Foreign Assistance: USAID Needs to Improve Its Workforce Planning and Operating Expense Accounting

Published by the Government Accountability Office on 2003-09-23.

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

                              United States General Accounting Office

GAO                           Testimony Before the Subcommittee on
                              National Security, Emerging Threats,
                              and International Relations, House
                              Committee on Government Reform

For Release on Delivery
Expected at 10:00 a.m. EDT
Tuesday, September 23, 2003   FOREIGN ASSISTANCE
                              USAID Needs to Improve Its
                              Workforce Planning and
                              Operating Expense
                              Statement of Jess T. Ford, Director
                              International Affairs and Trade

                                                September 23, 2003

                                                FOREIGN ASSISTANCE

                                                USAID Needs to Improve ITS Workforce
Highlights of GAO-03-1171T, a report to         Planning and Operating Expense
Subcommittee on National Security,
Emerging Threats, and International             Accounting
Relations, House Committee on
Government Reform

USAID oversees humanitarian and                 USAID has evolved from an agency in which U.S. direct-hire staff directly
economic assistance—an integral                 implemented development projects to one in which U.S. direct-hire staff oversee
part of the U.S. global security                the activities of contractors and grantees. Since 1992, the number of USAID U.S.
strategy—to more than 160                       direct-hire staff declined by 37 percent, but the number of countries with USAID
countries. GAO recommended in
                                                programs doubled and, over the last 2 years, program funding increased more
1993 that USAID develop a
comprehensive workforce plan;                   than 78 percent. As a result of these and other changes in its workforce and its
however, human capital                          mostly ad-hoc approach to workforce planning, USAID faces several human
management continues to be a                    capital vulnerabilities. For example, attrition of experienced foreign service
high-risk area for the agency.                  officers and inadequate training and mentoring have sometimes led to the
                                                deployment of staff who lack essential skills and experience. The agency also
GAO was asked to testify on how                 lacks a “surge capacity” to respond to evolving foreign policy priorities and
changes in USAID’s workforce over               emerging crises. With fewer and less experienced staff managing more
the past 10 years have affected its             programs in more countries, USAID’s ability to oversee the delivery of foreign
ability to deliver foreign aid, the             assistance is becoming increasingly difficult. USAID has taken steps toward
agency’s progress in implementing               developing a workforce planning and human capital management system that
a strategic workforce planning
                                                should enable the agency to meet its challenges and achieve its mission, but it
system, and whether its reported
operating expenses reflect the full             needs to do more, such as conducting a comprehensive skills assessment and
costs of delivering foreign aid.                including its civil service and contracted employees in its workforce planning

                                                USAID’s reported that operating expenses do not always reflect the full costs of
To help USAID plan for changes in               administering foreign assistance because the agency pays for some support and
its workforce and continue                      oversight activities done by contractors with program funds. As a result, the
operations in an uncertain                      amount of program funds directly benefiting foreign recipients is likely
environment, we recommended                     overstated.
that the USAID Administrator
institutionalize a strategic
                                                USAID U.S. Direct-Hire Presence, Fiscal Years 1992 and 2002
workforce planning and
                                                                                           Fiscal year      Fiscal year   Percentage
management system that takes                    USAID U.S. direct hires                          1992             2002        change
advantage of strategic workforce
                                                 Total number                                  3,163             1,985          (37)
planning principles.
                                                 Number assigned overseas                      1,082               631          (42)
                                                 Number of countries receiving USAID
USAID agreed with our findings                   assistance with U.S. direct-hire
and recommendation and noted it                  presence                                         66                71            7
has recently undertaken some                     Number of countries receiving USAID
efforts to improve management of                 assistance with no U.S. direct-hire
its workforce.                                   presence                                         16                88          450

                                                Source: GAO analysis of USAID data.


To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Jess Ford at
(202) 512-4268 or fordj@gao.gov.
          Mr. Chairman and Members of the Subcommittee:

          I am pleased to be here today to discuss our report on USAID’s workforce
          planning1 and highlight the preliminary findings from our ongoing review
          of USAID’s operating expense account. The workforce report is being
          released today. Humanitarian and economic development assistance is an
          integral part of U.S. global security strategy, particularly as the United
          States seeks to diminish the underlying conditions of poverty and
          corruption that may be linked to instability and terrorism. In fiscal year
          2003, USAID expects to obligate about $13 billion and manage programs in
          about 160 countries. Agency staff often work in difficult environments and
          under evolving program demands. More will be demanded of USAID’s staff
          as they implement large-scale relief and reconstruction programs in
          Afghanistan and Iraq while continuing traditional long-term development
          assistance programs.

