oversight

Border Security: New Policies and Increased Interagency Coordination Needed to Improve Visa Process

Published by the Government Accountability Office on 2003-07-15.

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

                            United States General Accounting Office

GAO                         Testimony
                            Before the Senate Judiciary Subcommittee
                            on Immigration, Border Security and
                            Citizenship

For Release on Delivery
Expected at 2:30 p.m. EDT
Tuesday, July 15, 2003      BORDER SECURITY
                            New Policies and Increased
                            Interagency Coordination
                            Needed to Improve Visa
                            Process
                            Statement of Jess T. Ford
                            Director, International Affairs and Trade




GAO-03-1013T
                                                  July 15, 2003


                                                  BORDER SECURITY

                                                  New Policies and Increased Interagency
Highlights of GAO-03-1013T, a testimony           Coordination Needed to Improve Visa
before the Senate Judiciary Subcommittee
on Immigration, Border Security and               Process
Citizenship




Since September 11, 2001, visa                    Our analysis of the visa process shows that the Departments of State,
operations have played an                         Homeland Security, and Justice could more effectively manage the visa
increasingly important role in                    process if they had clear and comprehensive policies and procedures and
ensuring the national security of                 increased agency coordination and information sharing. In our October 2002
the United States. The                            report on the visa process as an antiterrorism tool, we found that
Departments of State, Homeland
                                                  •
Security, and Justice, as well as
other agencies, are involved in the               •     State did not provide clear policies on how consular officers should
visa process. Each plays an                             balance national security concerns with the desire to facilitate legitimate
important role in making security                       travel when issuing visas; and
decisions so that potential                       •     State and Justice disagreed on the evidence needed to deny a visa on
terrorists do not enter the country.                    terrorism grounds.
In two GAO reports, we assessed
the effectiveness of the visa                     In our June 2003 report, we found that State had revoked visas for terrorism
process as an antiterrorism tool.                 concerns but that

                                                  •     The revocation process was not being used aggressively to alert
GAO made numerous                                       homeland security and law enforcement agencies that individuals who
recommendations to strengthen the                       entered the country before their visas were revoked might be security
visa process as an antiterrorism                        risks; and
tool. Among them, GAO                             •     The process broke down when information on revocations was not being
recommended that the Department                         shared between State and appropriate immigration and law enforcement
of Homeland Security, in                                officials.
conjunction with the Departments
of State and Justice, develop                     These weaknesses diminish the effectiveness of the visa process in keeping
specific policies and procedures for
                                                  potential terrorists out of the United States.
the interagency visa revocation
process to ensure that when State
revokes a visa because of terrorism               Diagram of Gaps in the Visa Revocation Notification System
concerns, the appropriate units                                                                                   Issuing visas
within State, Homeland Security,
and the FBI are notified                                  Department of State
immediately and that proper
actions are taken.                                                                                              Department of State
                                                               Bureau of
State said it is using our                                  Consular Affairs
recommendations as a roadmap for                                                                               Controlling entries
                                                             revokes visas
making improvements in the visa
process. Homeland Security
agreed that the visa process should
be strengthened as an antiterrorism
tool.                                                                                                     Department of Homeland Security

                                                                                                                 Managing stays



www.gao.gov/cgi-bin/getrpt?GAO-03-1013T.                           Inconsistent or incomplete
                                                                   information flow                       Department of Homeland Security
To view the full testimony, including the scope                    No information flow                         Department of Justice
and methodology, click on the link above.
For more information, contact Jess T. Ford at     Sources: GAO and Art Explosion.
(202) 512-4128 or fordj@gao.gov.
Mr. Chairman and Members of the Subcommittee:

I am pleased to be here to discuss our recent work on the visa process and
some of the ways we believe this process could be strengthened as an
important part of our country’s border security strategy. Mr. Chairman,
citizens of other countries seeking to enter the United States temporarily
for business, tourism, and other reasons generally must apply for and
obtain a U.S. travel document, called a nonimmigrant visa, at U.S.
embassies or consulates abroad before arriving at U.S. ports of entry. In
deciding who should and should not receive a visa, consular officers must
perform a risk assessment that balances the need to facilitate legitimate
travel with the need to protect the United States against potential
terrorists and to deter others whose entry is considered likely to be
harmful to U.S. national interests. Consular officers also need to delicately
balance U.S. national security interests with other interests such as
promoting U.S. business, tourism, education and cultural exchanges, and
the overall health of our economy.

