522,686 and 198,631 itemized expenditures, described in 71,779 
and 13,504 filings, for House and Senate committees, respectively. 

Measuring Media-Related Spending: 

The quantity and imprecision of the itemized expenditure purpose data 
complicated our measurement of media-related spending. Because 
committees may describe the purpose of each itemized expenditure with 
open-ended text, we could not use a set of standardized terms or 
numeric codes to describe their spending.[Footnote 16] Instead, we 
analyzed a broad range of terms that committees used to describe their 
spending across thousands of filings. Specifically, to measure media- 
related spending, we developed a set of relevant text patterns (e.g., 
"ADV" or "TIME BUY") and then identified which patterns appeared in 
the itemized expenditures. We developed these patterns using an 
iterative method of specifying initial text patterns (as discussed 
below), applying them to the data, and then updating the patterns 
based on the accuracy of the initial results. 

Creating Initial Text Patterns: 

We created initial text patterns using terms that were logically 
related to political advertising and the use of print or broadcast 
media. We based our initial patterns on those that FEC used in its 
feasibility assessment.[Footnote 17] The initial patterns included any 
of the following text, listed within quotation marks, in the purpose 
of disbursement field: "ADVER", "ADS", "AD", "CABLE", "COMMERCIAL", 
"TELEV", "TV", "BROADCAST", "MEDIA", "NEWSP", or "RADIO". 

We used a computer program to identify whether each itemized 
expenditure contained any of the initial patterns. For the House and 
Senate, respectively, we found 96,180 and 8,598 expenditures that 
matched the initial patterns. We applied the initial patterns to all 
expenditures provided by FEC, regardless of whether they were 
collected in periods with complete electronic data, in order to 
maximize the number of patterns we had available to make coding 
decisions. 

Assessing the Quality of the Initial Coding: 

We then examined the coding results that the initial text patterns and 
automated search process produced. A manual review allowed us to 
describe the text patterns that committees used, which may vary from 
the patterns that one might expect in advance. This approach reflected 
our strategy of estimating a range of expenditures, based on the 
specificity of the descriptions that committees actually used. 

Three team members reviewed all of the expenditures initially coded as 
media-related. Each team member used her own judgment to determine 
whether the computerized coding rule accurately identified a media- 
related expenditure. Due to the number of expenditures and imprecision 
of the data, the team members did not apply a precise, preexisting 
coding rule or conduct a content or measurement reliability analysis. 
Because the review process was exploratory rather than confirmatory, 
the results may be unique to our coding rules and source of data. 

We identified a number of "false-positive" text patterns that seemed 
related to media or advertising but, upon further review, appeared to 
measure spending for other purposes. For example, "COMMERCIAL" in 
reference to bank transactions, airlines, or insurance was not related 
to advertising. We also identified terms unrelated to advertising that 
included the text pattern "AD", such as "BREAD," "LETTERHEAD," 
"OVERHEAD," and "TOLL ROAD FEES." Similarly, we excluded expenditures 
described as "GOTV"--an acronym for efforts to "get out the vote" by 
canvassing or driving voters to the polls--because they were not 
television advertising. 

The same team members also reviewed random samples of expenditures 
initially coded as unrelated to media. We drew three independent, 
systematic random samples of expenditures without media-related terms, 
stratified by reporting date and candidate campaign committee. 
[Footnote 18] We selected one out of every 40 expenditures 
(approximately 2.5 percent) for a combined total of 131,574 
expenditures for the House and 20,481 expenditures for the Senate. We 
designed the samples to explore different measurement decisions using 
a representative group of expenditures, not to estimate statistical 
parameters. Reviewing these expenditures helped ensure that we 
assessed the possibility of false-negative misclassifications (i.e., 
expenditures incorrectly coded as not being media-related). For 
example, our initial text pattern did not code "PRINT BUYS" as being 
media-related. After our manual review, we included this exact pattern 
but not any description that contained "PRINT". Campaigns could use 
"PRINT" to describe print advertising, but they could also use it to 
describe spending on unrelated goods and services, such as "LETTERHEAD 
PRINTING" and "COMPUTER PRINTERS". 

