oversight

The Department's Process for Screening and Selecting Peer Reviewers for the Race to the Top Grant Program.

Published by the Department of Education, Office of Inspector General on 2010-08-16.

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

         U.S. Department of Education 

          Office of Inspector General 


   American Recovery and
   Reinvestment Act of 2009
    The Department’s Process for Screening and Selecting 

    Peer Reviewers for the Race to the Top Grant Program 


                    Final Audit Report




ED-OIG/A19K0006                             August 2010
                                         UNITED STATES DEPARTMENT OF EDUCATION

                                              OFFICE OF INSPECTOR GENERAL



                                                                       August 16, 2010

Thelma Meléndez de Santa Ana, Ph.D.
Assistant Secretary
Office of Elementary and Secondary Education
U.S. Department of Education
400 Maryland Avenue, S.W.
Washington, DC 20202

Dear Dr. Meléndez de Santa Ana:

This final audit report presents the results of our audit of the U.S. Department of Education’s
process for screening and selecting peer reviewers for Phase 1 of the Race to the Top
discretionary grant program competition. We received the Office of Elementary and Secondary
Education’s comments on the contents of our draft report. The comments are summarized within
the Results section of this report.

Corrective actions proposed (resolution phase) and implemented (closure phase) by your office
will be monitored and tracked through the Department’s Audit Accountability and Resolution
Tracking System (AARTS). Department policy requires that you develop a final corrective
action plan (CAP) for our review in the automated system within 30 days of the issuance of this
report. The CAP should set forth the specific action items, and targeted completion dates,
necessary to implement final corrective actions on the findings and recommendations contained
in this final audit report.

In accordance with the Inspector General Act of 1978, as amended, the Office of Inspector
General is required to report to Congress twice a year on the audits that remain unresolved after
6 months from the date of issuance.

In accordance with the Freedom of Information Act (5 U.S.C. § 552), reports issued by the
Office of Inspector General are available to members of the press and general public to the
extent information contained therein is not subject to exemptions in the Act.

We appreciate the cooperation given to us during this review. If you have any questions, please
call Michele Weaver-Dugan at (202) 245-6941.


                                                                           Sincerely,               



                                                                           Keith West /s/       

                                                                           Assistant Inspector General for Audit                               


 The Department of Education's mission is to promote student achievement and preparation for global competitiveness by fostering educational
                                                   excellence and ensuring equal access.
Final Audit Report                                                                                      Page 3 of 8
ED-OIG/A19K0006

        The Department’s Process for Screening and Selecting Peer Reviewers for the 

                            Race to the Top Grant Program 

                           Control Number ED-OIG/A19K0006

                                                    PURPOSE

The American Recovery and Reinvestment Act of 2009 (ARRA) places a heavy emphasis on
accountability and transparency, and in doing so, increases the responsibilities of the agencies
that are impacted by the Act. Overall, the U.S. Department of Education (Department) is
responsible for ensuring that education-related ARRA funds reach intended recipients and
achieve intended results. The Department’s responsibilities further include ensuring that
competitive discretionary grant review processes are consistent with applicable laws and
regulations and are executed in a manner that is both fair and objective. As a general rule, the
Department’s policy is that a fair and competitive review process is enhanced by the use of
outside reviewers to provide an independent perspective.

This final report provides the results of our audit of the Department’s process for screening and
selecting peer reviewers for Phase 1 of the Race to the Top (RTT) discretionary grant program
competition. This $4 billion program represents the largest-ever single Federal investment in
school reform and improvement efforts. The objectives of our audit were to determine the:

    1.	 Appropriateness of Department actions in the screening and selection of peer reviewers
        for the RTT discretionary grant program competition (including compliance with
        applicable laws, regulations, policies, and procedures); and
    2.	 Effectiveness of the Department’s processes and controls in identifying conflicts of
        interest or other issues.