Since September 11, 2001, visa operations have played an increasingly
important role in ensuring the national security of the United States. The
Departments of State, Homeland Security, and Justice, as well as other
agencies, are involved in the visa process, with each playing an important
role in making security decisions.

My testimony today is based on two of our recent reports1 on the visa
process that contained observations and recommendations on ways in
which national and border security could be strengthened through the visa
process, implementation of clear visa policies and guidelines, and sharing
of information and data. The first report focused on the effectiveness of
the visa process as an antiterrorism tool and recommended ways that the
process could be strengthened as a screen against terrorists. The second
report provides examples of how weaknesses in policy and interagency
coordination are affecting border security. In addition to my comments
based on the two reports, I will provide a brief overview of an emerging
visa policy issue that warrants oversight.




1
 U.S. General Accounting Office, Border Security: Visa Process Should Be Strengthened as
an Antiterrorism Tool, GAO-03-132NI (Washington, D.C.: Oct. 21, 2002) and U.S. General
Accounting Office, Border Security: New Policies and Procedures Are Needed to Fill Gaps
in the Visa Revocation Process, GAO-03-798 (Washington, D.C.: June 18, 2003).



Page 1                                                                   GAO-03-1013T
          Our analysis of the visa process shows that the Departments of State,
Summary   Homeland Security, and Justice could more effectively manage the visa
          function if they had clear and comprehensive policies and procedures and
          increased agency coordination and information sharing. Our October 2002
          report addressed the need for a clear policy on how to balance national
          security concerns with the desire to facilitate legitimate travel when
          issuing visas. It also addressed the need for more coordination and
          information sharing to realize the full potential of the visa process. In
          addition, there is a need for more human resources and more training for
          consular officers. We made several recommendations to the Department
          of State and the new Department of Homeland Security to improve this
          process. State reported that it plans to use our recommendations as a road
          map for improving the visa process.

          Our June 2003 report also pointed out that the U.S. government does not
          have a clear and comprehensive policy on the interagency visa revocation
          process. This process should be used more aggressively to alert homeland
          security and law enforcement agencies that individuals who entered the
          country before their visas were revoked might be security risks. However,
          we found that the process broke down because information on visa
          revocations was not shared between State and appropriate immigration
          and law enforcement offices. It broke down even further when individuals
          in question had already entered the United States prior to revocation. In
          our review of the 240 visas that were revoked for terrorism concerns
          between September 11, 2001 and December 31, 2002, we found numerous
          cases where notifications of the revocations did not reach appropriate
          units within the Immigration and Naturalization Service (INS)2 and FBI.
          We also found evidence that individuals whose visas were revoked
          because of terrorism concerns entered the United States and may still
          remain in the country. We have made recommendations to the
          Departments of Homeland Security, State, and Justice to improve the
          revocation process. Homeland Security agreed that the visa revocation
          process needed to be strengthened.




          2
           On March 1, 2003, INS became part of three units within the Department of Homeland
          Security. INS inspection functions transferred to the Bureau of Customs and Border
          Protection; its investigative and enforcement functions transferred to the Bureau of
          Immigration and Customs Enforcement; and its immigration services function became part
          of the Bureau of Citizenship and Immigration Services. Because our work focused on visa
          revocation cases that took place before the March 1 reorganization, our report referred to
          the U.S. government’s immigration agency as “INS.”



          Page 2                                                                     GAO-03-1013T
                        State has directed that, beginning August 1, posts interview all foreign
                        individuals, with a few exceptions, seeking to visit the United States prior
                        to visa issuance. The purpose of this guidance is to tighten the visa
                        process. The new regulations may result in delays if posts do not have
                        adequate resources to handle the number of interviews.

                        Mr. Chairman, I now want to provide additional details on the policies,
                        procedures, and coordination that we described in our reports.


