oversight

The Recertification Process for Foreign Schools Needs to be Improved.

Published by the Department of Education, Office of Inspector General on 2000-09-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                THE RECERTIFICATION PROCESS
          FOR FOREIGN SCHOOLS NEEDS TO BE IMPROVED




                                  FINAL AUDIT REPORT




                           Audit Control Number ED-OIG/A01-90005
                                       September 2000



Our mission is to promote the efficient                       U.S. Department of Education
and effective use of taxpayer dollars                           Office of Inspector General
in support of American education.                                             Boston, MA
                                              NOTICE

Statements that financial and/or managerial practices need improvement or recommendations that costs
questioned be refunded or unsupported costs be adequately supported, as well as other conclusions
and recommendations in this report, represent the opinions of the Office of Inspector General.
Determinations on these matters will be made by appropriate U.S. Department of Education officials.
In accordance with the Freedom of Information Act (5 U.S.C. §552), reports issued by the Office of
Inspector General are available, if requested, to members of the press and general public to the extent
information contained therein is not subject to exemptions in the Act.
                                             Table of Contents


Executive Summary ................................................................................................1

Audit Results ...........................................................................................................3

Finding: Ineffective Recertification ......................................................................3

          Recommendations .......................................................................................5
          Auditee Response .......................................................................................5
         OIG Reply .....................................................................................................6

Other Matters .........................................................................................................8

Background .............................................................................................................9

Audit Objectives......................................................................................................9

Methodology and Scope .........................................................................................9

Management Controls ..........................................................................................10


Audit Test Results ................................................................................. Appendix A

Auditee Response ................................................................................... Attachment
                                        Executive Summary
The recertification process for foreign schools’ Title IV, Federal Family Education Loan (FFEL)
program participation has been ineffective because Student Financial Assistance (SFA) has not
performed recertifications in a timely manner and has not based its recertification decisions on
information required by the Higher Education Act. Specifically, SFA did not enforce statutory
requirements for compliance audits from foreign schools and foreign medical school eligibility ratios. As
a result, $121,233,276 in Title IV FFEL funds were potentially at risk at improperly recertified foreign
schools. The risk is that ineligible institutions and/or students have received funds to which they were
not entitled.

The Higher Education Act (HEA) amendments of 1992, enacted July 23, 1992, provided that
institutional eligibility shall expire “not later than five years after such date of enactment.” As a result,
SFA needed to recertify all participating institutions by July 23, 1997.

SFA properly identified the universe of foreign schools requiring recertification. However, our testing of
SFA’s recertification effort, which included 50 foreign schools that represented 84 percent of the
foreign school FFEL volume, found that SFA did not base its recertification decisions on information
required by the HEA. Included in these 50 foreign schools are 38 active high loan volume schools.
SFA has made recertification decisions for 31 of the 38 schools; however, 22 of the 31 are missing
compliance audits. Included in our testing were medical schools required to provide medical
examination pass rate information and citizenship data. We found 79 percent of these medical schools
failed to provide medical exam pass rate data. In addition, 12 percent failed to provide citizenship data
or provided data that deemed them ineligible.

We recommend that the Chief Operating Officer for Student Financial Assistance:

1. Obtain and review all required documentation before making recertification decisions;
2. Implement controls to ensure required documentation is obtained and reviewed prior to making
   recertification decisions;
3. Establish definitive timeframes to receive the required information and if the school does not respond
   by the set time, take appropriate action(s) to terminate the school from participation in the FFEL
   programs; and
4. Document the basis for the statement that statutory requirements are not enforceable and report the
   findings to the Congress for consideration of changing the statute.


Auditee Response

SFA concurred with most of the OIG’s finding and recommendations. However, SFA did not agree to
implement all of the recommendations. SFA believes current HEA requirements for foreign institutions
are extremely difficult, if not virtually impossible, to enforce. The two provisions that caused the most
problems are the compliance audit and medical school pass rate requirements. SFA also stated that
schools were unaware of, or confused regarding these requirements. The specifics of SFA’s response
are summarized following the finding and a complete copy is included as an attachment to this report.
OIG Reply

We reviewed SFA’s comments but our findings and recommendations remain unchanged. SFA
provided no basis to authorize certain schools to participate in the FFEL program without meeting the
requirements of the HEA, or to authorize SFA to substitute reliance on other information to determine
eligibility.

