Rural Housing Service: Opportunities to Improve Management

Published by the Government Accountability Office on 2003-06-19.

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

                            United States General Accounting Office

GAO                         Testimony
                            Before the Subcommittee on Housing and
                            Community Opportunity, Committee on
                            Financial Services,
                            House of Representatives
For Release on Delivery
Expected at 2:00 p.m. EDT
Thursday, June 19, 2003     RURAL HOUSING
                            Opportunities to Improve
                            Statement of William B. Shear, Acting Director
                            Financial Markets and Community Investment

                                               June 19, 2003

                                               RURAL HOUSING SERVICE
                                               Opportunities to Improve Management
Highlights of GAO-03-911T, a testimony
before the Subcommittee on Housing and
Community Opportunity, Committee on
Financial Services, U.S. House of

Federal housing assistance in rural            Our testimony is based on two reports addressed to this subcommittee—the
America dates back to the 1930s,               September 2000 report on rural housing options and May 2002 report on
when most rural residents worked               multifamily project prepayment and rehabilitation issues. GAO found that
on farms. Without electricity,                 while RHS has helped many rural Americans achieve homeownership and
telephone service, or good roads               has improved the rural rental housing stock, it has been slow to adapt to
connecting residents to population
centers, residents were
                                               changes in the rural housing environment. Also, RHS has failed to adopt the
comparatively isolated and their               tools that could help it manage its housing portfolio more efficiently.
access to credit was generally poor.           Specifically:
These conditions led Congress to
authorize separate housing                     •   Dramatic changes in the rural housing environment since rural housing
assistance for rural residents, to be              programs were first created raise questions as to whether separately
administered by USDA.                              operated rural housing programs are still the best way to ensure the
                                                   availability of decent, affordable rural housing. Overlap in products and
Over time, the quality of the                      services offered by RHS, HUD, and other agencies has created
housing stock has improved and                     opportunities for merging the best features of each. Even without
credit has become more readily                     merging RHS’s programs with HUD’s or those of other agencies, RHS
available in rural areas. Also,
advances in transportation,
                                                   could increase its productivity and lower its overall costs by centralizing
computer technology, and                           its rural delivery structure.
telecommunications have
diminished many of the distinctions            •   RHS does not have a mechanism to prioritize the long-term rehabilitation
between rural and urban areas.                     needs of its multifamily housing portfolio. As a result, RHS cannot be
                                                   sure it is spending limited rehabilitation funds as effectively as possible
These changes call into question                   and cannot tell Congress how much funding it will need in the future.
whether rural housing programs
still need to be maintained
separately from urban housing
programs, and whether RHS is
adapting to change and managing
its resources as efficiently as


To view the full product, click on the link
above. For more information, contact William
B. Shear at (202) 512-4325 or
Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss the management of Rural Housing
Service (RHS) programs. RHS makes a significant investment in affordable
housing for low-income rural Americans through a variety of direct and
guaranteed loan and grant programs. RHS manages a single-family and
multifamily direct loan portfolio of about $28 billion, oversees a program
that guarantees about $3 billion in single-family mortgages annually, and
administers over $700 million in rental assistance payments each year.

This statement is based on two reports addressed to this Subcommittee:
our September 2000 report on rural housing options and our May 2002
report on multifamily project prepayment and rehabilitation issues.1 I will
also briefly discuss the objectives of our ongoing work on RHS’s rental
assistance program. My principle objective today is to present an overview
of the concerns identified in our previous reports that you may want to
consider as you deliberate on how best to improve housing services for
rural Americans.

In summary, while RHS has significantly improved the quality of the
housing stock in rural America and has helped many rural Americans
become homeowners, it has been slow to adapt to changes in the rural
housing environment. In addition, it has not adopted the managerial tools
that are now available that would help it make better use of its housing
portfolio and limited budgetary resources. Specifically:

•   First, dramatic changes in the rural housing environment since rural
    housing programs were first created raise the question of whether
    separately operated rural housing programs are still needed to best
    ensure the availability of decent affordable rural housing. Overlap in
    the products and services offered by RHS, the Department of Housing
    and Urban Development (HUD), and other agencies opened up
    opportunities for merging the best features of each program. But even
    without merging the best features of RHS’s programs with the best
    features of those of HUD or other agencies, RHS could increase its

 Rural Housing: Options for Optimizing the Federal Role in Rural Housing Development
(GAO/RCED-00-241, September 15, 2000) and Multifamily Rural Housing: Prepayment
Potential and Long-Term Rehabilitation Needs for Section 515 Properties (GAO-02-397,
May 10, 2002).