                        The September 11 attacks illustrated the vulnerabilities in the visa process
Visa Process Should     when it became known that all 19 of the terrorist hijackers had been
Be Strengthened as an   issued visas to enter the United States. Before the attacks, the State
                        Department’s visa operations focused primarily on screening applicants to
Antiterrorism Tool      determine whether they intended to work or reside illegally in the United
                        States. In deciding on who should receive a visa, consular officers relied
                        on the State Department’s consular “lookout” system, a name check
                        system that incorporates information from many agencies, as the primary
                        basis for identifying potential terrorists.3 Consular officers were
                        encouraged to facilitate legitimate travel and, at some posts we visited,
                        faced pressure to issue visas. The State Department gave overseas
                        consular sections substantial discretion in determining the level of
                        scrutiny applied to visa applications and encouraged streamlined
                        procedures to provide customer service and deal with a large workload.
                        As a result, according to State Department officials and documents,
                        consular sections worldwide adopted practices that reduced the review
                        time for visa applications. For example, some posts decided not to
                        interview applicants who appeared likely to return to their country at the
                        end of their allotted time in the United States.

                        Since the terrorist attacks, the U.S. government has introduced some
                        changes to strengthen the visa process. For example, the State Department
                        has, with the help of other agencies, almost doubled the number of names
                        and the amount of information in the lookout system. Further, the
                        Department began seeking new or additional interagency clearances on
                        selected applicants to screen out terrorists, although these checks were


                        3
                         U.S. General Accounting Office, Information Technology: Terrorist Watch Lists Should
                        Be Consolidated to Promote Better Integration and Sharing GAO-03-322 (Washington,
                        D.C.: Apr. 15, 2003). We recommended a series of actions including that the Department of
                        Homeland Security and other agencies that have and use watch lists lead an effort to
                        standardize and consolidate the federal government’s watch list structures and policies.



                        Page 3                                                                    GAO-03-1013T
not always completed by other U.S. agencies in a thorough or timely
manner. We also observed that consular officers at some of the posts we
visited were spending more time reviewing visa applications and
interviewing applicants; they were able to do so, at least temporarily,
because the number of visa applications decreased dramatically after
September 11.

While these actions have strengthened the visa process, our work in 2002
showed that there were widely divergent practices and procedures among
and within overseas posts regarding (1) the authority of consular officers
to deny questionable applicants a visa, (2) the role of the visa process in
ensuring national security, and (3) the types of changes in posts’ visa
policies and procedures that are appropriate given the need for heightened
border security. Also, the Departments of State and Justice disagreed on
the evidence needed to deny a visa on terrorism grounds. Most consular
officers at the posts we visited stated that more comprehensive guidance
and training would help them use the visa process as an antiterrorism tool
to detect questionable applicants. In July 2002, the Secretary of State
acknowledged that the visa process needed to be strengthened and
indicated that the State Department is working to identify areas for
improvement.

In addition, the State Department has stressed that it must have the best
interagency information available on persons who are potential security
risks in order to make good visa decisions. The additional data received
from the intelligence and law enforcement community has increased
State’s access to information for use in the visa adjudication process. In
addition, State indicated that it will work with Homeland Security to
establish the systems and procedures that will ensure seamless sharing of
information in the future.

We also found that human capital limitations are a concern, as some
consular sections may need more staff if the number of visa applicants
returns to pre-September 11 levels or if State continues to institute new
security checks for visa applicants. At some posts the demand for visas
combined with increased workload per visa applicant still exceeded
available staff, as evidenced by the waiting time for a visa appointment
and in overtime of consular staff. Moreover, several posts we visited
reported that they could manage their existing workload with current
staffing but would need more staff if they faced an increase in either
security clearance procedures or visa applications.




Page 4                                                         GAO-03-1013T
In our October 2002 report, we concluded that the visa process could be
an important tool to keep potential terrorists from entering the United
States but that weaknesses limited its effectiveness as an antiterrorism
tool. The State Department needed to improve implementation of the visa
process to increase its effectiveness and consistency among posts.

To strengthen the visa process as an antiterrorism tool, we recommended
that the Secretary of State, in consultation with appropriate agencies,

•   establish clear policy on addressing national security concerns through
    the visa process that is balanced with the desire to facilitate legitimate
    travel, provide timely customer service, and manage workloads;

•   develop comprehensive, risk-based guidelines and standards on how
    consular affairs should use the visa process as a screen against
    potential terrorists;

•   reassess staffing for visa operations in light of the current and
    anticipated number of visa applications and, if appropriate, request
    additional human resources to ensure that consular sections have
    adequate staff with necessary skills; and

•   provide consular training courses to improve interview techniques,
    recognize fraudulent documents, understand terrorism trends, and
    better use the name check system.

