National Security Advisor Jake Sullivan mocked critics of him and the Biden administration at a September 21 press conference at the White House: “‘Oh, Jake doesn’t know how much assistance we’ve provided.’”

“This is just off the top of my head,” Sullivan continued, “So you can confirm these numbers, but roughly $47 billion in military assistance between PDA [Presidential Drawdown Authority] and USAI [Ukraine Security Assistance Initiative]; roughly $1 to $1.5 billion per month in direct budget support that is sent not directly to Ukraine, but to the World Bank so that the World Bank can ensure every amount—all of the amounts of that aid, those dollars are being appropriately spent; and then in the range of 10-or-so billion dollars being spent for a range of humanitarian, energy, and other purposes to ensure that the basic livelihoods of Ukrainians, their humanitarian needs, basic food security needs, and otherwise are being taken care of.”

Sullivan clarified it was “not a precise estimate,” but assured the American public that “I spend my days making sure that we know that every dollar that we’re spending is being accounted for effectively.” The National Security Advisor intended to impress, but he and his estimate fell short.

Sullivan’s estimate amounted to $79.9 billion, a full $31.1 billion short of the Office of Management and Budget (OMB) estimate of $111 billion for Ukraine appropriations provided to Congress at the time.

OMB’s $111 billion Ukraine appropriations estimate, however, is also likely undervaluing the true amount the United States has set aside for Ukraine to the tune of billions. This potentially massive undervaluation is due to an undisclosed amount of base appropriations that has been funneled to Ukraine, as well as an unknown amount of appropriations transfers and reprogramming, figures that the administration, under pressure from Congress, has either been unwilling or unable to provide up to this point.

Is this a case of the Biden administration willfully withholding information from the people’s representatives? Or is reality even more concerning: that no one knows the true amount of taxpayer dollars America has given to Ukraine?

The battle between the legislative and executive branch over Ukraine funding transparency has intensified over the course of this year. 

On January 19, a letter signed by 37 members of Congress across both chambers addressed to OMB Director Shalanda Young requested, “a full crosscutting report on U.S. government-wide expenditures for Ukraine and ‘countries impacted by the situation in Ukraine’ since February 24, 2022.”

At the time, an estimated $114 billion had been appropriated to support Ukraine and “countries impacted by the situation in Ukraine” across four supplemental funding bills, which the members of Congress added, “amount to arguably the fourth-largest discretionary appropriations bill.”

While law requires the administration to report to Congress “describing the United States security assistance provided to Ukraine since February 24, 2022...including a comprehensive list of defense articles and services provided to Ukraine and the associated authority and funding used to provide such articles and services,” such reports do not provide a complete and comprehensive total of the aid funneled to Zelensky’s government. The $114 billion estimate cited by legislators, they point out, “does not include reprogrammings, and transfers, for which the administration has asked for additional authorities in each of its four supplemental requests.”

When Congress appropriates funds, it often provides executive agencies transfer and reprogramming authority to make budgetary adjustments in the execution of the allotted appropriations. Transfer authority relates to an agency’s ability to move funds from one appropriation to another; reprogramming, meanwhile, is the ability to reposition funds within the same appropriations account toward a different purpose.

The executive branch’s ability to transfer funds can be limited by Congress in appropriations legislation. Congress can choose what agencies the transfer authority is granted to or withheld from, set a cap on the amount that can be transferred, specify circumstances in which an agency can transfer funds, or implement a series of other controls. Reprogramming generally comes with fewer Congressionally-stipulated controls; nevertheless, Congress can choose to restrict or prohibit an agency's ability to shift funds within an appropriations account if it chooses.

For the DOD, for example, Congress provided the agency the authority to transfer 43 percent of the funds provided in the four supplemental funding bills between certain accounts. Congress also gave DOD a wide berth for reprogramming. Between May 1 and December 8, 2022, the Congressional Research Service found that almost $12 billion of DOD supplemental funding had been reprogrammed.

Congress can also require agencies to notify the legislature when it is using the transfer or reprogramming authority to redirect funds. This is more often the case with the transfer authority because it cuts across appropriations accounts. Regardless, reprogramming notification is also typically required when the reprogrammed funds exceed a congressional notification cap.

Furthermore, when an administration makes supplemental funding requests, it can suggest guidelines to manage the transfer and reprogramming authority. The Biden administration’s March 2 supplemental request, which Congress later passed on March 15, stated, “We are requesting the flexibility to utilize all of the U.S. Government’s tools to respond to this situation by requesting transfers between accounts for the purposes of helping the Ukrainian people and countering Russian aggression.” 

While the administration asked for $5 billion for Department of State, Foreign Operations, and Related Programs (SFOPS) appropriations accounts, Congress greenlit $6.8 billion for SFOPS along with new transfer and reprogramming authorities for FY22 and prior-year funding in the $13.6 billion total package. While the data is more well-known for the DOD, how exactly the State Department and USAID, for example, have employed transfer and reprogramming powers to increase its support for Ukraine remains unclear.