Page 1                                                                 GAO-03-911T
                 productivity and lower its overall costs by centralizing its rural delivery

             •   Second, RHS does not have a mechanism for prioritizing the long-term
                 rehabilitation needs of its multifamily portfolio. As a result, RHS cannot
                 be that sure that it is spending its limited rehabilitation funds as
                 effectively as possible and cannot tell Congress how much funding it
                 will need in the future.

             The government has been providing housing assistance in rural areas since
Background   the 1930s. At that time, most rural residents worked on farms, and rural
             areas were generally poorer than urban areas. For example, in the 1930s
             very few rural homes had electricity or indoor plumbing. Accordingly, the
             Congress authorized housing assistance specifically for rural areas and
             made USDA responsible for administering it. However, rural demographic
             and economic characteristics have greatly changed over time. By the 1970s
             virtually all rural homes had electricity and indoor plumbing. Today, less
             than 2 percent of the nation’s population lives on farms, and advances in
             transportation, technology, and communications have – or have the
             potential to – put rural residents in touch with the rest of the nation. The
             federal role has also evolved, with HUD, the Department of Veterans
             Affairs (VA), and state housing finance agencies becoming significant
             players in administering housing programs.

             Homeownership in the United States is at an all-time high with 68 percent
             of the nation’s households owning their own home. In rural areas, the
             homeownership rate is even higher — 76 percent. However, according to
             the Housing Assistance Council, affordability is the biggest problem facing
             low-income rural households. Rural housing costs have increased and
             income has not kept pace, especially for rural renters who generally have
             lower incomes than owners. As a result, rural renters are more likely to
             have affordability problems and are twice as likely as rural owners to live
             in substandard housing.

             Although the physical condition of rural housing has greatly improved
             over time, it still lags somewhat behind that of urban housing. The most
             severe rural housing quality problems are found farthest from the nation’s
             major cities, and are concentrated in four areas in particular: the
             Mississippi Delta, Appalachia, the Colonias on the Mexican border, and on
             Indian trust land. Minorities in these areas are among the poorest and
             worst housed groups in the nation, with disproportionately high levels of
             inadequate housing conditions. Migrant farm workers in particular have
             difficulty finding affordable, livable housing. The higher incidence of

             Page 2                                                             GAO-03-911T
housing quality problems, particularly in these four areas, offsets many of
the advantages of homeownership, including the ability to use homes as
investments or as collateral for credit.

USDA’s Farmers Home Administration managed rural housing programs
and farm credit programs until reorganization legislation split these
functions in 1994.2 Farm credit programs were then shifted to the new
Farm Service Agency. Housing programs were moved to the newly created
RHS in the new Rural Development mission area which was tasked with
helping improve the economies of rural communities. RHS currently
employs about 5,500 staff to administer its single family, multifamily, and
community facilities programs.

RHS’s homeownership programs provide heavily subsidized direct loans to
households with very low and low incomes, guaranteed loans to
households with low and moderate incomes, and grants and direct loans
to low-income rural residents for housing repairs. Multifamily programs
provide direct and guaranteed loans to developers and nonprofit
organizations for new rental housing that is affordable to low and
moderate income tenants; grants and loans to public and nonprofit
agencies and to individual farmers to build affordable rental housing for
farm workers; housing preservation grants to local governments, nonprofit
organizations, and Native American tribes; and rental assistance subsidies
that are attached to about half the rental units that RHS has financed. In
addition, RHS administers community facilities programs that provide
direct and guaranteed loans and grants to help finance rural community
centers, health care centers, child care facilities, and other public
structures and services.