          As a result, it is essential that USAID develop a strategic approach to its
          workforce planning so that it can identify and attain the essentials skills it
          needs to accomplish its goals. It is also important that USAID identify and
          report accurate costs on administering its foreign aid programs. My
          statement today will cover these two broad areas.

          I will focus most of my statement on our review of USAID’s workforce
          planning. I will discuss some of USAID’s human capital challenges,
          including its recent efforts to staff missions in Afghanistan and Iraq, and
          the status of its efforts to develop a strategic workforce planning system.
          Regarding USAID’s operating expense account, I will focus on how the
          agency’s reporting of operating expenses does not always capture the full
          cost of administering foreign assistance.

          USAID’s workforce has undergone many changes over the years. For
Summary   example, the number of U.S. direct-hire staff, including foreign service
          officers, has dropped 37 percent from 3,163 in 1992 to 1,985 in December
          2002; and the agency has increasingly relied on personal services and
          institutional contractors to implement its humanitarian and development
          assistance projects and manage the day-to-day activities of overseas

          U.S. General Accounting Office, Foreign Assistance: Strategic Workforce Planning Can
          Help USAID Address Current and Future Challenges, GAO-03-946 (Washington, D.C.:
          Aug. 22, 2003).

          Page 1                                                                 GAO-03-1171T
             missions. At the same time, while the number of countries with USAID
             activities has almost doubled, program funding levels have remained
             relatively level, with significant increases in 2003.

             However, as we reported in 1993 and still find today, USAID has not
             developed a comprehensive, strategic workforce planning system that
             would help it manage these changes. As a result, the agency faces a
             number of human capital challenges, such as difficulties in filling overseas
             positions, a lack of mentoring and training opportunities for new staff, and
             the lack of a “surge capacity” to quickly respond to post-emergency and
             disaster situations. These vulnerabilities are reflected in the agency’s
             difficulties in staffing the missions in Afghanistan and Iraq. As of early
             September, the Kabul mission had 61 vacancies, including 5 for direct-hire
             foreign service officers, and the Baghdad mission had 13 vacancies that
             will most likely be filled by contract staff.

             Recently, and particularly in response to the President’s Management
             Agenda, USAID has taken a number of preliminary steps to determine the
             workforce it needs now and in the future and devise strategies for
             achieving these goals. However, in comparing USAID’s efforts to proven
             principles for strategic workforce planning, more work needs to be done.
             Accordingly, we recommend that USAID develop and implement a
             strategic workforce planning system to help it manage the changes in its
             workforce and overseas environment.

             USAID’s operating expenses are a separate line-item appropriation
             intended to clearly identify the agency’s “cost of doing business.” In fiscal
             year 2003, USAID expects to obligate about $668 million for operating
             expenses. However, USAID’s reported operating expense obligations do
             not always reflect all the costs associated with managing its foreign aid
             program primarily because missions sometimes pay contractors
             performing administrative or oversight duties with program funds.
             Distinguishing between funds spent on operating expenses and funds
             benefiting foreign recipients is not always clear; and, as a result, the
             amount spent for program funds is likely overstated.

             In 1993, we reported that USAID had not adequately managed changes in
Background   its overseas workforce and recommended that USAID develop a
             comprehensive workforce planning system to better identify staffing needs

             Page 2                                                           GAO-03-1171T
and requirements.2 In the mid-1990s, USAID reorganized its activities
around strategic objectives and began reporting in a results-oriented
format but had made little progress in personnel reforms.3 In July 2002, we
reported that USAID could not quickly relocate or hire the staff needed to
implement a large-scale reconstruction and recovery program in Latin
America, and we recommended actions to help improve USAID’s staffing
flexibility for future disaster recovery requirements.4