SFA provided additional documentation for schools included in our testing. We have made appropriate
changes to the report to reflect this data.
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    Ineffective Recertification


SFA did not recertify foreign schools for Title IV FFEL program participation in a timely manner and
improperly recertified foreign schools because it did not base its recertification decisions on information
required by the HEA. Specifically, SFA did not enforce requirements for compliance audits and foreign
medical school eligibility ratios. As a result, $121,233,276 in Title IV FFEL funds were potentially at
risk at improperly recertified foreign schools. The risk is that ineligible institutions and/or students have
received funds to which they were not entitled.

The HEA provides that institutional eligibility shall expire not more than five years after the date of
enactment and Section 487(c)(A)(1)(i) states the Secretary shall prescribe regulations to provide for “.
. . a compliance audit . . .with regard to any funds obtained by it [institution]. . . .”

HEA Section 102 (a)(2)(A) also states foreign medical schools must meet the following criteria:
       “. . . at least 60 percent of those enrolled in, and at least 60 percent of the graduates of,
the graduate medical school . . . were not persons described in section 484(a)(5) [U.S. citizens or
permanent residents] in the year preceding the year for which the student is seeking a loan under
part B of this title; and
       (II) at least 60 percent of the individuals who were students or graduates of the graduate
medical school . . . taking the examinations administered by the Educational Commission for
Foreign Medical Graduates [ECFMG] received a passing score in the year preceding the year for
which a student is seeking a loan under part B of title IV; or
       (ii) the institution has a clinical training program that was approved by a State as of
January 1, 1992. . . .”

SFA must ensure institutions meet the statutory requirements for administrative capability and financial
responsibility for recertification. Accordingly, SFA should review financial statements, compliance
audits, program review reports, recertification applications and other relevant documentation. Some of
the relevant specific review items should include foreign medical school ratios, significant findings and
liabilities, accreditation, governmental approval, complaints against the institution, and default rates.

Our testing of 50 foreign school files1, representing 84 percent of the FFEL funding for the period July
1, 1996 through July 30, 1998, found that SFA’s recertification effort has been untimely and ineffective.
 Based on our review of 50 school files, SFA has made 35 recertification decisions; 9 schools have

1
 Using National Student Loan Data System (NSLDS) data, we identified all foreign schools receiving FFEL funds
during the period 7/1/96 – 6/30/98. From this universe we judgmentally selected 43 schools, representing
approximately 84 percent of the FFEL funds for all foreign schools for that time period, and randomly selected seven
schools from the remaining universe.
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continued on month to month provisional status (considered eligible until a recertification decision is
made); and 6 schools did not require recertification because they had closed or were otherwise
ineligible.

Of the 35 foreign schools2 with decisions, 26 (74 percent) were missing documentation required to
make an appropriate recertification decision such as a compliance audit and medical school eligibility
ratios. Further, 23 of the 35 are medical schools, of which 14 are required to provide medical exam
pass rate data. However, 11 (79 percent) of the 14 medical schools failed to provide the data. Lastly,
17 medical schools are required to provide citizenship data; 16 provided citizenship data; however, one
of the 16 provided data that deemed the school ineligible, yet SFA recertified the school. See
Appendix A for details of missing or unacceptable data for the 35 schools with decisions.

Officials of SFA’s Case Management & Oversight (CMO) stated that the statutory provisions regarding
medical exam pass rates, U.S. citizenship rates, and compliance audits are not enforceable and are not
considered in SFA’s recertification decisions. The officials stated that medical exam pass rate
information provided by the foreign medical schools is unreliable. The officials also stated that the
agency administering the test (ECFMG) has been uncooperative in providing pass rate information to
the Department. However, the Application for Institutional Participation requires foreign medical
schools to provide pass rate information – not the ECFMG. This information must be provided under
penalty of perjury.

The HEA requires compliance audits and foreign medical school eligibility information for participation in
the FFEL program. CMO officials stated that such requirements are not enforceable. However, we
did find some schools complying. Within our sample, nine schools provided compliance audits. Also,
three foreign medical schools with recertification decisions provided medical exam pass rate data and
16 recertified medical schools provided citizenship data.