Refining the Initial Coding Rule: 

We revised the initial list of text patterns based on our review of 
the initial measurement decisions, in order to avoid false-positives 
and false-negatives. The final list included four groups of patterns. 
The first group included all terms related to advertising and 
broadcast and print media. The second group included a subset of terms 
in the first group that were specifically related to broadcast 
advertising. The third and fourth groups included terms related to the 
use of consultants. Campaigns sometimes pay for advertising through 
consultants specializing in media, media-buying, and political 
strategy. We identified patterns that appeared to indicate the use of 
consultants, such as "CONSULT", in order to measure this type of 
spending. Accordingly, the third group included any terms related to 
consulting, and the fourth group included a subset of these terms that 
were related to media or advertising. The third and fourth groups both 
excluded terms that were clearly unrelated to media, such as "LEGAL" 
or "FUND-RAISING". Table 1 lists the text patterns that determined 
whether we classified an expenditure into each of the four groups. 

Table 1: Text Patterns Coded as Being Media-Related: 

Group of expenditures; Text pattern.
Media: 
Media 1: All media-related; "ADVERT".
"ADS ".
"AD".
"AD" with ("/" ":" "_" ".") in the subsequent character position 
allowed.
"ADV" with ("/" ":" "_" ".") in the subsequent character position 
allowed.
"ADVT " with ("/" ":" "_" ".") in the subsequent character position 
allowed.
"CABLE" but not ("SUBSCRIPT", "SERVICE", "GOTV", "TVL", "FAX", 
"DELIVERY", "CLIPPING", "COPIES", or "UTIL") and (amount of 
expenditure exceeds $300).
"TELEV" but not ("SUBSCRIPT", "SERVICE", "GOTV", "TVL", "FAX", 
"DELIVERY", "CLIPPING", "COPIES", or "UTIL") and (amount of 
expenditure exceeds $300).
"TV" but not ("SUBSCRIPT", "SERVICE", "GOTV", "TVL", "FAX", 
"DELIVERY", "CLIPPING", "COPIES", or "UTIL") and (amount of 
expenditure exceeds $300).
"BROADCAST" but not ("SUBSCRIPT", "SERVICE", "GOTV", "TVL", "FAX", 
"DELIVERY", "CLIPPING", "COPIES", or "UTIL") and (amount of 
expenditure exceeds $300).
"NEWSP" but not ("SUBSCRIPT", "SERVICE", "GOTV", "TVL", "FAX", 
"DELIVERY", "CLIPPING", "COPIES", or "UTIL") and (amount of 
expenditure exceeds $300).
"PRODUCTION" but not ("SUBSCRIPT", "SERVICE", "GOTV", "TVL", "FAX", 
"DELIVERY", "CLIPPING", "COPIES", or "UTIL") and (amount of 
expenditure exceeds $300).
"MEDIA".
"COMMERCIALS".
"AIRTIME".
"RADIO".
"INSERT".
"PRINT BUY".
"TIME BUY".
"AD BUY".
"AIRTIME BUY".
"VIDEO".
"AUDIO".
"FILM".
"SPOT". 

Media 2: Broadcast media; Terms for Media 1, but must also include any 
of the following terms related to television or radio: "CABLE", 
"TELEV" , "TV", "BROADCAST", "COMMERCIALS", "AIRTIME", "RADIO" , "TIME 
BUY", "VIDEO", "AUDIO", "FILM", or "SPOT". 

Consulting: 
Consulting 1: All consulting; "CONSULT" but not ("LEGAL", "FINAN", 
"ACCOUNT", "REAL ESTATE", "FUND-RAISING", "COMPLIANCE", "FIELD", 
"GOTV", "MAIL", "POLLING", "RESEARCH"). 

