oversight

Status of Open World Exchange Program's Efforts to Strengthen Financial Management and Performance Measurement

Published by the Government Accountability Office on 2012-09-21.

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

United States Government Accountability Office
Washington, DC 20548



          September 21, 2012


          The Honorable Ben Nelson
          Chairman
          The Honorable John Hoeven
          Ranking Member
          Subcommittee on Legislative Branch
          Committee on Appropriations
          United States Senate

          The Honorable Ander Crenshaw
          Chairman
          The Honorable Michael M. Honda
          Ranking Member
          Subcommittee on Legislative Branch
          Committee on Appropriations
          House of Representatives

          Subject: Status of Open World Exchange Program’s Efforts to Strengthen Financial
          Management and Performance Measurement

          Since its establishment in 1999, 1 the Open World Leadership Center (Open World)
          exchange program has brought nearly 18,000 emerging leaders from Russia and 13 other
          participating countries to the United States to give them firsthand exposure to the U.S.
          economic system and democratic institutions. 2 Open World is governed by a Board of
          Trustees 3 and has seven permanent staff, led by an Executive Director, that work with
          numerous partners to carry out its program. U.S. embassies in participating countries play
          a key role by nominating many individuals for the program, vetting applicants for final
          selection, and processing visas for participants. Open World awards grants to U.S.
          national host organizations that, in conjunction with local partners, develop programs for
          1
           The Russian Leadership Program was established in Pub. L. No. 106-31, § 3011 (May 21, 1999). The
          program was renamed the Open World Leadership Center by Pub. L. No. 108-7, Div. H, §1401 (Feb. 20,
          2003).

          2
           The Library of Congress served as the administrator of the Open World program during the exchange's pilot
          phase. The program is now managed by the Open World Leadership Center, a separate entity within the U.S.
          legislative branch. Although the Center is independent of the Library, it has an interagency agreement with the
          Library to provide financial management and administrative support services to support Open World’s
          operations.

          3
           The Board of Trustees is composed of ten members—a Chairman; the Librarian of Congress; one member of
          Congress appointed by the Speaker of the House of Representatives and two members appointed by the
          President Pro Tempore of the Senate; three other individuals appointed by the Librarian of Congress; and the
          two Chairs of the Appropriations Subcommittees on Legislative Branch.


                                                                 GAO-12-1004R Open World Leadership Center
participants and arrange home stays. Program participants stay in the homes of
American host volunteers.

In 2003, Congress asked us to review Open World’s progress toward achieving its overall
purpose and whether the program had appropriate financial management and
accountability mechanisms in place. 4 As a result of our review, we issued a report in 2004
that contained eight recommendations aimed at enhancing Open World’s financial
management and performance measurement. 5 In 2011, Congress directed us to
determine the actions the program had taken to implement our 2004 recommendations. 6
In response to the mandate, we reviewed (1) Open World’s actions to address our
recommendations on financial management and internal controls, and how the program’s
current financial management controls compare with leading practices for accountability;
and (2) the program’s actions to address our recommendations on performance
measurement and how its mechanisms for performance measurement compare with
leading practices.

Scope and Methodology

To examine Open World’s actions to address our recommendations on financial
management and how the program’s current financial management controls compare with
leading practices for accountability, we met with Open World officials and reviewed
relevant policies and procedures. We compared selected financial management controls
to GAO’s Standards for Internal Control in the Federal Government 7 and the Internal
Control Management and Evaluation Tool. 8 Our assessment focused on whether these
policies and procedures were designed to provide an adequate framework for internal
controls. We did not conduct an audit of Open World’s financial reports or individual
transactions.

To examine Open World’s actions to address our recommendations on performance
measurement and how its mechanisms for performance measurement compare with
leading practices, we reviewed the performance measures in Open World’s strategic plan
and compared them to GAO’s Key Attributes of Successful Performance Measures. 9 We
also reviewed Open World’s organizational structure, operational policies and procedures,
and program documentation. In addition, we met with Open World’s Executive Director,

4
 In 2003, Congress expanded the scope of the program to include cultural leaders in Russia and extended
eligibility to 11 countries of the Newly Independent States of the former Soviet Union and 3 Baltic states.
5
 GAO, International Exchange Programs: Open World Achieves Broad Participation; Enhanced Planning and
Accountability Could Strengthen Program, GAO-04-436 (Washington, D.C.: Mar. 17, 2004).