Studies by several organizations, including GAO, have shown that highly
successful service organizations use strategic management approaches to
prepare their workforces to meet present and future mission requirements.
We define strategic workforce planning as focusing on long-term strategies
for acquiring, developing, and retaining an organization’s workforce and
aligning human capital approaches that are clearly linked to achieving
programmatic goals. Based on work with the Office of Personnel
Management and other entities, we identified strategic workforce planning
principles used by leading organizations. According to these principles, a
strategic workforce planning and management system should (1) involve
senior management, employees, and stakeholders in developing,
communicating, and implementing the workforce plan; (2) determine the
agency’s current critical skills and competencies and those needed to
achieve program results; (3) develop strategies to address gaps in critical
skills and competencies; and (4) monitor and evaluate progress and the
contribution of strategic workforce planning efforts in achieving program

Until the mid-1970s, about two thirds of USAID’s operating expenses were
funded from appropriations to program accounts, and the rest were
funded from a separate administrative expenses account.5 In 1976,
Congress began providing a line-item appropriation for operating expenses

 U.S. General Accounting Office, Foreign Assistance: Status of USAID’s Reforms, GAO-
NSIAD-241-BR (Washington, D.C.: Sept. 24, 1996); Foreign Assistance: USAID’s
Reengineering at Overseas Missions, GAO/NSIAD-97-194 (Washington, D.C.: Sept. 12,
 U.S. General Accounting Office, Foreign Assistance: Disaster Recovery Program
Addressed Intended Purposes, but USAID Needs Greater Flexibility to Improve Its
Response Capability, GAO-02-787 (Washington, D.C.: July 24, 2002).
 The administration’s budget request for fiscal year 1975 identified 11 separate funding
accounts from which administrative expenses would be funded.

Page 3                                                                       GAO-03-1171T
                            separate from USAID’s humanitarian and economic development
                            assistance programs.6 The accompanying Senate report noted that USAID’s
                            “cost of doing business” would be better managed if these funds were
                            separately appropriated.7 Congress authorized USAID’s separate operating
                            expense account the following year.8 USAID’s criteria for determining the
                            expenses to be paid from operating expense funds are based on guidance
                            it has received from Congress as well as its assessment of who benefits
                            from a particular activity—the agency or the intended program recipient.
                            For example, congressional reports in the late 1970s directed USAID to
                            fund the costs of all full-time staff in permanent positions from the
                            operating expense account. 9

                            USAID faces a number of challenges in developing and implementing a
Strategic Workforce         strategic workforce plan. Its overseas missions operate in a changing
Planning Can Help           foreign policy environment often under very difficult conditions. USAID’s
                            workforce, particularly its U.S. direct-hire foreign service officers, has
USAID Address               decreased over the years; but in recent years program dollars and the
Current and Future          number of countries with USAID activities have increased. These factors
                            have combined to produce certain human capital vulnerabilities that have
Challenges                  implications for the agency’s ability to effectively carry out and oversee
                            foreign assistance. A strategic approach to workforce planning and
                            management can help USAID identify the workforce it needs and develop
                            strategies for attaining this workforce that will last throughout successive

USAID Faces Challenges in   Since 1990, USAID has continued to evolve from an agency in which U.S.
Workforce Planning          direct-hire foreign service employees directly implemented development
                            projects to one with a declining number of direct-hire staff who oversee
                            the contractors and grantees carrying out most of its day-to-day activities.
                            As numbers of U.S. direct-hire staff declined, mission directors began
                            relying on other types of employees, primarily foreign national personal
                            services contractors, to manage mission operations and oversee
                            development activities implemented by third parties. In December 2002,

                            P.L. 94-330.
                            S. Rept. 94-704.
                            P.L. 95-88, Sec. 129, 22 U.S.C. 2427.
                            H. Rept. 95-701 and S. Rept. 95-1194.

                            Page 4                                                          GAO-03-1171T
according to USAID’s staffing report, the agency’s workforce totaled 7,741,
including 1,985 U.S. direct-hires.10 Personal services contractors made up
more than two-thirds of USAID’s total workforce, including 4,653 foreign
national contractors. Of the 1,985 U.S. direct-hires, 974 were foreign
service officers, about 65 percent of whom were posted overseas. Other
individuals not directly employed by USAID also perform a wide range of
services in support of the agency’s programs. These individuals include
employees of institutional or services contractors, private voluntary
organizations, and grantees.11