To address visa issues requiring coordination and actions across several
agencies, we recommended that the Department of Homeland Security
coordinate with appropriate agencies to

•   establish governmentwide guidelines on the level of evidence needed
    to deny a visa on terrorism grounds under provisions of the
    Immigration and Nationality Act;

•   reassess interagency headquarters’ security checks on visa applicants
    to verify that all the checks are necessary and promptly conducted, and
    provide clear guidance to overseas posts and headquarters agencies on
    their roles in conducting these checks;

•   consider reassessing, on an interagency basis, visas issued before the
    implementation of the new security checks;

•   reexamine visa operations on a regular basis to ensure that the
    operations effectively contribute to the overall national strategy for


Page 5                                                           GAO-03-1013T
                             homeland security; and

                         •   ensure that law enforcement and intelligence agencies promptly
                             provide information to the State Department on persons who may pose
                             a security risk and, therefore, should not receive visas.

                         In its response to our recommendations, the Department of State noted
                         that it has acted on or is currently acting on some of the issues we
                         reported and continues to reexamine its visa process. Moreover, in
                         January 2003, the Assistant Secretary for Consular Affairs reported that
                         State plans to use our recommendations as a roadmap for improvements
                         within the Bureau of Consular Affairs and in consular sections around the
                         world. State has also indicated that it is currently undertaking a number of
                         initiatives to review visa policies, staffing, and training needs.
                         Furthermore, State said it is looking at refining various screening
                         programs and will coordinate with other agencies to reassess interagency
                         headquarters’ security checks.


                         In our recent work on visa revocations, we again found weaknesses
New Policies and         caused by the lack of comprehensive policies and coordination between
Procedures Are           agencies. The visa revocation process can be an important tool to prevent
                         potential terrorists from entering the United States. Ideally, information on
Needed to Fill Gaps in   suspected terrorists would reach the Department of State before it decides
the Visa Revocation      to issue a visa; however, there will always be some cases in which the
                         information arrives after the visa has been issued. Revoking a visa can
Process                  mitigate this problem, but only if State notifies the appropriate agencies
                         and if those agencies take appropriate actions to deny entry or investigate
                         persons with a revoked visa. In our June 2003 report, we identified the
                         policies and procedures of several agencies that govern the visa
                         revocation process and determined the effectiveness of the process. We
                         focused on all 240 visas that State revoked for terrorism concerns from
                         September 11, 2001, to December 31, 2002.

                         Our analysis indicated that the U.S. government has no specific written
                         policy on the use of visa revocations as an antiterrorism tool and no
                         written procedures to guide State in notifying relevant agencies of visas
                         that have been revoked on terrorism grounds. State and INS have written
                         procedures that guide some types of visa revocations; however, neither
                         they nor the FBI has written internal procedures for notifying appropriate
                         personnel to take action on visas revoked by the State Department. State
                         and INS officials could articulate their informal policies and procedures
                         for how and what purpose their agencies have used the process to keep


                         Page 6                                                          GAO-03-1013T
terrorists out of the United States, but neither they nor FBI officials had
specific policies or procedures that covered investigating, locating, or
taking appropriate action in cases where the visa holder had already
entered the country.

The lack of formal, written policies and procedures may have contributed
to systemic weaknesses in the visa revocation process that increase the
probability of a suspected terrorist entering or remaining in the United
States. At the time of visa revocation, State should notify its consular
officers at overseas posts, the Department of Homeland Security, and the
FBI. State would have to provide notice of revocation, along with
supporting evidence to the appropriate units within Homeland Security
and the FBI, which would allow them to take appropriate action. In our
review of the 240 visa revocations, we found that (1) appropriate units
within INS and the FBI did not always receive timely notification of the
revocations; (2) lookouts were not consistently posted to the agencies’
watch lists; (3) 30 individuals whose visas were revoked on terrorism
grounds entered the United States and may still remain in the country;4 (4)
INS investigators were not usually notified of individuals with revoked
visas who had entered the United States and therefore did not open
investigations on them; and (5) the FBI did not investigate individuals with
revoked visas unless these individuals were also in TIPOFF. For instance:

•   In a number of cases, notification between State and the appropriate
    units within INS did not take place or was not completed in a timely
    manner. For example, INS officials said they did not receive any notice
    of the revocations from State in 43 of the 240 cases. In another 47
    cases, the INS Lookout Unit received the revocation notice only via a
    cable, which took, on average, 12 days to reach the Unit.