                                                    RESULTS

We found that the Department’s process for screening and selecting peer reviewers for Phase 1
of the RTT discretionary grant program competition was generally appropriate and effective in
identifying applicant conflicts of interest.1 The Department employed a 10-step selection
process that involved no less than 35 Department employees and included at least 4 separate
checks for conflicts of interest, performed by personnel from 3 distinct entities – the Office of
Elementary and Secondary Education (OESE), the Office of the General Counsel (OGC), and a
private contractor.2 Applicants were screened for both direct and indirect conflicts of interest,3
and in instances where such conflicts were identified, either dropped from consideration and
informed of the reason(s) or granted a waiver for indirect conflicts to participate in the RTT
Phase 1 application review process. The Department granted waivers only for indirect conflicts
1
  A narrative overview of the Department’s implemented process is included as Attachment 1 to this report. A
summary of participants and outcomes of each step of the implemented process is included as Attachment 2.
2
  The group of 35 individuals was comprised of 28 career employees and 7 political appointees from 9 principal
offices. See Attachment 2 for additional detail on the employees and offices involved in the RTT peer reviewer
screening and selection process.
3
  A direct conflict of interest is a situation in which an individual’s financial interests would be affected by the
outcome of the competition. An indirect conflict of interest includes relationships with entities or individuals who
might stand to benefit financially from the outcome of the competition.
Final Audit Report                                                                                       Page 4 of 8
ED-OIG/A19K0006

determined not to be substantial. Overall, 15 of the 49 individuals (31 percent) who reviewed
RTT Phase 1 applications received waivers from the Department. We reviewed the waivers
granted as part of our audit and found them to be granted and issued in accordance with the
Department’s policies and procedures.4

However, we determined that the Department did not perform a check of selected RTT peer
reviewers against the General Services Administration’s (GSA) Excluded Parties List System
(EPLS) or adequately document formal approval of its peer reviewer roster prior to the beginning
of the application review process.5 This verification and documentation occurred after the initial
application review and rating was completed and the Department publically announced the 16
RTT finalists. Although no RTT peer reviewers appeared in the EPLS, the integrity of the
review process could have been compromised had it been discovered that a reviewer –
particularly one involved in such a high visibility program – was debarred or suspended from
doing business with the Federal government.

In its response to the draft audit report, OESE concurred that there was an issue with the
timeliness of the EPLS verification. However, OESE believed the issue did not impact the
integrity or quality of either the competition or the review process and further believed the issue
should not be reported as an audit finding. While we acknowledge that no RTT peer reviewers
were found in the EPLS, we do not agree with OESE’s position on the issue. The 16 RTT
finalists had been publicly announced prior to the EPLS verification. We believe that due to this
timing, the integrity of the review process could have been compromised had any reviewers been
identified in the EPLS. OESE’s comments are summarized at the end of the finding. The full
text of OESE’s response is included as Attachment 4 to this report.

                                                BACKGROUND

The RTT program is a discretionary grant program, new in fiscal year 2010, authorized under the
ARRA. It consists of two separate grant programs: (1) RTT assessment grants, for which $350
million has been set aside for the purpose of supporting States in the development of a next
generation of assessments aligned to common sets of standards, and (2) RTT competitive State
grants for reform, valued cumulatively at $4 billion and the focus of this audit. The Department
decided to make RTT grant awards in two phases. Phase 1 applications were due on
January 19, 2010 and awards were announced on March 29, 2010. Phase 2 applications were
due on June 1, 2010, with awards expected by September 30, 2010.

The purpose of the RTT program is to encourage and reward States that are creating the
conditions for education innovation and reform; achieving significant improvement in student
outcomes, including making substantial gains in student achievement, closing achievement gaps,
4
  A document posted online by the Department entitled Race to the Top Summary of Conflict of Interest Policy and
Procedure states that “A waiver may be issued when a determination is made that an individual’s financial interest
is not so substantial as to affect the integrity of his or her services and, given all relevant facts, the Department’s
need for the individual reviewer’s services outweighs the possibility that a reasonable person would question the
reviewer’s impartiality.”
5
  The purpose of the EPLS is to provide a single comprehensive list of individuals and firms excluded by Federal
government agencies from receiving Federal contracts or Federally-approved subcontracts and from certain types of
Federal financial and nonfinancial assistance and benefits.
Final Audit Report                                                                     Page 5 of 8
ED-OIG/A19K0006

improving high school graduation rates, and ensuring student preparation for success in college
and careers; and implementing ambitious plans in four core education reform areas:

          Adopting standards and assessments that prepare students to succeed in college and the
           workplace and to compete in the global economy;
          Building data systems that measure student growth and success, and inform teachers and
           principals about how they can improve instruction;
          Recruiting, developing, rewarding, and retaining effective teachers and principals, 

           especially where they are needed most; and

          Turning around our lowest-achieving schools.