In addition to having reduced the number of U.S. direct hires, USAID now
manages programs in more countries with no USAID direct-hire presence,
and its overseas structure has become more regional. Table 1 illustrates
the changes in USAID’s U.S. direct-hire overseas presence between fiscal
years 1992 and 2002. In fiscal year 2002, USAID managed activities in 88
countries with no U.S. direct-hire presence. According to USAID, in some
cases, activities in these countries are very small and require little
management by USAID staff. However, in 45 of these countries USAID
manages programs of $1 million or more, representing a more significant
burden on the agency. USAID also increasingly provides administrative
and program support to countries from regional service platforms, which
have increased from 2 to 26 between fiscal years 1992 and 2002.12 Program
funding also recently increased about 78 percent—from $7.3 billion in
fiscal year 2001 to about $13 billion in fiscal year 2003.

  All figures exclude the staff of USAID’s Office of the Inspector General, which includes 95
foreign service officers (51 posted overseas) and 76 civil service staff in Washington, D.C.
 In 1990, USAID estimated this extended workforce was approximately 10,000 individuals.
For this report, USAID was unable to provide an estimate.
 Services include legal, executive office, financial/controller, procurement, and program
and project development support services. Services vary among the 26 platforms due to
security, ease of travel, and other local concerns. For example, the regional office in Kenya
provides all services to up to 14 countries, while the Honduras mission simply shares a
contracts officer with Nicaragua.

Page 5                                                                       GAO-03-1171T
Table 1: USAID U.S. Direct-Hire Presence, Fiscal Years 1992 and 2002

    USAID U.S. direct hires                        Fiscal year 1992 Fiscal year 2002                                change
    Total number                                                   3,163a                   1,985b                             (37)
                                                                           a                        b
    Number assigned overseas                                       1,082                       631                             (42)
    Number of countries receiving
    USAID assistance with U.S.
    direct-hire presence                                               66                       71d                               7
    Number of countries receiving
    USAID assistance with no
                                                                           c                        d
    U.S. direct-hire presence                                          16                       88                               450
    USAID’s Monthly Workforce Profile Report, data as of September 30, 1992.
    USAID’s Quarterly Worldwide Staffing Pattern Report, data as of December 31, 2002.
 U.S. General Accounting Office, Foreign Assistance: A Profile of the Agency for International Development, GAO/NSIAD-92-148
(Washington, D.C.: Apr. 3, 1992).
 USAID’s Bureau for Policy and Program Coordination data provided in May 2003. USAID staff cautioned that this information was
gathered in 2002 and may not be up to date.

As a result of the decreases in U.S. direct-hire foreign service staff levels,
increasing program demands, and a mostly ad-hoc approach to workforce
planning, USAID now faces several human capital vulnerabilities. For
example, the attrition of its more experienced foreign service officers, its
difficulties in filling overseas positions, and limited opportunities for
training and mentoring have sometimes led to the deployment of direct-
hire staff who do not have essential skills and experience and the reliance
on contractors to perform many functions. In addition, USAID lacks a
“surge capacity” to enable it to respond quickly to emerging crises and
changing strategic priorities. As a result, according to USAID officials and
a recent overseas staffing assessment, the agency is finding it increasingly
difficult to manage the delivery of foreign assistance.

In addition, USAID works in an overseas environment that presents unique
challenges to workforce planning. Mission officials noted the difficulties in
adhering to a formal workforce plan linked to country strategies in an
uncertain foreign policy environment. For example, following the events
of September 11, 2001, the Middle East and sub-Saharan African missions
we visited—Egypt, Mali, and Senegal—received additional work that was
not anticipated when they developed their country development strategies
and work plans. Also, the mission in Ecuador had been scheduled to close
in fiscal year 2003. However, this decision was reversed due to political
and economic events in Ecuador, including a coup in 2000, the collapse of
the financial system, and rampant inflation. Program funding for Ecuador

Page 6                                                                                                       GAO-03-1171T
tripled from fiscal year 1999 to fiscal year 2000, while staffing was reduced
from 110 to 30 personnel; and the budget for the mission’s operating
expenses was reduced from $2.7 million to $1.37 million. During our field
work, we found that other factors unique to USAID’s overseas work
environment can affect its ability to conduct workforce planning and
attract and retain top staff. These factors vary from country to country and
among regions and include difficulties in attracting staff to hardship posts,
inadequate salaries and benefits for attracting the top host country
professionals, and lengthy clearance processes for locally contracted staff.