The National Board of Medical Examiners (NBME) maintains statistics for results of the United States
Medical Licensing Examination. The exams are administered in three steps but just two are administered
by ECFMG. NBME’s web site reports the following average pass rates for foreign medical graduates
– both of which are below the 60 percent pass rate required for a foreign medical school to be eligible
to participate in the FFEL program:

§   49% for 1998 for Step I – Biomedical Science
§   48% for the 1997-98 cohort for Step II – Clinical Science.

Based on the medical exam pass rate statistics, SFA may have recertified medical schools that failed to
meet the pass rate ratio.


2
 One school was granted a deferment status, meaning the students attending the school are eligible for in-school
deferments for existing FFEL program loans but the school is not eligible to participate in the FFEL program.
Accordingly, the school is not required to provide compliance audits or medical school eligibility information.
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SFA’s untimely and ineffective recertification of foreign schools was due to the low priority it assigned
to the effort. In the Spring of 1997, SFA sent Applications for Institutional Participation to the 833
foreign schools identified as requiring recertification. In the Fall of 1997, SFA terminated 449 (96 of the
449 have since been reinstated) of these foreign schools from the FFEL program for failure to submit
the application. SFA needed to recertify 377 of the remaining 384 foreign schools that submitted the
application because seven are inactive in the FFEL program. SFA made its first recertification decisions
in June 1998 and as of February 15, 2000, SFA has made decisions for 180 of the 377 schools (48
percent). The remaining 197 have remained on month to month provisional status.

Providing continued eligibility to schools that merely responded to its recertification effort and providing
full and provisional recertification to schools without appropriate documentation is contrary to the HEA.
 Had SFA enforced the HEA, some foreign schools may have been determined ineligible to participate
in the FFEL program.


Recommendations

We recommend that the Chief Operating Officer for Student Financial Assistance:

1.       Obtain and review required documentation including compliance audits, medical school pass
         rates and citizenship rates.

2.       Implement controls to ensure required documentation is obtained and reviewed prior to making
         recertification decisions.

3.       Establish definitive timeframes to receive the required information and if the school does not
         respond by the set time, take appropriate action(s) to terminate the school from participation in
         the FFEL program.

4.       Document the basis for its statement that statutory requirements are not enforceable and report
         the findings to the Congress for consideration of changing the statute.

Auditee Response

SFA generally concurred with recommendations 2, 3, and 4 and will set reasonable timeframes for
submission of documentation and plans to work with the Office of Postsecondary Education to assess
what changes in regulations and/or statute may be advisable.

SFA did not completely concur with recommendation 1, although it agreed that the HEA requires that
compliance audits and medical school eligibility data be obtained. SFA believes current HEA
requirements for foreign institutions are extremely difficult, if not virtually impossible, to enforce. The two
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provisions that caused the most problems are the compliance audit and medical school pass rate
requirements.

SFA stated that some schools were unaware of, or confused with respect to the audit requirements.
SFA stated that OIG’s 1997 audit guide informed public and private nonprofit institutions, which
represent all of the schools cited for missing audits in the report, that they did not have to comply with
that guidance. As a result, it decided to wait for publication of a revised audit guide before fully
implementing this requirement. SFA will develop a “Dear Partner” letter for high volume (i.e. $500,000
and higher) foreign schools that are not in compliance with the audit requirement. This letter will direct
the schools to the OIG web site for the January 2000 revised audit guide. SFA provided compliance
audits for two schools cited in the draft audit report for not providing a compliance audit. SFA agreed
that citizenship data should be obtained, and it provided information for the four schools cited as not
being in compliance in the draft audit report.

SFA stated that prior to March 1997, foreign schools were not aware of the requirement to maintain
ECFMG pass rate data. Further, ECFMG would not provide the data to schools nor SFA acting on
behalf of the schools. SFA stated it used pass rate data provided by the schools. However, for those
schools that could not obtain the data, SFA relied on the quality of the other information in the school
application and financial statements to determine the school’s eligibility.