In November 2009, the Department published a notice of final priorities in the Federal Register
and invited applications for RTT grants.6 The notice provided a brief description of the
application review process, stating that a two-tiered review process would be used to judge the
eligible applications. The initial review would be based solely on reviews of the written
applications, while the final review would be based on both a State’s written application and in-
person presentation. The notice also stated that the Department would use independent
reviewers chosen from a pool of qualified educators, scholars, and other individuals
knowledgeable in education reform. It further noted that the Department would thoroughly
screen all reviewers for conflicts of interest to ensure a fair and competitive review process.

To facilitate the selection of RTT peer reviewers, the Department posted a Dear Colleague Letter
from the Secretary on August 31, 2009. The letter stated that the Department sought 50 to 80
individuals to serve on the peer review panels, each with expertise in some, if not all, of the
following areas: (1) education policy, (2) education reform, (3) capacity and scale, and
(4) application review and evaluation. It added that any applicant's selection as a peer reviewer
for the RTT competition would also include a review for possible, apparent, and/or actual
conflicts of interest, and that if a potential conflict of interest was identified, the Department
would consider whether the applicant could participate as a peer reviewer in full compliance with
all applicable Department policies and procedures. As part of this process, each applicant would
be required to complete a conflict of interest questionnaire that provided information about the
applicant’s professional experience(s), including any financial interest that the applicant may
have in any State's RTT application. The Department planned to provide each peer reviewer
with an honorarium of up to $7,500 for their work.

On January 25, 2010, the Department posted a description of the RTT application review process
on its website. This included information on the screening and selection of peer reviewers. The
description stated that the Department’s legal ethics team eliminated any applicant with existing
or potential conflicts of interest, including people currently employed by a State department of
education or school district. It further stated that, despite the extensive vetting that occurred
prior to the selection of the 58 reviewers, the Department recognized that in the process of
reading an application, a reviewer may spot a potential conflict that had not been considered. If
such conflicts occurred, applications would be reassigned among reviewers. To mitigate this,
reviewers would also be prohibited from reviewing applications from their home State or States
where they had any potential conflicts of interest.
6
    A draft notice was put forth for public review and comment in July 2009.
Final Audit Report                                                                                 Page 6 of 8
ED-OIG/A19K0006

                                                 FINDING

The Department Did Not Perform Timely EPLS Verification or Adequately Document
Approval of its Peer Reviewer Roster

We determined that OESE did not perform a check of selected RTT peer reviewers against the
GSA’s EPLS prior to the beginning of the application review process and selection of the 16
RTT finalists. Individual RTT program application reviews began on January 23, 2010, and
RTT finalists were announced on March 4, 2010. OESE staff indicated that the debarment check
was conducted by their front office during the week of March 8, 2010, as evidenced by a related
memorandum signed by their Executive Officer on March 9, 2010.

In addition, we found OESE did not maintain required documentation in the grant files to support
that the peer reviewer roster was officially approved prior to the start of the application review
process. OESE noted that the Executive Officer’s March 9, 2010 correspondence is the standard
documentation used as evidence that the overall list of peer reviewers is approved. OESE
emphasized that these reviewers were actually approved during a meeting of RTT and OESE
leadership that took place on January 5, 2010. OESE cited two documents found during our
review of the Grant Program Competition File as evidence that the reviewers were approved on
January 5: (1) a meeting invitation, dated January 5, 2010, that identified members of the RTT
Program, Leadership, and Management Teams as required or optional attendees;7 and (2) an
adjacent list of 74 peer reviewers. However, neither document was signed or otherwise indicated
approval of the reviewer roster prior to the start of the application review process on
January 23, 2010.

Section 3.4.3 of the Department’s Handbook for the Discretionary Grant Process states

        The program staff must also ensure that the names of any reviewers to be chosen do not
        appear on the GSA Excluded Parties List System (EPLS) list of persons who have been
        debarred or suspended. … After reviewers are selected, the program staff submits the
        reviewer roster for each competition to the program official for review and approval. The
        program official must approve the reviewer roster and include it as part of the Grant
        Program Competition File prior to beginning the review.