6
See House Conference Report 112-331.

7
 GAO, Standards for Internal Control in the Federal Government, AIMD-00-21.3.1 (Washington, D.C.: Nov. 1,
1999).

8
GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, D.C.: Aug. 1, 2001).

9
 GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance Measures, GAO-
03-143 (Washington, D.C.: Nov. 22, 2002). As part of this report, we developed key attributes of successful
performance measures for results-based organizations. We have since used these attributes to assess
performance measures of entities other than the IRS.


Page 2                                                   GAO-12-1004R Open World Leadership Center
management, and other staff; State Department officials; and international exchange
Interagency Working Group (IAWG) officials.

We conducted this performance audit from May 2012 to September 2012 in accordance
with generally accepted government auditing standards. Those standards require that we
plan and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit objectives. We
believe that the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

Results in Brief

Since our 2004 report, Open World has taken a number of steps to address our
recommendations on financial management controls, and has also generally followed
leading financial management practices. For example, to address our recommendations,
Open World (1) contracted with an independent public accountant to perform an
assessment of its ability to be audited; (2) developed Financial Procedures and Directives
guidance that covers key activities such as grants; (3) developed the Grant Procedures
document, which enhanced accountability for its grantees; (4) submitted its financial
statements to an annual financial statement audit since fiscal year 2005, resulting in clean
audit opinions since fiscal year 2006; (5) established an audit committee, comprised of
independent members that have financial and programmatic knowledge, which also
reviews management’s annual assessment of its internal controls; and (6) developed
guidelines for grantees to calculate and report the estimated value of U.S. volunteers’
contributed services, and also disclosed this value as part of its annual budget
justification. Open World’s financial management controls also generally followed leading
practices for financial accountability. For example, Open World (1) developed appropriate
policies, procedures, techniques, and mechanisms with respect to each of the agency’s
activities; (2) developed guidance aimed at ensuring that transactions are properly
documented, approved, and processed; and (3) performed ongoing monitoring of its
transactions through annual financial audits since fiscal year 2005. Open World has plans
to further enhance its financial management controls to better align its grant monitoring
with leading practices by performing reviews of grantees’ compliance with grant
agreement guidelines.

Open World has taken a number of steps that address our 2004 recommendations and
reflect several leading practices for performance measurement. For example, to address
our recommendations, Open World established its first strategic plan covering fiscal years
2007-2011 and later issued an updated plan covering fiscal years 2012-2016. In addition,
it (1) presented to the Board the first comprehensive quantitative analysis of annual
achievement on each of its performance measures for fiscal years 2007 through 2011;
(2) implemented periodic reports from program participants, hosts, and contractors that
provide standardized information about program performance and results; and (3) is
currently converting its performance databases to a web-based system intended to reduce
time needed to report on program feedback and performance. As of August 2012, Open
World’s efforts were generally consistent with several of the key attributes that GAO has
identified for successful performance measures. For example, most performance
measures in Open World’s strategic plan were clearly stated and could allow for objective
data to be collected. Although Open World had some intended outcomes that did not link
to corresponding measures or program activities that contribute to achieving these
outcomes, Open World officials stated in September 2012 that they revised their


Page 3                                         GAO-12-1004R Open World Leadership Center
performance measures to ensure that they directly link the activities of the program to the
objectives in their strategic plan. In June 2012, Open World set numerical targets that
could allow management to more systematically track its performance against program
goals, but Open World had not yet developed an agency performance plan or released
annual updates comparing its performance targets to actual results. During August 2012
discussions with us, Open World officials agreed to take the additional steps of preparing
an annual performance plan and reporting annual updates publicly to further align their
performance measurement efforts with leading practices. In September 2012, Open World
officials stated that they had finalized an annual performance plan.