SFA stated they were pleased that the schools identified in the OIG’s report meet the financial
responsibility standards established under 34 CFR § 668.15.


OIG Reply

We reviewed SFA’s comments but our findings and recommendations remain unchanged. SFA has
provided an analysis regarding many of the challenges it faces in enforcing these requirements of the
HEA. However, we found no basis to authorize certain schools to participate in the FFEL program
without meeting the requirements of the HEA, or to authorize SFA to substitute reliance on other
information to determine eligibility.

Regarding the comments on the compliance audit requirements, the July 1997 audit guide did not inform
foreign public or private non-profit institutions that they did not have to comply with the guide. The
guide stated, in part, “This guide is to be used by all institutions (including foreign schools) which
administer SFA funds, with the exception of public colleges, State and local universities, and nonprofit
institutions audited in accordance with OMB Circular A-133 or its predecessors. . . . ” The guide
excepted only those institutions, both foreign and domestic, that submitted audits under the Single Audit
Act. Previously, the 1995 audit guide stated that “HEA requires annual financial and compliance audits.
. . of Title IV HEA programs for all institutions that participate in: Federal Family Educational Loan. . .
.” Therefore, audit guidance applicable to foreign schools has been available since 1995.
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We agree with SFA’s plan to send a “Dear Partner” letter to high volume schools that are not in
compliance with the audit requirements; however, that proposal does not address how SFA will ensure
compliance by institutions receiving less than $500,000. We note that § 487(c) of the HEA, which
authorizes a modified audit requirement for schools receiving less than $200,000 annually, specifically
excluded foreign schools. Section 498B(b) of the HEA, which directed the Secretary to review and
evaluate how regulations and HEA provisions could be improved, streamlined or eliminated for schools
receiving less than $200,000 a year, also specifically excluded foreign schools.

Regarding the ECFMG medical examination pass rate data, we recognize that SFA has been
unsuccessful in its effort to independently obtain the required data. However, it is the responsibility of
the institutions to provide this eligibility data to document their continued eligibility for the FFEL
program, and we found that 3 of 14 medical schools in our sample complied. SFA should ensure all
medical schools accumulate and report this data.

We reviewed the citizenship data provided and the compliance audits provided by SFA. We have
incorporated this data into the final report as appropriate.

Our audit testing found that SFA generally did have financial statements on file, and it had reviewed
these statements. However, we did not conduct an analysis of these financial statements to conclude the
schools met the financial responsibility standards set forth in 34 CFR § 668.15.
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Other Matters

SFA placed one of the 50 sampled schools in deferment status on March 30, 1999, but this school was
listed as certified and eligible in the Postsecondary Education Participant System (PEPS). Deferment
status means students attending the school are eligible for in-school deferment for existing FFEL
program loans but the school is not eligible to participate in the FFEL program. However, on
September 10, 1999, this school was listed as certified and eligible in the PEPS. Based on NSLDS
data, FFEL funds have not been awarded to students who attended the school during the period March
30, 1999 and September 29, 1999. However, because PEPS contains the official eligibility and
certification status used by guaranty agencies for lending funds to schools, this information must be
updated timely.

Auditee Response

SFA has implemented quality control measures to review PEPS data entry information using the
Eligibility and Certification Approval Report implemented to ensure the proper status is entered into
PEPS timely.
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Background

The Higher Education amendments of 1998 established a performance based organization (PBO) for
managing the operational functions of the Title IV, Student Financial Assistance programs. The Office of
Student Financial Assistance was designated as the PBO and was reorganized in the fall of 1999 and
renamed Student Financial Assistance (SFA).

Within SFA, Case Management and Oversight’s responsibilities include determining institutions’
eligibility to participate in the Title IV Student Financial Assistance programs; certifying institutions for
participation; developing and implementing policies and procedures for monitoring institutions
participating in the programs to ensure compliance with the HEA, regulations, and policies; and
conducting on-site reviews of participating educational institutions.

Audit Objectives

The purpose of our audit was to determine whether SFA:
§ Identified the universe of foreign schools requiring recertification;
§ Made timely and proper recertification decisions; and
§ Implemented adequate management controls over the recertification of foreign schools.