7
  The Department established four working groups to guide and direct the RTT program, each consisting of
representatives from various principal offices. The Response Team convenes frequently to respond to questions on
the RTT application. The Program Team convenes as-needed to address programmatic questions and make
recommendations to the Leadership Team. The Leadership Team convenes weekly or biweekly to consider
recommendations made by the Program Team and discuss other programmatic questions, as needed. Lastly, the
Management Team, which consists of the RTT Director, the Director of OESE’s Academic Improvement and
Teacher Quality programs, and the Senior Advisor for Policy and Programs in the Office of the Deputy Secretary,
meets frequently, as needed, to consider and make decisions pertaining to RTT programmatic and policy issues.
The Application Technical Review Plan (ATRP) states that these three Management Team officials have had central
roles in the planning, development, and implementation processes for the RTT program and competition and have
participated as members of the Leadership Team.
Final Audit Report                                                                              Page 7 of 8
ED-OIG/A19K0006

We found that OESE staff did not provide a memorandum that served as both a debarment check
request and a request for approval of prospective peer reviewers to their Deputy Assistant
Secretary for Management until March 2, 2010. As a result, the EPLS check was not completed
and official roster approval was not documented until 45 days after the start of the application
review process and 5 days after the announcement of the finalists. As outlined in Attachment 2,
the screening and selection process for RTT peer reviewers otherwise appeared detailed and
thorough.

We confirmed that none of the 588 selected peer reviewers were, in fact, in the EPLS. However,
we identified four reviewers for whom additional research was required, including one who
shared the same name and location as an individual in the EPLS. Failure to perform a timely
EPLS verification and document roster approval could have compromised the integrity of the
review process, especially had it been discovered that a reviewer – particularly one involved in
such a high visibility program – was debarred or suspended from doing business with the Federal
government after the 16 RTT finalists were announced.

Recommendation

We recommend that the Assistant Secretary for OESE:

1.1	       Ensure that timely EPLS verifications are performed and that reviewer rosters are
           approved and placed in the Grant Program Competition File prior to the initiation of
           application reviews for discretionary grant program competitions.

OESE Comments

OESE stated that it recognizes, and does not dispute, that there was an issue in the peer reviewer
selection process regarding the timeliness of its check of potential reviewers to ensure that they
were not on the debarment and suspension list. However, OESE believed the issue was
discovered at a “… point [at which] it could be easily addressed… .” OESE also expressed its
belief that the issue was minor, as evidenced by the fact that no reviewers were actually found on
the debarment and suspension list, and therefore should not have risen to the level of a finding.
OESE described the issue as a “… harmless, procedural matter that was conducted a little late
and that was corrected by the Department on a timely basis, as soon as it was discovered, and did
not in any way affect the integrity or quality of the competition or the review process.”

OIG Response

While we acknowledge that no RTT peer reviewers were found on the debarment and suspension
list, we do not concur with OESE’s assertion that it was discovered at a “… point [at which] it
could be easily addressed,” nor its characterization of the issue as a “… harmless, procedural
matter... .” The 16 RTT finalists had already been publicly announced at the time of the
debarment and suspension list check, meaning that the integrity of the review process could have
been compromised had any reviewers subsequently been found on the list. The fact that no

8
    Overall, 49 of the 58 selected peer reviewers actually reviewed RTT Phase 1 applications.
Final Audit Report                                                                     Page 8 of 8
ED-OIG/A19K0006

reviewers were identified in the EPLS when the check was conducted does not obviate the need
to complete the review earlier in the selection process or lessen its significance as an internal
control procedure.

                               SCOPE AND METHODOLOGY

To accomplish our objectives, we performed a review of internal control applicable to the
Department’s process for screening and selecting peer reviewers for discretionary grant program
competitions. This included reviews of applicable Department policies and procedures; prior
audit reports from OIG and other agencies, through which we sought to identify any potential
vulnerabilities in this area; and the Government Accountability Office’s Standards for Internal
Control in the Federal Government. We also gained an understanding of procedures specific to
the screening and selection of RTT peer reviewers. We reviewed the authorizing legislation and
program regulations, as well as various materials provided by Department officials and/or posted
on the Department’s ARRA website. We conducted interviews with these same officials in order
to obtain additional information on the reviewer selection process.

We reviewed the RTT Grant Competition File and ATRP to determine whether they contained
all required information. We reviewed all 58 selected peer reviewers’ files for completeness,
reviewed and assessed the appropriateness of the 15 waivers granted by the Department, and
conducted independent searches to confirm the accuracy of reported information and identify any
discrepancies or other matters of concern. This included verification of eligibility based on an
individual’s presence in the EPLS and a review of Federal Election Commission data to establish
whether it might appear that political affiliation played a role in the selection process. We also
reviewed documentation maintained for a random sample of 25 of the 130 individuals
(19 percent) who were eliminated from consideration following the initial conflict of interest
questionnaire and for all 16 individuals who were eliminated from consideration following the
final conflict of interest questionnaire. This was done to determine the reasoning behind such
decisions and gain assurance that the Department did not arbitrarily eliminate prospective
reviewers from the pool of applicants.