The aforementioned letter from 37 members of Congress also brought up concerns from Department of Defense Inspectors General about the DOD’s ability to disperse appropriated funds accurately and effectively. “In particular, both the July 8 advisory and the September 19 advisory raise the issue that the DOD’s use of systems unable to interface with its budgetary management software may be a potential source for reporting errors,” the letter stated.

Therefore, to receive a holistic picture of the U.S. government’s support for Ukraine, the legislators wrote in the January 19 letter that “the full crosscutting report on U.S. government-wide expenditures for Ukraine…should include a full accounting of total budget authority in this area by appropriations account after transfers and reprogrammings, as well as obligations, apportionments, and outlays for each account. The report should also include a list of countries the administration considers ‘impacted by the situation in Ukraine’ and an accounting of budgetary resources the administration intends to provide to each of these countries in response to the situation in Ukraine including obligations, apportionments, and outlays.”

While the letter asked for a response by February 7, 2023, OMB did not send a response until September 11—more than seven months past deadline. Their response was underwhelming.

“As President Biden has made clear, the United States will not waver in our commitment to the Ukrainian people as they fight for their freedom and independence,” Young wrote in her response. “As for your request for additional information from the Administration, we agree that transparency and accountability are paramount to ensuring American taxpayers can be confident in their assistance in helping the Ukrainians fight for their country against Russia’s aggression.”

Young directed legislators to a public website, which she claims to have “all of OMB’s apportionment data related to Ukraine.” Like any government website that deals with grants and appropriations, it’s poorly built and difficult to navigate without some expertise. The documents themselves are anything but straightforward accounts of when and where the money went. It’s hard to think it is anything but an intentional effort to obscure how the government actually spends the average citizen’s money.

Rather than providing a “full crosscutting report,” OMB attached a table breaking down only the supplementally appropriated funds provided and then obligated or executed for Ukraine across a range of agencies and programs.

The OMB spreadsheet claims security assistance supplemental funding for Ukraine amounts to $49.595 billion, of which $45.663 billion has been obligated or executed. Within that security assistance total, according to the OMB, the DOD has received $43.93 billion in supplemental funding, of which 40.078 billion, or 91 percent, has been obligated or executed, USAI has received $18 billion in supplemental funds, of which $17.7 has been obligated or executed, and the State Department and USAID has received $5.665 billion, of which the Biden administration has obligated or executed $5.585 billion. An additional $18.38 billion in security assistance supplemental funding has gone to DOD military, intelligence, and other defense support. The Biden administration has obligated $14.248 billion of that total. The spreadsheet explains that the “DOD received multi-year Procurement and Research, Development, Test and Evaluation funding in this category, and no-year funding to support the defense industrial base's efforts to increase capacity in response to the situation in Ukraine.”

Beyond security assistance, supplemental funding has allocated $28.5 billion in economic assistance, all of which has been obligated or executed, $13.218 in humanitarian support, 89 percent of which has been doled out, and a billion and change for “other,” 85 percent of which has been executed or obligated. Most of the funding in the other three buckets have been directed towards the State Department or USAID. For economic assistance, more than 98 percent of the funds were directed towards the State Department and USAID, for humanitarian support, 73 percent, and for “other,” 58 percent.

At the bottom of the OMB spreadsheet, the OMB notes an “authority not included in the above.” That authority is the Presidential Drawdown Authority (PDA), a mechanism at the President’s disposal to provide material aid in short order, drawing from pre-existing American stockpiles. Prior to Russia’s invasion of Ukraine, the PDA was capped by Congress at $100 million per fiscal year. In the May 2022 supplemental appropriations bill for Ukraine, however, Congress jacked the $100 million cap up to $11 billion for FY 2022, and increased it again to $14.5 billion for FY23 in December 2022. Over the course of the war in Ukraine, the Biden administration has made use of the PDA on nearly 50 separate occasions to provide tanks, HIMARS, drones, howitzers, Javelins, Stingers, and loads of other equipment, ammunition, and training. The OMB spreadsheet claims that $23.225 billion worth of aid has been sent to Ukraine using the PDA.

In June, however, the Pentagon announced that over the past two years it had overvalued the weapons it had sent to Ukraine by $6.2 billion—freeing up more PDA funding for providing Ukraine arms and equipment. The overvaluation was split between FY22 and FY23 to the tune of $2.6 billion and $3.6 billion respectively.

The OMB spreadsheet notes that the September spreadsheet (sent nearly three months after the Pentagon announced the accounting error), “does not reflect DOD's recent PDA revaluations, which identified $6.2 billion in ‘freed-up’ authority.” 

The accounting error came at a relatively convenient time for the Biden administration. According to a CRS report, the Biden administration used the PDA to provide Ukraine with nearly $15.5 billion worth of U.S. military aid in FY23 without accounting for the Pentagon’s overvaluation. Up until the Pentagon announced the accounting error, the Biden administration had already given Ukraine $13.3 billion in aid via the PDA in FY23. By the end of July, the Biden administration would have hit the $14.5 billion PDA cap if not for their realization that the Pentagon had overvalued previous PDA packages.