Methodology and Scope

To achieve the audit objectives, we selected a sample of 50 institutions from the universe of 517
institutions3 identified in NSLDS as located in foreign countries and receiving FFEL funds. Each foreign
school in the universe participated in the FFEL program during the period July 1, 1996 through June 30,
1998. Forty-three of the 50 foreign schools were judgmentally selected and account for approximately
84 percent of the FFEL activity to foreign schools during the period. Seven additional institutions from
the remaining foreign school universe were randomly selected for review. As part of the review, we
compared the eligibility status reported on PEPS with the eligibility status in institutional files and
determined if compliance audits and institutional eligibility information was obtained and reviewed. In
addition, we tracked the status of the 833 foreign schools SFA identified as requiring recertification.
Using SFA’s case team decision/tracking systems and SFA eligibility lists, we traced the recertification
status of the 3844 foreign institutions identified as requiring recertification as of July 23, 1997, and the
reinstatement of 449 institutions terminated as of July 23, 1997.

We reviewed SFA’s recertification policies and procedures and interviewed SFA personnel to obtain
an understanding of the management controls over recertifications. We interviewed Office of General


3
  Using NSLDS data, we identified all foreign institutions receiving FFEL funds during the period 7/1/96 – 6/30/98.
This universe consisted of 517 institutions receiving over $401 million in FFEL funds. This universe is less than the
833 identified by SFA because not all institutions identified by SFA received FFEL funding during the period 7/1/96 –
6/30/98.
4
  SFA included seven institutions that were inactive. As a result, SFA needed to recertify 377 institutions.
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Counsel officials regarding matters related to recertification of foreign schools. We reviewed the
NBME web site regarding pass rates for foreign medical schools graduates. We also relied on detailed
FFEL loan data maintained on the NSLDS.

To verify the accuracy of the universe of 377 foreign institutions identified by SFA as requiring
recertification, we compared the information to key data elements maintained on the NSLDS. We also
compared data maintained on PEPS to source documentation. Summarized totals of FFEL activity for
selected schools obtained from the NSLDS were traced to detailed NSLDS loan record information to
ensure the accuracy and reasonableness of the summarized totals. Based on our tests, we concluded
the data were sufficiently reliable to meet the audit objectives.

The period of our audit was from July 23, 1997 to February 15, 2000. Updated data as of February
29, 2000 was incorporated into the findings presented. We performed our fieldwork at SFA
headquarters in Washington, D.C. from April 6, 1999 through October 21, 1999. We conducted a
follow-up site visit on March 1, 2000 and obtained additional information. The information has been
incorporated into this report.

Our audit was conducted in accordance with government auditing standards appropriate to the limited
scope of the audit described above.

Management Controls

As part of our audit, we made an assessment of SFA's management control structure, policies,
procedures, and practices applicable to the audit scope. The purpose of our assessment was to
determine the level of control risk; that is, the risk that material errors, irregularities, or illegal acts may
occur.

We identified and classified the significant management controls into the following categories:

§ Documentation; and
§ Recertification decisions.

Because of inherent limitations, a study and evaluation made for the limited purpose described above
would not necessarily disclose all material weaknesses in the control structure. However, our
assessment disclosed weaknesses specifically related to obtaining the required documentation and the
quality of recertification decisions. These weaknesses are discussed in the body of this report.
ACN: ED-OIG/A01-90005                                      Audit Test Results                                                   Appendix A