•   In cases in which the INS Lookout Unit had received notification, it
    generally posted information on these revocations in its lookout
    database within 1 day of receiving the notice. In cases where it was not
    notified, it could not post information on these individuals in its
    lookout database, which precluded INS inspectors at ports of entry
    from knowing that these individuals had had their visas revoked.



4
 This number is based on our analysis of data we received from INS as of May 19, 2003. On
May 20 and 21, INS and the FBI, respectively, provided additional information related to
this matter. We were not able to complete analysis of the data prior to the release of our
report due to the nature and volume of the data. The data could show that the actual
number of persons is higher or lower than 30.



Page 7                                                                     GAO-03-1013T
    Moreover, the State Department neglected to enter the revocation
    action for 64 of the 240 cases into its own watch list.

•   GAO’s analysis of INS arrival and departure data indicates that 29
    individuals entered the United States before their visas were revoked
    and may still remain in the country. These data also show that INS
    inspectors admitted at least four other people after the visa revocation,
    one of whom may still remain in the country. However, in testimony on
    June 18, 2003, the FBI said that none of these 30 individuals posed a
    terrorist threat since they were not in TIPOFF, a State-operated
    interagency terrorist watch list that FBI’s Foreign Terrorist Tracking
    Task Force monitors. State Department officials told us during our
    review that State relied on sources of information in addition to
    TIPOFF in making visa revocation decisions. INS inspectors prevented
    at least 14 others from entering the country because the INS watch list
    included information on the revocation action or had another lookout
    on them.

•   INS investigators said they did not open cases on these individuals with
    revoked visas who had entered the United States because their unit had
    not been notified that State had revoked visas because of terrorism
    concerns and that these persons had entered the country. They added
    that, in the 10 cases that were referred to them, they conducted a full
    investigation of possible immigration violations. INS officials said that
    it would be challenging to remove individuals with revoked visas who
    had entered the United States unless they were in violation of their
    immigration status. Homeland Security officials said that the issue of
    whether a visa revocation, after an individual is admitted on that visa,
    has the effect of rendering the individuals out-of-status is unresolved
    legally.

•   FBI officials told us they were not concerned about individuals whose
    visas were revoked because of terrorism concerns unless the
    individuals’ names were in TIPOFF. They said that they had a system in
    place to monitor individuals in TIPOFF who enter the country but that
    they would not investigate individuals who were not in TIPOFF based
    solely on the revocation notice from State. FBI’s position indicates that
    FBI is not taking into account all sources of information that State uses
    in determining if a person may pose a terrorism threat.

We concluded that the visa process could be an important tool to keep
potential terrorists from entering the United States. However, there are
currently major gaps in the notification and investigation processes. One
reason for this is that there are no comprehensive written policies and


Page 8                                                          GAO-03-1013T
                       procedures on how notification of a visa revocation should take place and
                       what agencies should do when they are notified. As a result, there is
                       heightened risk that persons who State believed should not have been
                       issued a visa because of terrorism concerns could enter the country with
                       revoked visas or be allowed to remain after their visas are revoked
                       without undergoing investigation or monitoring.

                       To strengthen the visa revocation process as an antiterrorism tool, we
                       recommended that the Secretary of Homeland Security, in conjunction
                       with the Secretary of State and the Attorney General

                       •   develop specific policies and procedures for the interagency visa
                           revocation process to ensure that notification of visa revocations for
                           suspected terrorists and relevant supporting information is transmitted
                           from State to immigration and law enforcement agencies and their
                           respective inspection and investigation units in a timely manner;

                       •   develop a specific policy on actions that immigration and law
                           enforcement agencies should take to investigate and locate individuals
                           whose visas have been revoked for terrorism concerns and who remain
                           in the United States after revocation; and

                       •   determine if persons with visas revoked on terrorism grounds are in
                           the United States and, if so, whether they pose a security threat.

                       In response to our recommendations, the Department of State testified
                       that the Bureau of Consular Affairs is engaged in an effort to formalize
                       standard operating procedures. The Department of Homeland Security
                       also remarked that it was working to better standardize its procedures.
                       The FBI determined that 47 of the 240 persons with revoked visas were in
                       TIPOFF and therefore could pose a terrorism threat but that it had no
                       indication that any of these individuals were in the country.