For fiscal year 2003, RHS received an appropriation of $1.6 billion. Of this
amount, the largest share, $721 million, is for its rental assistance program.
Congress also authorized about $4.2 billion for making or guaranteeing
loans, primarily for guaranteeing single-family loans.3 RHS oversees an

 Federal Crop Insurance Reform and Department of Agriculture Reorganization Act of
1994, Pub. L. 103-354 (1994).
 Authorized dollar amounts represent the expected private-sector loan levels guaranteed by
RHS as well as loans made directly by RHS during the year. Actual appropriations are much
lower because they cover the subsidy cost, not the face value of the loans or guaranteed
loans. The subsidy cost is the estimated long-term cost to the government of a direct or
guaranteed loan calculated on a net present value basis, excluding administrative costs. In
fiscal year 2003, the $4.2 billion in loan authorizations are estimated to require about $37
million in credit subsidy costs.

Page 3                                                                       GAO-03-911T
                                                               outstanding single-family and multifamily direct loan portfolio of about
                                                               $28 billion. Table 1 lists RHS’s programs, briefly describes them, and
                                                               compares the spending for them in fiscal year 1999 with the spending for
                                                               them in fiscal years 1979 and 1994. The table also shows that, although
                                                               RHS’s single and multifamily guaranteed programs are relatively new, by
                                                               1999 RHS had guaranteed more single- and multifamily loans than it made

Table 1: Data on RHS’s Housing Programs

 Dollars in millions
                                                Total               Total       Total
                                              dollars             dollars     dollars                       Number of
                                               spent,              spent,      spent,                     households
                                          fiscal year         fiscal year fiscal year                    helped, fiscal
 RHS housing program                            1979                1994        1999                         year 1999 Type of assistance
                                                    a                   a           a
 Single-Family Housing                      $2,870.0            $1,656.8      $966.9                            15,600 Loans subsidized as low as 1 percent
 Direct Loans (sec. 502)                                                                                                interest
 Single-Family Housing                                             $725.9a        $2,980.0a                     38,600 No money down, no monthly mortgage
 Guaranteed Loans (sec.                                                                                                 insurance loans
 Single-Family Home                               $33.7              $52.7              $46.8                        9,021 Grants for elderly and loans subsidized as
 Repair Grants and Loans                                                                                                   low as 1 percent interest
 (sec. 504)
 Single-Family Housing                              $5.6             $12.8              $25.4                        1,350 Grants to nonprofit and public entities to
 Mutual Self-Help Grants                                                                                                   provide technical assistance
 (sec. 523)
 Multifamily Direct Rural                      $869.5a             $512.4a           $114.3a                         2,181 Loans to developers subsidized as low as 1
 Rental Housing Loans                                                                                                      percent interest
 (sec. 515)
 Multifamily Housing                                                                   $74.8                         2,540 Guaranteed loans for developing moderate-
 Guaranteed Loans (sec.                                                                                                    income apartments
 Multifamily Housing Farm                         $68.8              $56.3              $33.2                           622 Grants and loans subsidized at 1 percent
 Labor Grants and Loans                                                                                                     interest
 (secs. 516/514)
 Multifamily Housing                                                 $23.0                $7.2                      1,800 Grants to nonprofit organizations, local
 Preservation Grants (sec.                                                                                                governments, and Native American tribes,
 533)                                                                                                                     usually leveraged with outside funding
 Multifamily Housing                            $423.0             $446.7             $583.4                       42,000 Rental assistance to about one-half the
 Rental Assistance (sec.                                                                                                  residents in RHS rental and farm labor units
Source: Rural Housing: Options for Optimizing the Federal Role in Rural Housing Development (GAO/RCED-00-241, September 15, 2000). pp. 15-16.
                                                                Dollar amounts represents private-sector loan levels guaranteed by RHS or loans made directly by
                                                               RHS during the year. Actual federal outlays are much lower because they cover the subsidy cost, not
                                                               the face value of the loans or guaranteed loans. The subsidy cost is the estimated long-term cost to
                                                               the government of a direct or guaranteed loan calculated on a net present value basis, excluding
                                                               administrative costs.

                                                               Page 4                                                                                      GAO-03-911T
                       While RHS administers its programs in rural areas, HUD, VA, and state
                       housing finance agencies provide similar programs nationwide, including
                       assistance to households that may be eligible for RHS programs in rural
                       areas. For example, RHS’s single-family loan guarantee program serves
                       moderate-income homebuyers as does the Federal Housing
                       Administration’s (FHA) much larger single-family insurance program. VA
                       and most state housing finance agencies also offer single-family loan
                       programs. In the multifamily area, HUD’s multifamily portfolio is similar to
                       RHS’s multifamily portfolio and HUD’s project-based section 8 program
                       operations parallel RHS’s rental assistance program. Further, in contrast
                       to RHS, HUD has more established systems for assessing the quality of its
                       multifamily portfolio through its Real Estate Assessment Center (REAC)
                       and for restructuring financing and rental assistance for individual
                       properties through its Office of Multifamily Housing Assistance
                       Restructuring (OMHAR).