USAID’s workforce challenges are illustrated by its difficulties in staffing
hardship posts like Afghanistan and Iraq. As of September 4, 2003,
according to USAID’s new personnel data system, the mission in Kabul
had 42 full-time staff—7 foreign service officers and 35 personal service
contractors, mostly local hires. However, the mission had 61 vacancies,
including 5 vacancies for foreign service officers.13 In Iraq, as of September
15, 2003, the mission had 13 USAID direct-hire staff; 3 additional U.S.
government employees; and about 60 personal services and institutional
contractors. The mission had 13 vacancies that will most likely be filled by
contract staff.

USAID’s human resource office is in its annual bidding process for foreign
service positions. When that process is complete, the office expects to
have a better picture of replacements for current staff in Afghanistan and
Iraq as well as additional placements. According to USAID staff, the
agency is having trouble attracting foreign service officers to these posts
because in-country conditions are difficult and tours are unaccompanied.
USAID’s average staff age is in the late forties, and this age group is
generally attracted to posts that can accommodate families. Both posts are
responsible for huge amounts of foreign aid—in fiscal year 2003 alone,
USAID’s assistance for Afghanistan and Iraq is expected to
total $817 million and $1.6 billion, respectively. USAID faces serious
accountability and quality of life issues as it attempts to manage and
oversee large-scale, expensive reconstruction programs in countries with
difficult conditions and inadequate numbers of both foreign service and
local hire staff.

  The foreign service vacancies included a supervisory program officer, a supervisory
general development officer, two general development officers in the rural sector
development office, and an economic development officer. The vacancies of contractor
staff ranged from professionals with technical program or financial management skills to
numerous support positions, such as secretaries, clerks, drivers, and maintenance workers.

Page 7                                                                    GAO-03-1171T
USAID’s Workforce   In response to the President’s Management Agenda, USAID has taken
Planning Efforts    steps toward developing a comprehensive workforce planning and human
                    capital management system that should enable the agency to meet its
                    challenges and achieve its mission, but progress so far is limited. In
                    evaluating USAID’s efforts in terms of proven strategic workforce planning
                    principles, USAID has more to do. For example:

                    •   The involvement of USAID leadership, employees, and stakeholders in
                        developing and communicating a strategic workforce plan has been
                        mixed. USAID’s human resource office is drafting a human capital
                        strategy, but at the time of our review it had not yet been finalized or
                        approved by such stakeholders as OMB and the Office of Personnel
                        Management. As a result, we cannot comment on whether USAID
                        employees and other stakeholders will have an active role in
                        developing and communicating the agency’s workforce strategies.

                    •   USAID has begun identifying the core competencies its future
                        workforce will need, and a working group is conducting a
                        comprehensive workforce analysis and planning pilot at three
                        headquarters units that will include an analysis of current skills.
                        However, it has not yet conducted a comprehensive assessment of the
                        critical skills and competencies of its current workforce. USAID hopes
                        to have a contractor in place by the end of September, 2003, to assist
                        the working group in identifying critical competencies and devising
                        strategies to close skill gaps. USAID is also in the process of
                        determining the appropriate information technology instrument and
                        methodology that will permit the assessment of its current workforce
                        skills and competencies.

                    •   USAID’s strategies to address critical skill gaps are not comprehensive
                        and have not been based on a critical analysis of current capabilities
                        matched with future requirements. USAID has begun hiring foreign
                        service officers and Presidential Management Interns to replace staff
                        lost through attrition. However, the agency has not completed its civil
                        service recruitment plan and has not yet included personal services
                        contractors—the largest segment of its workforce—in its agencywide
                        workforce analysis and planning efforts. According to USAID human
                        resource staff, the civil service recruitment plan will be completed after
                        conducting the competency analysis for civil service staff.
                    •   USAID has not created a system to monitor and evaluate its progress
                        toward reaching its human capital goals and ensuring that its efforts
                        continue under the leadership of successive administrators.

                    Page 8                                                          GAO-03-1171T
                            •     Because it does not have a comprehensive workforce planning and
                                  management system, USAID cannot ensure that it has the essential
                                  skills needed to carry out its ongoing and future programs. To help
                                  USAID plan for changes in its workforce and continue operations in an
                                  uncertain environment, our report recommends that the USAID
                                  Administrator develop and institutionalize a strategic workforce
                                  planning and management system that takes advantage of strategic
                                  workforce planning principles.