Consulting 2: Media consulting; "CONSULT" and; ("MEDIA", 
"COMMUNICATION", " AD " "ADV", "PRODUCTION", "TELEV", "TV", "MESSAGE", 
"ADVERT", "MESSAGE", "RADIO", or "VIDEO") but not; ("LEGAL", "FINAN", 
"ACCOUNT", "REAL ESTATE", "FUND-RAISING", "COMPLIANCE", "FIELD", 
"GOTV", "MAIL", "POLLING", "RESEARCH"). 

Source: GAO analysis of FEC data. 

Note: The table lists text patterns used to measure whether an 
itemized expenditure reported on FEC Form 3 paid for media or 
advertising. 

[End of table] 

In our manual review, we identified expenditures of less than $100 
that committees described as "CABLE TV" or "TV". These expenditures 
appeared to be office subscriptions, because a committee identified 
the recipient as a cable television service provider rather than a 
media production company. For example, recipients of recurring "CABLE 
TV" expenditures of $57 or $34.98 were "COMCAST" and "DISH NETWORK". 
To avoid these false-positives, we assumed that an expenditure was 
media-related if it matched several text patterns in the "media" sub-
groups and if the amount exceeded $300. For example, an expenditure 
described as "CABLE" was coded as media-related only if it exceeded 
$300. Because cable and newspaper subscriptions are less likely to 
exceed $300 than advertising purchases, this coding rule helps 
distinguish each type of expenditure. 

We used the four groups of text patterns in table 1 to create six 
partially overlapping categories of media spending, as shown in table 
2.[Footnote 19] 

Table 2: Categories of Media-Related Spending: 

Category: 1. All media-related, all consulting; 
Media 1: [Check]; 
Media 2: [Check]; 
Consulting 1: [Check]; 
Consulting 2: 

Category: 2. All media-related, media consulting; 
Media 1: [Check]; 
Media 2: [Empty]; 
Consulting 1: [Empty]; 
Consulting 2: [Check]. 

Category: 3. All media-related, no consulting; 
Media 1: [Check]; 
Media 2: [Empty]; 
Consulting 1: [Empty]; 
Consulting 2: [Empty]. 

Category: 4. Broadcast media, all consulting; 
Media 1: [Empty]; 
Media 2: [Check]; 
Consulting 1: [Check]; 
Consulting 2: [Empty]. 

Category: 5. Broadcast media, media consulting; 
Media 1: [Empty]; 
Media 2: [Check]; 
Consulting 1: [Empty]; 
Consulting 2: [Check]. 

Category: 6. Broadcast media, no consulting; 
Media 1: [Empty]; 
Media 2: [Check]; 
Consulting 1: [Empty]; 
Consulting 2: [Empty]. 

Source: GAO analysis. 

[End of table] 

We used multiple definitions to gauge the sensitivity of our results 
to alternative choices about which text patterns to include or 
exclude. Our estimates of media-related expenditures should decrease 
between definitions 1, 2, and 3 and between definitions 4, 5, and 6, 
as the scope of the definitions narrows. In the attached briefing, we 
excluded measures that used the "all consulting" text patterns, in 
order to focus on the types of consulting most relevant to media and 
advertising. 

Results: 

To develop estimates for each of the six categories in table 2, we 
coded each itemized expenditure for media content using the text 
entered on the "purpose of disbursement" line of FEC Form 3, Schedule 
B. We then aggregated the estimates to the level of campaign 
committees and two-year periods for which FEC had compiled and 
provided electronic databases. Specifically, we developed our 
estimates using data for House committees from 2003 through 2008 and 
for Senate committees from 2007 through 2008. We estimated media-
related spending for groups of committees at various levels of total 
itemized operating expenditure, which partially controls for campaign 
resources and candidate strength. Committees may vary in their use of 
media due to differences in the size of their budgets. 

Use of Any Media: 

Thirty-five to 63 percent of House committees reported any itemized 
expenditure with a media-related purpose in the 2004, 2006, and 2008 
election cycles across our six measures. The use of any media 
increased from 54 percent of committees in 2004 to 58 percent in 2008, 
using the "all media-related, media consulting" measure. The change 
over time ranged from 0 to 5 percentage points using the five other 
measures. Our measurement decisions cause our estimates to vary by 23 
to 28 percentage points, depending on the period, which reflects the 
imprecision in defining media use with the descriptors coded in the 
FEC data. 