                       Given the diminished distinctions between rural and urban areas today,
Changes in the Rural   improvements in rural housing quality and access to credit, and RHS’s
Housing Environment    increasing reliance on guaranteed lending and public/private partnerships,
                       our September 2000 report found the federal role in rural housing is at a
Raise Questions        crossroads. We listed arguments for and against fundamentally changing
About the Need to      the programs’ targeting, subsidy levels, and delivery systems, as well as
                       merging RHS’s programs with HUD’s or other agencies’ comparable
Maintain Separately    programs.
Operated Rural
Housing Programs

Arguments For and      A number of arguments have been presented to support continuing RHS’s
Against Separately     housing programs separately from HUD and other agencies or for
Operated Programs      maintaining a separate system for delivering these programs, including the

                       •   Some rural residents need the close supervision offered by RHS local
                           offices because they do not have access to modern
                           telecommunications or other means of obtaining information on
                           affordable housing opportunities;

                       •   Rural borrowers often need a local service office familiar with their
                           situation in the first year of a loan;

                       Page 5                                                           GAO-03-911T
                          •   Rural areas could lose their federal voice in housing matters;

                          •   Rural areas could lose the benefits of the lower rates and terms RHS’s
                              direct and guaranteed loan programs currently offer; and

                          •   HUD and other potential partners have not focused on rural areas.

                          Proponents of arguments for merging RHS’s housing programs with other
                          housing programs or not maintaining a separate system for delivering
                          housing programs in rural areas present a different set of arguments:

                          •   RHS’s field role has changed from primarily originating and servicing
                              direct loans to leveraging deals with partner organizations;

                          •   In some states, local banks, nonprofit organizations, social workers,
                              and other local organizations are doing much of the front-line work
                              with rural households that was previously done by RHS staff;

                          •   The thousands of RHS staff with local contacts could provide a field
                              presence for HUD, and other public partners, applying their leveraging
                              and partnering skills to all communities; and

                          •   RHS and HUD could combine management functions for their
                              multifamily portfolios that are now provided under separate systems.

                          We also noted that without some prodding, the agencies are not likely to
                          examine the benefits and costs of merging as an option. As a first step
                          toward achieving greater efficiency, we suggested that the Congress
                          consider requiring RHS and HUD to explore the potential benefits of
                          merging similar programs, such as the single-family insured lending
                          programs and the multifamily portfolio management programs, taking
                          advantage of the best practices of each and ensuring that targeted
                          populations are not adversely affected.

Actions Taken to Share    Since we issued our report in September 2000, it appears that RHS and
Resources and Expertise   FHA have shared some mutually beneficial practices. First, RHS’s single-
                          family guaranteed program plans to introduce its automated underwriting
                          capabilities through technology that FHA has already developed and has
                          agreed to share with RHS. Second, RHS, FHA, and VA have collaborated in
                          developing common reporting standards for tracking minority and first-
                          time homeownership statistics. Third, we understand that there have been
                          discussions between RHS and HUD staff on developing a model to

                          Page 6                                                           GAO-03-911T
                         restructure RHS section 515 mortgages using techniques that HUD has
                         learned through restructuring similar HUD section 236 mortgages.

Opportunities Exist to   Our September 2000 report also identified a number of actions that RHS
Improve RHS Program      officials and others have identified that could increase the efficiency of
Efficiencies             existing rural housing programs, whether or not they are merged. I will
                         limit my discussion today to two issues that deal with RHS’s field

                         The first issue involves state delivery systems. When state Rural
                         Development offices were given the authority to develop their own
                         program delivery systems as part of the 1994 reorganization, some states
                         did not change, believing that they needed to maintain a county-based
                         structure with a fixed local presence to deliver one-on-one services to
                         potential homeowners. Other states tried innovative, less costly
                         approaches to delivering services, such as consolidating local offices to
                         form district offices and using traveling loan originators for single-family
                         programs. However, RHS has undergone a major shift in mission during
                         the past few years. RHS is still a lending agency like its predecessor, the
                         Farmers Home Administration, but it now emphasizes community
                         development, and uses its federal funding for rural communities to
                         leverage more resources to develop housing, community centers, schools,
                         fire stations, health care centers, child care facilities, and other community
                         service buildings. Some state Rural Development officials we spoke with
                         questioned the efficiency and cost-effectiveness of maintaining a county-
                         based field structure in a streamlined environment where leveraging,
                         rather than one-on-one lending, has become the focus of the work.