The OMB’s failure to account for the Pentagon’s revised PDA package valuations raises critical questions about U.S. stockpiles. There has been growing concern in Washington over the impact the Biden administration’s support for Ukraine is having on U.S. stockpiles. To assuage concerns, however, the Biden administration and other supporters of Ukraine aid have assured the public that supplemental Ukraine funding directed toward stockpiles is sufficient to maintain readiness. The Biden administration’s most recent supplemental funding request on October 20, however, suggests the Biden administration, now faced with another crisis unfolding in the Middle East, is growing increasingly concerned with the strain PDA packages are placing on U.S. stockpiles. While it is seeking only $7 billion in PDA capacity, it is seeking over $20 billion in funding to replenish a variety of stockpiles.

Replenishing U.S. stockpiles is a necessary and worthwhile investment. Yet the problem cannot be solved by simply throwing large sums of money at it. That’s only the start. Replenishing stockpiles is a several-year process, especially as currently hampered by America’s diminished defense industrial base. Reestablishing, restarting, and rejuvenating production lines for U.S. weaponry is easier said than done. Although the U.S. has had some success in doing this, to take one example, it could still take upwards of six years for the U.S. to replenish its stockpiles of 155mm shells used in Howitzers to pre-Ukraine war levels.

While supplemental funding makes up a considerable bulk of the aid the U.S. has provided to Ukraine, supplemental funding is precisely what it purports to be: provided in addition to funds already or previously available. By responding simply with supplemental funding data, the OMB does not address the base funding that pre-exists supplemental funding packages. The OMB admits as much in a note on the table: “DOD has fully committed the $300 million in USAI funding provided through regular FY 2022 appropriations, not included in this total. DOD has not yet committed the $300 million in USAI funding provided through regular FY 2023 appropriations, also not included in this total.” 

The $600 million appropriated for the USAI across FY 2022 and 2023 is a component of the base, but is by no means all of it. Across appropriation accounts for relevant agencies, there are a host of authorities, mechanisms, and programs that a presidential administration has at its disposal to provide aid to Ukraine, whether its equipment, training, or humanitarian and economic support. What Congress is trying to figure out now, with little help from the Biden administration, is what proportion of base funding has actually been used for Ukraine assistance unbeknownst to the American public.

The Biden administration's failures in providing an accurate, comprehensive presentation for America’s support for Ukraine led Sens. J.D. Vance, Rand Paul, Mike Lee, and Reps. Dan Bishop, Matt Gaetz, and Byron Donalds, among other legislators, to conclude that the OMB was “nonresponsive to our inquiry,” in a letter dated September 28.

The OMB’s spreadsheet, the legislators claimed, “does not account for base appropriations,” failed to explain why the $6.2 billion correction in PDA valuation was not included, refuses to address transfers and reprogrammings, and does not elucidate what countries the administration considered to be “impacted by the situation in Ukraine.”

As for the website Young directed legislators to, the signatories said that “while Ukraine-related spending may be reflected in figures published there, the website does not disaggregate Ukraine-related funding for all accounts.”

“It is not possible to recreate even the incomplete spreadsheet OMB provided using only this website’s data,” the signatories wrote.

“We believe we lack key information about the U.S. government’s Ukraine-related expenditures,” the group of legislators concluded. “Perhaps most notably, we remain without an accurate figure for how much the United States has spent to date in total on this conflict. If OMB’s spreadsheet is to be relied on to produce such a figure—and we believe it cannot be—it is around $111 billion. It would appear likely that the data you have yet to provide would raise this figure by an indeterminate magnitude.”

Senator J.D. Vance of Ohio, one of the primary legislators pushing for accountability and transparency vis-à-vis Ukraine funding, told The American Conservative that “the Biden White House has spent months hiding the ball in regard to the total amount of aid we’ve sent to Ukraine.”

A source familiar with the matter on Capitol Hill told TAC that the real dollar amount of U.S. aid to Ukraine “could be anywhere from 10 extra billion to 30 extra billion” over the OMB’s estimate. “Realistically, we just don't know because there’s so many unanswered questions.”

“Simultaneously, they expect Congress to approve an additional $60 billion to Ukraine before we receive basic answers to our very straightforward questions on this matter,” Vance told TAC. “It’s a slap in the face to the American people who are footing the bill for all this in the form of their hard-earned tax dollars.”

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Representative Dan Bishop of North Carolina shares in Vance’s frustration. “It’s unacceptable that the official figures from the Biden administration aren’t fully accurate and complete—the number is likely significantly higher than what has been publicly stated,” Bishop claimed. “Americans are bankrolling this conflict, and they deserve to know the full details of how much of their money has been spent and where that is going. Anything less is untenable.”

Thankfully, Congress seems determined to get some answers. An October 30 letter from House Budget Committee Chair Jodey Arrington and Chair of the Oversight Task Force Jack Bergman requested a full report no later than November 20, and for Young to schedule a time to testify before the committee. “Failure to provide forthcoming and transparent answers to the Committee’s questions and failure to respond to the request for testimony could necessitate additional action,” Arrington and Bergman wrote, “including resorting to compulsory process, to obtain the required information.”

Until OMB responds or Young is hauled to testify before Congress, the American people won’t fully know just how deep Uncle Sam has been reaching into his—and their—pockets for Zelensky.