Senate committees were similarly likely to report any itemized 
expenditure with a media-related purpose. The proportion ranged from 
34 percent to 63 percent in the 2007 through 2008 time period. Our 
measurement decisions account for all of this variation, due to the 
fact that the electronically available data we analyzed were for one 
two-year period. 

Both House and Senate committees were more likely to report at least 
one itemized media-related expenditure as their total itemized 
operating expenditure increased. In the 2004 election cycle, for 
example, 36 percent of House committees with less than $400,000 in 
total itemized operating expenditure reported any expenditure that 
matched the "all media-related, media consulting" text pattern, as 
compared to 100 percent of House committees with more than $1 million 
in total itemized operating expenditure. These proportions for Senate 
committees were 38 percent and 99 percent, respectively, in 2007 
through 2008. 

Total Spending on Media: 

The majority of reported expenditures by House and Senate committees 
do not indicate purchasing media-related products or services. For 
House committees, we estimate that from 8 to 41 percent of the total 
itemized operating expenditures reported in the 2004, 2006, and 2008 
election cycles, across the categories, were media-related. For Senate 
committees, our estimated proportions range from 6 percent to 46 
percent in 2007 through 2008, as shown in table 3.[Footnote 10] 

Table 3: Total Media-Related Expenditures by Principal House and 
Senate Campaign Committees, and Media-Related Expenditures as a 
Percentage of Total Itemized Operating Expenditures, by Time Period: 

Category: All Media, All Consulting; Total; 
House: 2003-2004: $225,433,212; 
House: 2005-2006: $327,778,907; 
House: 2007-2008: $341,277,727; 
Senate: 2007-2008: $219,664,454. 

Category: All Media, All Consulting; Percentage; 
House: 2003-2004: 37.1; 
House: 2005-2006: 41.1; 
House: 2007-2008: 38.6; 
Senate: 2007-2008: 46.1; 

Category: All Media, Media Consulting; Total; 
House: 2003-2004: $200,352,204; 
House: 2005-2006: $299,330,670; 
House: 2007-2008: $314,973,379; 
Senate: 2007-2008: $207,469,060. 

Category: All Media, Media Consulting; Percentage; 
House: 2003-2004: 32.9; 
House: 2005-2006: 37.6; 
House: 2007-2008: 35.7; 
Senate: 2007-2008: 43.6. 

Category: All Media, No Consulting; Total; 
House: 2003-2004: $191,846,842; 
House: 2005-2006: $290,903,898; 
House: 2007-2008: $300,238,875; 
Senate: 2007-2008: $202,614,409. 

Category: All Media, No Consulting; Percentage; 
House: 2003-2004: 31.5; 
House: 2005-2006: 36.5; 
House: 2007-2008: 34.0; 
Senate: 2007-2008: 42.5. 

Category: Broadcast Media, All Consulting; Total; 
House: 2003-2004: $84,367,304; 
House: 2005-2006: $120,370,207; 
House: 2007-2008: $128,436,272; 
Senate: 2007-2008: $46,471,134. 

Category: Broadcast Media, All Consulting; Percentage; 
House: 2003-2004: 13.9; 
House: 2005-2006: 15.1; 
House: 2007-2008: 14.5; 
Senate: 2007-2008: 9.8. 

Category: Broadcast Media, Media Consulting; Total; 
House: 2003-2004: $59,174,871; 
House: 2005-2006: $91,908,992; 
House: 2007-2008: $102,129,840; 
Senate: 2007-2008: $34,257,994. 

Category: Broadcast Media, Media Consulting; Percentage; 
House: 2003-2004: 9.7; 
House: 2005-2006: 11.5; 
House: 2007-2008: 11.6; 
Senate: 2007-2008: 7.2. 

Category: Broadcast Media, No Consulting; Total; 
House: 2003-2004: $50,780,934; 
House: 2005-2006: $83,495,198; 
House: 2007-2008: $87,397,421; 
Senate: 2007-2008: $29,421,089. 