                         For example, the shift in emphasis from direct to guaranteed single-family
                         lending moved RHS from relying on a labor intensive loan generation
                         process to one that relies on private lenders to underwrite loans. When we
                         performed our audit work in 2000 we found that Mississippi, which
                         maintains a county-based Rural Development field structure, had more
                         staff and field offices than any other state but the next to lowest
                         productivity as measured by dollar program activity per staff member.
                         Ohio, however, which ranked fifth in overall productivity, operated at less
                         than one-fifth of Mississippi’s cost per staff member. We recognize that it
                         is more difficult to underwrite single-family loans in the Mississippi Delta
                         and other economically depressed areas than in rural areas generally, and
                         Mississippi does have a substantial multifamily portfolio. Nevertheless, the
                         number of field staff in Mississippi far exceeded that in most other states.
                         Ohio, whose loan originators were based in four offices and traveled
                         across the state with laptop computers, ranked seventh in the dollar value

                         Page 7                                                           GAO-03-911T
of single-family guaranteed loans made and fifth in the dollar amount per
staff member of direct loans made. Ohio had also done a good job of
serving all of its counties, while Mississippi had experienced a drop in
business in the counties where it had closed local offices. Ohio’s travel and
equipment costs had increased with the use of traveling loan originators.

The Maine Rural Development office had also fundamentally changed its
operational structure, moving from 28 offices before the reorganization to
15 afterwards, and in 2000 it operated out of 3 district offices. The state
director at the time, who had also headed the Farmers Home
Administration state office in the 1970s, said that he had headed the
agency under both models and believed the centralized system to be much
more effective. He added that under the new structure, staff could no
longer sit in the office waiting for clients to come to them but had to go to
the clients. He also maintained that a centralized structure was better
suited to building the partnerships with real estate agents, banks, and
other financial institutions that had become the core element of RHS’s

The second issue involves the location of field offices. Consistent with its
1994 reorganization legislation, USDA closed or consolidated hundreds of
county offices and established “USDA service centers” with staff
representing farm services, conservation, and rural development
programs. However, the primary goal of the task team that designed the
service centers was to place all the county-based agencies together,
particularly those that dealt directly with farmers and ranchers, to reduce
personnel and overhead expenses by sharing resources. But while the
farm finance functions from the old Farmers Home Administration fit well
into the new county-based Farm Service Agency, the housing finance
functions that moved to the new state Rural Development offices were
never a natural fit in the centers. The decision to collocate Rural
Development and Farm Service offices was based on the fact that Rural
Development had a similar county-based field structure and the
Department needed to fill space in the new service centers. Collocating
Rural Development and Farm Service offices designed to serve farmers
and ranchers makes less sense today, especially in states where Rural
Development operations have been centralized.

Page 8                                                           GAO-03-911T
                        How to deal with the long-term needs of an aging portfolio is the
RHS Does Not Have a     overriding issue for section 515 properties. In the program’s early years, it
Mechanism to            was expected that the original loans would be refinanced before major
                        rehabilitation was needed. However, with prepayment and funding
Prioritize the Long-    restricted, this original expectation has not been realized, and RHS does
Term Rehabilitation     not know the full cost of the long-term rehabilitation needs of the
                        properties it has financed. RHS field staffs perform annual and triennial
Needs of Its            property inspections that identify only current deficiencies rather than the
Multifamily Portfolio   long-term rehabilitation needs of the individual properties. As a result,
                        RHS does not know whether reserve accounts will cover long-term
                        rehabilitation needs. Without a mechanism to prioritize the portfolio’s
                        rehabilitation needs, including a process for ensuring the adequacy of
                        individual property reserve accounts, RHS cannot be sure it is spending its
                        limited rehabilitation funds as effectively as possible and cannot tell
                        Congress how much funding it will need to cover the portfolio’s long-term
                        rehabilitation costs.