                       The Department of State has recently issued guidance to its posts about
Plans to Tighten the   using the visa process as an antiterrorism tool. In May 2003, the Secretary
Visa Process           of State announced that, by August 1, 2003, with a few exceptions, all
                       foreign individuals seeking to visit the United States would be interviewed
                       prior to receiving a visa. The purpose of this guidance is to tighten the visa
                       process to protect U.S. security and to prepare for the eventual
                       fingerprinting of applicants that State must undertake to meet the
                       legislated mandate to include a biometric identifier with issued visas. To
                       comply with the new guidance, some posts may have to make substantial


                       Page 9                                                           GAO-03-1013T
changes in how they handle nonimmigrant applications. State
acknowledges that posts may find that personnel or facility resources are
not adequate to handle the additional number of interviews. Even though
State expects interview backlogs, the Department has indicated that posts
are to implement the interview requirement with existing resources.

It is not certain what impact the new policy will have on visa issuance.
However, education, business, and government officials have expressed
concern that it was already taking too long to issue visas and that without
a commensurate increase in resources to accommodate the heavier
workload that may result from the new requirement, there could be
serious delays for those seeking to visit the United States. In March 2003,
the House Committee on Science held a hearing on “Dealing with Foreign
Students and Scholars in the Age of Terrorism: Visa Backlogs and
Tracking Systems.” In June 2003, the House Committee on Small Business
held a hearing on “The Visa Approval Backlog and its Impact on American
Small Business. “ In both hearings, higher education and business leaders
and agency officials testified on the negative impacts of delays in issuing
visas. The testimonies also highlighted the difficulties of balancing
national security interests with the desire to facilitate travel. At the request
of the House Committee on Science, we are currently examining the
amount of time taken to adjudicate visa applications from foreign science
students and scholars. As part of this work, we will be looking at how the
new interview policy will affect the process.

Before I conclude my statement, I would like to raise some questions that
the subcommittee may want to consider in its oversight role:

•   Have the Departments of State, Homeland Security, and Justice
    reached agreement on how best to communicate information on
    individuals who should not be issued visas and on individuals whose
    visas have been revoked?

•   Have the Departments of State, Homeland Security, and Justice agreed
    on the level of evidence needed to deny and revoke visas?

•   Does the Department of State have adequate number of trained staff
    for visa processing, especially if the number of visa applicants or
    security checks increase?

•   Do the Departments of Homeland Security and Justice agree on
    whether persons who are in the country and have visas that have been
    revoked on terrorism concerns should be investigated and, if so, by


Page 10                                                           GAO-03-1013T
                      which agency?

                   Mr. Chairman, I would like to reiterate our two overarching areas of
                   concern for U.S. visa policy. First, the U.S. government needs to have
                   clear, comprehensive policies governing U.S. visa processes and
                   procedures so that all agencies involved agree on the level of security
                   screening for foreign nationals both at our consulates abroad and at ports
                   of entry. These policies should balance the need for national security with
                   the desire to facilitate legitimate travel to the United States. The
                   Departments of State and Homeland Security should coordinate to
                   establish governmentwide guidelines on the level of evidence needed to
                   deny a visa. There should also be a specific policy for the interagency visa
                   revocation process, including the actions that immigration and law
                   enforcement agencies should take to investigate and locate individuals
                   with revoked visas who have entered the country.

                   The second area of concern is the continued need for coordination and
                   information sharing among agencies. If our intelligence or law
                   enforcement community is concerned that an individual poses a security
                   risk, we have to make sure that this information is communicated to the
                   State Department so that consular officers can deny and, if need be,
                   revoke visas in a timely manner. Similarly, when State revokes a visa for
                   terrorism concerns, we have to make sure that full information on the
                   revocation is communicated to immigration and law enforcement
                   agencies.

                   Mr. Chairman, this concludes my statement. I would be pleased to answer
                   any questions that you or members of the subcommittee may have.


                   For future contacts regarding this testimony, please call Jess Ford at (202)
Contacts and       512-4128. Individuals making key contributions to this testimony included
Acknowledgements   John Brummet, Andrea Miller, Kate Brentzel, Janey Cohen, Lynn Cothern,
                   and Suzanne Dove.




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                   Page 11                                                        GAO-03-1013T
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