We relied on computer-processed data obtained from OESE staff to identify our universe of non-
selected applicants. There were no other data sources readily available to independently
corroborate the completeness of this data. However, the data were deemed sufficiently reliable
for the purpose of this audit and adequately support resulting conclusions and recommendations.
The scope of our review was limited to the Department’s screening and selection of peer
reviewers for Phase 1 of the RTT discretionary grant program competition. We conducted
fieldwork at Department offices in Washington, D.C., during the period March 2010 through
April 2010. We provided our audit results to Department officials during an exit conference held
on April 28, 2010.

Our audit was performed in accordance with generally accepted government auditing standards
appropriate to the scope of the review. The standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on the audit objectives.
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           The Department of Education’s mission is to promote 

     student achievement and preparation for global competitiveness 

      by fostering educational excellence and ensuring equal access. 


                                     www.ed.gov
                                                                                                    Attachment 1

                                 Overview of the Department’s 

                        RTT Peer Reviewer Screening and Selection Process


OESE’s ATRP included all required information and provided a comprehensive overview of the
RTT peer reviewer selection process. The Department employed a 10-step selection process
which involved no less than 35 Department employees and included at least 4 separate checks
for conflicts of interest, performed by personnel from 3 distinct entities – OESE, OGC, and a
private contractor.9 Applicants were screened for both direct and indirect conflicts of interest,10
and in instances where such conflicts were identified, either dropped from consideration and
informed of the reason(s) or granted a waiver to participate in the RTT Phase 1 application
review process. These screenings were conducted by the entities described above, both
singularly and in consultation with each other.

OESE staff initially identified the RTT peer reviewer applicants that possessed the necessary
expertise and experience, as outlined by the Secretary in his August 2009 request for reviewers.
These applicants were asked to complete a questionnaire designed to identify direct conflicts of
interest. Responses were provided to OESE and entered into a database to allow review by
program staff. Prospective candidates with a direct conflict of interest were identified and
removed from consideration.

Subsequently, a team of Department officials consisting of career employees and political
appointees with knowledge and experience concerning RTT program goals ranked the remaining
candidates on the basis of their qualifications to serve.11 This process identified 74 preliminary
finalists who were asked to complete another questionnaire designed to identify indirect conflicts
of interest. The preliminary finalists were also asked whether they were aware of any other
circumstances that might cause someone to question their ability or objectivity. This item was
intended to raise awareness of any actual, potential, or perceived conflicts of interest. Responses
were provided online through a survey tool administered by a private contractor.

In mid-December 2009, OESE provided the contractor with the preliminary finalists’ responses
to the questionnaire and asked that it run targeted internet searches on each individual to identify
any issues or affiliations not previously disclosed. The contractor conducted follow-up phone
calls with those for whom clarification and/or additional information was needed and
documented their responses in a conflict of interest report prepared for each candidate. The
reports were subsequently provided to officials in OGC’s Ethics Division, who in consultation
with OESE, reviewed all available information, contacted some individuals again by phone to
clarify their responses, and made the final decision on whether a prospective reviewer would be



9
  See footnote 2 on page 3. 

10
   See footnote 3 on page 3.

11
   The Department sought applicants with expertise in the following four areas: 1) education policy, 2) education

reform, 3) capacity and scale, and 4) application review and evaluation. It was also suggested that applicants 

possess a broad understanding of each of the four education reform areas embodied by RTT: 1) standards and 

assessments, 2) teachers and school leaders, 3) data systems, and 4) school turnaround. 

cleared to serve. In the end, the Department invited 58 individuals to participate in the RTT
Phase 1 peer review, either as reviewers or alternates.12

During this process, the Department deemed some applicants to have an indirect conflict of
interest for which a waiver could be granted. Specifically, OGC recommended waivers for 21 of
the 58 individuals (36 percent) invited to serve as RTT Phase 1 peer reviewers. However, 5 of
these 21 individuals served as alternates, meaning they did not review any applications and
therefore, according to Department officials, did not require waivers unless called upon to do so.
In addition, one individual who would have required a waiver based on a prior affiliation with
one State Education Agency did not receive a waiver because the applicable State did not submit
an RTT Phase 1 application. We subsequently located approved waivers on file for the 15
individuals who reviewed RTT Phase 1 applications and required waivers. None of the
alternates who would have required waivers were asked to serve.