                                             Compliance                     Medical school           Medical exam           Citizenship
  Sample       Decision         Decision         audit         Medical         approved              pass rate data             data
      #         by team           Date           in file       School        by 1/1/1992 *       reported by school *   reported by school *
      1      Provisional         6/18/98         YES             YES              YES                     N/A                   N/A
      2      Full                1/12/99         YES             YES              YES                     N/A                   N/A
      3      Provisional         2/2/00          YES             YES              YES                     N/A                   N/A
      4      Provisional         3/31/99         YES             YES              YES                     N/A                   N/A
      5      Provisional         5/11/99         YES             YES              NO                      NO                 YES 78%
      6      Full                6/18/98         YES             NO               N/A                     N/A                   N/A
      7      Provisional         6/29/99          NO             YES              NO                      NO                 YES 94%
      8      Provisional         8/19/98         YES             YES              YES                     N/A                   N/A
     10      Full                2/9/00          NO              NO               N/A                     N/A                   N/A
     11      Provisional         4/27/99          NO             YES              NO                      N/A                YES 87%
     12      Provisional         9/8/99           NO             YES              NO                      NO                 YES 69%
     13      Provisional         4/27/99          NO             NO               N/A                     N/A                   N/A
     14      Provisional         2/2/99           NO             YES              NO                      NO                 YES 83%
     15      Provisional         6/15/99          NO             YES              YES                     N/A                 N/A
     16      Provisional         6/29/99          NO             YES              NO                   YES 62%               YES 73%
     18      Provisional        10/23/98          NO             YES              NO                      NO                 YES 96%
     19      Full                6/29/99          NO             YES              NO                      N/A                YES 99%
     20      Provisional         2/25/99          NO             YES              NO                      NO                 YES 97%
     21      Provisional        10/13/99          NO             NO               N/A                     N/A                 N/A
     23      Provisional         7/28/99          NO             YES              NO                      NO                 YES 95%
     24      Provisional         8/25/99          NO             YES              NO                      NO                     NO
     25      Full                9/29/99         YES             NO               N/A                     N/A                   N/A
     27      Provisional         9/8/99          NO              YES              NO                   YES 71%               YES 89%
     28      Provisional         2/2/99          YES             YES              NO                   YES 82%               YES 98%
     29      Provisional         4/27/99          NO             NO               N/A                     N/A                   N/A
     35      Provisional         2/2/99           NO             NO               N/A                     N/A                   N/A
     37      Provisional         4/27/99          NO             YES              NO                      NO                 YES 99%
     38      Provisional         8/25/99          NO             YES              NO                      NO                 YES 0%
     39      Full                4/27/99          NO             YES              NO                      N/A                YES 75%
     40      Provisional         11/3/99          NO             YES              NO                      NO                 YES 98%
     41      Full                8/3/98           NO             NO               N/A                     N/A                   N/A
     44      Full                2/2/99           NO             NO               N/A                     N/A                   N/A
     46      Provisional         4/27/99          NO             NO               N/A                     N/A                   N/A
     47      Provisional         6/30/99         NO              NO               N/A                     N/A                   N/A
     50      Deferment           3/30/99         N/A             N/A              N/A                     N/A                   N/A
   Totals                  35                   YES - 9       YES - 23          YES - 6                  YES - 3              YES - 16
                                                NO - 25        NO - 11          NO - 17                  NO - 11                NO - 1
                                                N/A - 1        N/A - 1          N/A - 12               N/A - 21              N/A - 18


 * HEA requires foreign medical schools to meet either the first two, or the last of, the following criteria:
             - at least 60% of its medical school graduates from the preceding year must be non-US citizens;
             - at least 60% of its medical students or graduates must receive a passing score on ECFMG administered tests; or
             - the institution must have a clinical program that was approved by a state as of 1/1/92.


 Yellow denotes noncompliance.
                                     REPORT DISTRIBUTION LIST

                                                                                                              No. of copies

Greg Woods
Chief Operating Officer
Student Financial Assistance.........................................................................................1

Other ED Offices
Deputy Secretary, Office of the Deputy Secretary.........................................................1

Assistant Secretary, Office of Postsecondary Education................................................1

General Manager for Schools, Student Financial Assistance ..........................................1

Chief Financial Officer, Student Financial Assistance.....................................................1

Director, Case Management & Oversight, Student Financial Assistance.........................1

General Counsel, Office of General Counsel.................................................................1

Director, Office of Public Affairs...................................................................................1

Director, Post Audit Group, Office of the Chief Financial Officer...................................1


ED-OIG
Inspector General.........................................................................................................1

Deputy Inspector General.............................................................................................1

Assistant Inspector General for Investigations ...............................................................1

Assistant Inspector General for Analysis and Inspections...............................................1

Assistant Inspector General for Audit (A) .....................................................................1

Deputy Assistance Inspector General for Audit (A).......................................................1

Director, Student Financial Assistance Advisory & Assistance Team.............................1

Regional Inspectors General for Audit ..........................................................................6