USAID’s Operating           USAID’s operating expense account does not fully reflect the agency’s cost
Expense Account Does        of delivering foreign assistance, primarily because the agency pays for
Not Reflect the Full Cost   some administrative activities done by contractors with program funds. As
                            we noted in our recent report, USAID’s overseas missions have
of Delivering Foreign       increasingly hired personal services contractors to manage USAID’s
Assistance                  development activities due to declining numbers of U.S. direct-hire staff.14
                            According to USAID guidance, contractor salaries and related support can
                            be paid from program funds when the expenses are benefiting a particular
                            program or project. In some cases, however, the duties performed by
                            contractors, especially personal services contractors, are indistinguishable
                            from those done by U.S. direct-hire staff. One senior level USAID program
                            planning officer told us that 10 to 15 percent of program funds may be a
                            more realistic estimate of USAID’s cost of doing business, as opposed to
                            the 8.5 percent average since fiscal year 1995 that we calculated based on
                            our analysis of USAID reported data.

                            •     A recent USAID internal study identified about 160 personal services
                                  contractors who were performing inherently governmental duties,15 but
                                  these costs are not always reported as operating expenses.

                            •     Recent data collection efforts by USAID indicate that the agency will
                                  likely obligate approximately $350 million in program funds for
                                  operating expenses incurred during fiscal year 2003.

                            Because USAID’s cost of doing business is not always separated from its
                            humanitarian and development programs—the original intent behind

                              U.S. Agency for International Development, Report of the Overseas Working Group, May
                            2003. USAID guidance states that salaries and support for nondirect-hire staff performing
                            inherently governmental functions should be funded from the operating expenses account
                            (ADS 601.5.7).

                            Page 9                                                                     GAO-03-1171T
              establishing the separate operating expense account, the amount of
              program funds that directly benefits a foreign recipient is likely overstated.

              Overall, to accomplish our objectives, we analyzed personnel data,
Scope and     workforce planning documents, and obligations data reported by USAID in
Methodology   its annual budget justification documents. We did not verify the accuracy
              of USAID’s reported data. We also interviewed cognizant USAID officials
              representing the agency’s regional, technical, and management bureaus in
              Washington, D.C., and conducted fieldwork at seven overseas missions—
              the Dominican Republic, Ecuador, Egypt, Mali, Peru, Senegal, and the
              West Africa Regional Program in Mali.

              •   To examine USAID’s progress in developing and implementing a
                  strategic workforce planning system, we evaluated the agency’s efforts
                  in terms of workforce planning principles used by leading
                  organizations: ensuring the involvement of agency leadership,
                  employees, and stakeholders; determining current skills and
                  competencies and those needed; implementing strategies to address
                  critical staffing needs; and evaluating progress in achieving human
                  capital goals.

              •   To determine whether USAID’s operating expenses reflect its cost of
                  doing business, we reviewed USAID reports and obligations data and
                  discussed the matter with cognizant officials at USAID, the Department
                  of State, and the Office of Management and Budget. We also reviewed
                  mission staffing reports to determine whether staff were funded from
                  the operating expense account or program funds and discussed staff
                  duties with cognizant mission officials.

              We obtained written comments on a draft of our report on USAID’s
              workforce planning and discussed our preliminary findings from our
              review of USAID’s operating expense account with cognizant USAID
              officials. Overall, USAID agreed with our findings and concurred with our
              recommendation to implement a strategic workforce planning system.

              Our review was conducted between July 2002 and September 2003 in
              accordance with generally accepted government auditing standards.

              Mr. Chairman and Members of the Subcommittee, this concludes my
              prepared statement. I will be happy to answer any questions you may have.

              Page 10                                                         GAO-03-1171T
                  For future contacts regarding this testimony, please call Jess Ford at (202)
Contacts and      512-4268 or Al Huntington at (202) 512-4140. Individuals making key
Acknowledgments   contributions to this testimony included Kimberly Ebner, Jeanette
                  Espinola, Emily Gupta, Rhonda Horried, and Audrey Solis. Mark Dowling,
                  Reid Lowe, and Jose Pena provided technical assistance.

                  Page 11                                                        GAO-03-1171T
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