Upon selection, reviewers and alternates were required to sign a reviewer agreement, thereby
certifying to the completeness and accuracy of information provided by them during the conflict
of interest review and acknowledging the need for integrity in the review process and
confidentiality with respect to their role as a peer reviewer. Individuals were also advised to
promptly notify the appropriate program official if they became aware of any circumstances that
might cause someone to question their impartiality or if they discovered that they may have a
previously unidentified direct or indirect conflict of interest while reviewing the applications
assigned to them.

Department officials also stated that certain aspects of the design of the RTT competition itself
helped mitigate the possibility that any individual peer reviewer may not be impartial. These
included the following:

        Reviewers were not permitted to serve on a panel reviewing the application submitted by
         the State in which he or she resides.
        Reviewers granted a waiver for an indirect conflict of interest were not permitted to
         review an application from the State(s) that gave rise to the conflict.
        Applications were randomly assigned to reviewers after the States for which reviewers
         had waivers or disqualifications were “blacked out.”
        Each application was reviewed by five reviewers.
        Both before and during the review process, program officials and reviewers were
         reminded that throughout the course of the review, they must identify any circumstances
         that might cause a reasonable person to question a reviewer’s impartiality in serving.




12
  Thirteen of these 58 individuals (22 percent) were initially designated as alternates. Five alternates were
subsequently included in the RTT Phase 1 application review.
                                                                 Attachment 2

Summary of Participants and Outcomes of Each Step of the Department’s
        RTT Peer Reviewer Screening and Selection Process
                                                                   Attachment 3

                      Acronyms/Abbreviations Used in this Report

ARRA         American Recovery and Reinvestment Act of 2009

ATRP         Application Technical Review Plan

Department   U.S. Department of Education

EPLS         Excluded Parties Listing System

GSA          Government Services Administration

OESE         Office of Elementary and Secondary Education

OGC          Office of the General Counsel

OIG          Office of Inspector General

RTT          Race to the Top

Secretary    U.S. Secretary of Education
                                                                          Attachment 4


                       UNITED STATES DEPARTMENT OF EDUCATION
                           OFFICE OF ELEMENTARY AND SECONDARY EDUCATION




 
 
TO:      Ms. Michele Weaver‐Dugan, Director 
          Operations Internal Audit Team 
 
FROM:    Joseph Conaty, Director 
         Academic Achievement and Teacher Quality Programs   
                    
SUBJECT: Draft Audit Report: The Department’s Process for Screening and  
         Selecting Peer Reviewers for the Race to the Top Grant Program,  
         A19‐K0006 
 
We appreciate the opportunity your office provided for a meeting to discuss the 
possible findings from the audit work on "The Department's Process for Screening 
and Selecting Peer Reviewers for the Race to the Top Grant Program," and the 
opportunity to provide comments on the draft report. We found the audit team 
working on this matter to be open, objective, cooperative, and highly 
professional. 
 
As a general matter, we appreciate that the Office of Inspector General 
recognizes the many careful steps we included in our selection and review process 
of potential peer reviewers to ensure fairness, objectivity, and highly skilled 
group of peer reviewers.  The process was very effective in meeting its goals and 
worked exceedingly well. 
 
At the same time, we recognize that there was one minor issue in the competition 
regarding checking potential reviewers to ensure that they were not on the 
debarment and suspension list.  While we do not dispute that ideally this check 
should have occurred on a more timely basis, we do not believe that this issue 
should rise to the level of a finding and have such prominence in this report.  
When the Department discovered it, it was a point that it could be easily 
addressed, and Department officials immediately addressed this issue and, in 
fact, no reviewers were on the debarment and suspension list.  At most, 
therefore, this was a harmless, procedural matter that was conducted a little 
late and that was corrected by the Department on a timely basis, as soon as it 
was discovered, and did not in any way affect the integrity or quality of the 
competition or the review process. 
 
We appreciate the overall positive nature of the report in identifying the 
overall very fair and successful process, and thank you for the opportunity to 
comment.  Please let us know if you have any questions.  Thanks.