Category: Broadcast Media, No Consulting; Percentage; 
House: 2003-2004: 8.4; 
House: 2005-2006: 10.5; 
House: 2007-2008: 9.9; 
Senate: 2007-2008: 6.2. 

Source: GAO analysis of FEC Form 3 data. 

Note: Expenditure estimates do not sum because the categories of media-
related spending are not mutually exclusive. The total itemized 
operating expenditures, by time period, for House are: $608,260,574 
for 2003-2004; $796,682,472 for 2005-2006; and $883,428,651 for 2007-
2008; and for the Senate are $476,417,293 for 2007-2008. 

[End of table] 

Media-related spending by House committees did not increase by a large 
amount between the 2004 and 2008 election cycles. Based on our "all 
media-related, media consulting" measure, the proportion of total 
itemized operating expenditures on media was about 33 percent in 2004, 
38 percent in 2006, and 36 percent in 2008--an increase of 3 
percentage points over the six-year period. The change over time 
varies from 1 to 2 percentage points, using the five alternative 
measures. 

Our estimates change by larger amounts when we use different 
definitions of media (e.g., all media-related versus broadcast media) 
than when we use different definitions of consulting (e.g., all 
consulting versus media consulting) to code the data. For House 
committees, our estimates decrease by 23 to 26 percentage points in 
the three election cycles, from a maximum of 41 percent in 2006 to a 
minimum of 8 percent in 2004, when we limit our definition of media to 
text patterns that include broadcast media terms, without changing the 
definition of consulting. The same estimates for Senate committees 
decrease by 36 to 37 percentage points, from a maximum of 46 
percentage points to a minimum of 6 percentage points. In contrast, 
our estimates vary by 4 to 6 percentage points for the House and by 3 
to 4 percentage points for the Senate when we change the definition of 
consulting but not the definition of media. 

Media-related expenditures represent a larger proportion of total 
itemized operating expenditure for committees that spent more overall. 
Among House committees with more than $1 million in total itemized 
operating expenditure, from 41 to 49 percent of the total expenditure 
was for media-related purposes, based on our three "all media-related" 
measures and all three election cycles. By comparison, the same 
proportions among House committees with less than $400,000 in total 
itemized operating expenditure ranged from 15 percent to 24 percent. 
For Senate committees, these proportions ranged from 41 percent to 45 
percent among those with more than $1 million in total itemized 
operating expenditure, as compared to 15 percent to 21 percent among 
those with less than $400,000.[Footnote 21] When using our "broadcast 
media, media consulting" measure, the differences between the groups 
spending the least and the most were 5 percent to 9 percent for the 
House and 3 percent to 8 percent for the Senate. 

Variation in Media-Related Spending Across Committees: 

The proportion of itemized operating expenditures spent on media by 
each committee varied widely across committees. The average proportion 
of each committee's total itemized operating expenditure spent for 
media-related purposes varied from 5 percent to 24 percent for House 
committees and from 3 percent to 19 percent for Senate committees, 
depending on the measure and period. The median proportion varied from 
0 percent to 17 percent for House committees and from 0 percent to 7 
percent for Senate committees, as shown in table 4. 

Table 4: Mean and Median Proportion of Total Itemized Operating 
Expenditures Spent on Media-Related Purposes for Each Principal House 
and Senate Campaign Committee, by Time Period: 

Category: All Media, All Consulting; Median; 
House: 2003-2004: 17%; 
House: 2005-2006: 17%; 
House: 2007-2008: 14%; 
Senate: 2007-2008: 7%. 

Category: All Media, All Consulting; Mean; 
House: 2003-2004: 24%; 
House: 2005-2006: 24%; 
House: 2007-2008: 23%; 
Senate: 2007-2008: 19%. 

Category: All Media, Media Consulting; Median; 
House: 2003-2004: 9%; 
House: 2005-2006: 7%; 
House: 2007-2008: 7%; 
Senate: 2007-2008: 1%. 