                        RHS’s state personnel annually inspect the exterior condition of each
                        property financed under the section 515 program and conduct more
                        detailed inspections every 3 years. However, according to RHS guidelines,
                        the inspections are intended to identify current deficiencies, such as
                        cracks in exterior walls or plumbing problems. Our review of selected
                        inspection documents in state offices we visited confirmed that the
                        inspections are limited to current deficiencies. RHS headquarters and state
                        officials confirmed that the inspection process is not designed to
                        determine and quantify the long-term rehabilitation needs of the individual

                        RHS has not determined to what extent properties’ reserve accounts will
                        be adequate to meet long-term needs. According to RHS representatives,
                        privately owned multifamily rental properties often turn over after just 7 to
                        12 years, and such a change in ownership usually results in rehabilitation
                        by the new owner. However, given the limited turnover and funding
                        constraints, RHS properties primarily rely on reserve accounts for their
                        capital and rehabilitation needs. RHS officials are concerned that the
                        section 515 reserve accounts often are not adequate to fund needed

                        RHS and industry representatives agree that the overriding issue for
                        section 515 properties is how to deal with the long-term needs of an aging
                        portfolio. About 70 percent of the portfolio is more than 15 years old and
                        in need of repair. Since 1999, RHS has allocated about $55 million in
                        rehabilitation funds annually, but owners’ requests for funds to meet

                        Page 9                                                           GAO-03-911T
                    safety and sanitary standards alone have totaled $130 million or more for
                    each of the past few years. RHS headquarters has encouraged its state
                    offices to support individual property owners interested in undertaking
                    capital needs assessments and has amended loan agreements to increase
                    their rental assistance payments as necessary to cover the future capital
                    and rehabilitation needs identified in the assessments. However, with
                    varying emphasis by RHS state offices and limited rental assistance
                    funding targeted for rehabilitation, the assessments have proceeded on an
                    ad hoc basis. As a result, RHS cannot be sure that it is spending these
                    funds as cost-effectively as possible.

                    To better ensure that limited funds are being spent as cost-effectively as
                    possible, we recommended that USDA undertake a comprehensive
                    assessment of the section 515 portfolio’s long-term capital and
                    rehabilitation needs, use the results of the assessment to set priorities for
                    the portfolio’s immediate rehabilitation needs, and develop an estimate for
                    Congress on the amount and types of funding required to deal with the
                    portfolio’s long-term rehabilitation needs. USDA agreed with the
                    recommendation and requested $2 million in the President’s 2003 budget
                    to conduct a comprehensive study. RHS staff drafted a request for
                    proposal that would have contracted out the study, but the Undersecretary
                    for Rural Development chose to lead the study himself. Plans are to
                    develop an inspection and rehabilitation protocol by February 2004 on the
                    basis of an evaluation of a sample of properties.

                    Finally, I would like to mention some work we have begun on the Section
GAO Is Examining    521 rental assistance program. With an annual budget of over $700 million,
Rental Assistance   the rental assistance program is the largest line item appropriation to the
                    Rural Housing Service. This is a property-based subsidy that provides
Program Issues      additional support to units created through the Section 515 multifamily
                    and farm labor housing programs. RHS provides this subsidy to property
                    owners through 5-year contracts. The objectives for our current work are
                    to review (1) how RHS estimates the current and future funding needs of
                    its Section 521 rental assistance program; (2) how RHS allocates the rental
                    assistance; and (3) what internal controls RHS has established to monitor
                    the administration of the rental assistance program. We anticipate
                    releasing a report on our findings in February of 2004.

                    Page 10                                                          GAO-03-911T
                   Mr. Chairman, this concludes my prepared remarks. I would be pleased to
                   answer any questions you or any other members of the Committee may

                   For questions regarding this testimony, please contact William B. Shear on
Contact and        (202) 512-4325 or at shearw@gao.gov, or Andy Finkel on (202) 512-6765 or
Acknowledgements   at finkela@gao.gov. Individuals making key contributions to this testimony
                   included Emily Chalmers, Rafe Ellison, and Katherine Trimble.

                   Page 11                                                       GAO-03-911T
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