Category: All Media, Media Consulting; Mean; 
House: 2003-2004: 19%; 
House: 2005-2006: 19%; 
House: 2007-2008: 18%; 
Senate: 2007-2008: 15%. 

Category: All Media, No Consulting; Median; 
House: 2003-2004: 7%; 
House: 2005-2006: 7%; 
House: 2007-2008: 5%; 
Senate: 2007-2008: 1%. 

Category: All Media, No Consulting; Mean; 
House: 2003-2004: 18%; 
House: 2005-2006: 19%; 
House: 2007-2008: 18%; 
Senate: 2007-2008: 14%. 

Category: Broadcast Media, All Consulting; Median; 
House: 2003-2004: 5%; 
House: 2005-2006: 3%; 
House: 2007-2008: 3%; 
Senate: 2007-2008: 2%. 

Category: Broadcast Media, All Consulting; Mean; 
House: 2003-2004: 12%; 
House: 2005-2006: 11%; 
House: 2007-2008: 10%; 
Senate: 2007-2008: 8%. 

Category: Broadcast Media, Media Consulting; Median; 
House: 2003-2004: 0%; 
House: 2005-2006: 0%; 
House: 2007-2008: 0%; 
Senate: 2007-2008: 0%. 

Category: Broadcast Media, Media Consulting; Mean; 
House: 2003-2004: 7%; 
House: 2005-2006: 7%; 
House: 2007-2008: 6%; 
Senate: 2007-2008: 5%. 

Category: Broadcast Media, No Consulting; Median; 
House: 2003-2004: 0%; 
House: 2005-2006: 0%; 
House: 2007-2008: 0%; 
Senate: 2007-2008: 0%. 

Category: Broadcast Media, No Consulting; Mean; 
House: 2003-2004: 6%; 
House: 2005-2006: 6%; 
House: 2007-2008: 5%; 
Senate: 2007-2008: 3%. 

Source: GAO analysis of FEC Form 3 data. 

[End of table] 

The lower proportions spent for media-related purposes by each 
committee, as compared to the proportion spent by all committees in 
the same time period, suggests that the distribution of media spending 
is skewed toward a small number of committees that spend a larger 
amount of money on media. In the 2004 election cycle, for example, 630 
out of the 1,225 House committees with any itemized operating 
expenditures (51 percent) spent between 0 percent and 10 percent of 
that expenditure for media-related purposes, using the "all media-
related, media consulting" measure. For the Senate, in 2007 through 
2008, the proportion of such Senate committees in the 0 percent to 10 
percent range was 66 percent. Nevertheless, a small number of 
committees spent larger sums. In 2004 election cycle, 114 of the 1,672 
House committees (7 percent) reported at least $600,000 in itemized 
media expenditures. These results suggest that the majority of 
committees spend relatively smaller sums on media, measured in dollars 
or as a proportion of their budgets, but also that a small number of 
committees account for a large proportion of the total spending. 

[End of Enclosure II} 

Footnotes: 

[1] S. Rep. No. 110-129, at 72 (2007). 

[2] S. Rep. No. 110-129, at 72 (2007). 

[3] Under the Federal Election Campaign Act of 1971 (Pub. L. No. 92-
225, 86 Stat. 3 (1972)), as amended, and FEC implementing regulations, 
an individual becomes a candidate when a campaign exceeds $5,000 in 
either contributions or expenditures and is required to file a 
Statement of Candidacy (FEC Form 2) designating a principal campaign 
committee to receive contributions and make expenditures on the 
candidate’s behalf. The committee is required to file reports of 
receipts and disbursements in accordance with the schedule established 
in the act (FEC Form 3). 

[4] An expenditure includes any purchase, payment, distribution, loan, 
advance, deposit or gift of money or anything of value made to 
influence a federal election. Operating expenditures include day-to-
day expenses, such as staff salaries, rent, travel, advertising, 
telephones, office supplies and equipment, and fundraising. 

[5] Dollar values presented are in current dollar. When the values are 
adjusted for inflation, the same pattern over time exists. 

[6] To standardize the reporting period for purposes of this review, 
we defined House election cycle as a 2-year calendar period (e.g., 
January 1, 2005, through December 31, 2006). In contrast, FEC defines 
a House election cycle as the period beginning on the day after the 
date of the most recent election and ending on the date of the next 
election. Since one-third of the Senate, referred to as a class, 
stands for election every 2 years, we reported Senate expenditure data 
by 2-year calendar period. 

[7] According to a CMAG official, CMAG data cover media markets for 
all House and Senate campaigns as of the 2006 election cycle. 

[8] Under federal law, broadcast licensees are required to maintain 
and make available for public inspection records of, among other 
things, broadcast time purchase requests made by or on behalf of a 
legally qualified candidate for public office. 

[9] According to FEC, FEC maintains information, disclosed by House 
and Senate principal campaign committees, that provides the amount, 
date, purpose, payee and payee’s address for every itemized 
expenditure. Although not compiled in comprehensive electronic 
databases, FEC has this information available on its web site for 
House committees beginning in May 1996, and for Senate committees 
beginning in May 15, 2000. Earlier House and Senate information is 
available from the FEC, and Senate information is also available from 
the Office of the Secretary of the Senate. 

[10] In a December 17, 2009, letter to the House and Senate 
Appropriations Committees in response to the Explanatory Statement for 
the Omnibus Appropriations Act, 2009, FEC described a method for 
developing current media expenditure information for House and Senate 
campaigns using FEC data. 

[11] Itemized operating expenditures are not equal to total operating 
expenditures, as itemized operating expenditures may not include 
expenditures of less than $200. 

[12] Operating expenditures include day-to-day expenses, such as staff 
salaries, rent, travel, advertising, telephones, office supplies and 
equipment, and fundraising. 

[13] The Federal Election Campaign Act of 1971 (Pub. L. No. 92-225, 86 
Stat. 3 (1972)), as amended. 

[14] Under the Federal Election Campaign Act of 1971 and FEC 
implementing regulations, an individual becomes a candidate when a 
campaign exceeds $5,000 in either contributions or expenditures and is 
required to file a Statement of Candidacy (FEC Form 2) designating a 
principal campaign committee to receive contributions and make 
expenditures on the candidate's behalf. The committee is required to 
file reports of receipts and disbursements in accordance with the 
schedule established in the act (FEC Form 3). 

[15] According to FEC, FEC maintains information, disclosed by House 
and Senate principal campaign committees, that provides the amount, 
date, purpose, payee and payee's address for every itemized 
expenditure. Although not compiled in comprehensive electronic 
databases, FEC has this information available on its web site for 
House committees beginning in May 1996, and for Senate committees 
beginning in May 15, 2000. Earlier House and Senate information is 
available from the FEC, and Senate information is also available from 
the Office of the Secretary of the Senate. 

[16] FEC provides standardized numeric codes that committees may use 
to describe their itemized expenditures, but does not require them to 
do so. We could not use these codes to analyze the expenditure data, 
particularly the "004" code that committees may use to indicate an 
expenditure on "advertising," because committees do not use these 
codes consistently. 

[17] In a December 17, 2009, letter to the House and Senate 
Appropriations Committees in response to the Explanatory Statement for 
the Omnibus Appropriations Act, 2009, FEC described a method for 
developing current media expenditure information for House and Senate 
campaigns using FEC data. 

[18] Stratified sampling, or sampling that draws sample members from 
within groups, increased the chance that the expenditures included a 
representative list of purposes used by each candidate, in each 
reporting period. 

[19] We implemented the coding rules using a SAS statistical analysis 
program and PERL syntax for regular text expressions. 

[20] This variation may reflect differences in each committee's stage 
of the six-year election cycle. Because the electronic data we 
analyzed were for one two-year period, we were unable to analyze a 
complete cycle. 

[21] Because the electronically available Senate committee data we 
analyzed were for one two-year period and not a complete, six-year 
election cycle, this association may reflect differences in the use of 
media at different stages of the election cycle. 

[End of section] 

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