Background
Congress created the precursor of Open World, the Russian Leadership Program, as a
pilot project within the Library of Congress in 1999 and, about 2 years later, established it
as an independent, permanent entity. The program’s founders envisioned it as a way to
promote mutual understanding between the United States and Russia and positively
influence Russia’s development following the collapse of the former Soviet Union. The
program aimed to expose emerging political leaders at all levels of government in Russia
to the American economic system and democratic institutions through visits to
communities across the United States, allowing participants to see how Americans from
all walks of life conduct their business and professions and their private, social, and
cultural lives. As envisioned by its founders, the overall mission of the program was to
develop a cadre of people in Russia committed to democratic and free market principles
by reaching out to emerging leaders, similar to the way that young German leaders were
targeted by the Marshall Plan after World War II. In 2003, Congress changed the
program’s name to the Open World Leadership Center, expanded its scope to include
cultural leaders from Russia, and extended eligibility to additional countries in the Newly
Independent States of the former Soviet Union and the Baltic states. 10

Open World has awarded hosting grants to 61 organizations headquartered in 25 states
and the District of Columbia. By the end of 2011, about 800 local host organizations—
including universities, community colleges, service organizations, sister-city associations,
local government agencies, and international visitor councils and other nonprofit
organizations in all 50 states and the District of Columbia—had conducted exchanges for
Open World. About 6,700 American families have hosted participants in 2,000
communities. In addition, Open World has contracts with organizations that provide
logistical support and coordinate alumni activities. In fiscal year 2012, Open World’s
appropriation was $10 million. In addition, Open World is authorized to seek and accept
private donations.

Open World Has Taken Actions to Address Our Recommendations on Financial
Management Controls and Has Generally Followed Leading Practices

Open World Has Taken Actions to Strengthen Financial Management

Since GAO reported in 2004, Open World has taken a number of steps to address our six
recommendations regarding its financial management and internal controls, as outlined in

10
  The expansion of Open World extended eligibility to the remaining 11 countries of the Newly Independent
States of the former Soviet Union and 3 in the Baltic states. The countries that have participated in Open
World exchanges are Armenia, Azerbaijan, Belarus, Georgia, Kazakhstan, Kyrgyzstan, Lithuania, Moldova,
Russia, Serbia, Tajikistan, Turkmenistan, Ukraine, and Uzbekistan.


Page 4                                                  GAO-12-1004R Open World Leadership Center
table 1. Specifically, Open World (1) contracted with an independent public accountant to
perform an auditability assessment; (2) developed Financial Procedures and Directives
guidance; (3) developed the Grant Procedures document; (4) submitted its financial
statements to an annual financial statement audit since fiscal year 2005, resulting in clean
audit opinions since fiscal year 2006; (5) established an audit committee, comprised of
independent members that have financial and programmatic knowledge, which also
reviews management’s annual assessment of its internal controls; and (6) developed
guidelines for grantees to calculate and report the value of U.S. volunteers’ contributed
services, and also disclosed this value as part of its annual budget justification.

Table 1: Actions Taken by Open World to Address GAO’s 2004 Financial Management and Internal
Control Recommendations

2004 GAO recommendations on financial                   Open World actions to address recommendations
management and internal controls
Assess whether the current procedures provide           •   Contracted with an independent public
adequate internal control over expenditures and             accountant to perform an auditability
grantee oversight                                           assessment, which concluded that Open World’s
                                                            financial reporting structure was sufficient to allow
                                                            a full-scope audit and provided recommendations
                                                            to improve policies and procedures

                                                        •   Submitted its financial statements since 2005 to
                                                            an annual financial statement audit, which covers
                                                            internal controls over expenditures

                                                        •   Created an audit committee in 2008 that is
                                                            tasked with reviewing management’s annual
                                                            assessment of its internal controls

Develop and implement written, management-              •   Developed Financial Procedures and Directives
approved policies, procedures, and internal controls        guidance, which documented internal controls
for Open World’s resources and expenditures                 through policies and procedures for areas such
                                                            as procurement of supplies and expert services,
                                                            credit card purchases, reimbursements, travel,
                                                            training, and grants administration and closure

                                                        •   Communicated and maintained this guidance on
                                                            an internal shared drive for easy access by its
                                                            employees

                                                        •   Developed a vulnerability assessment and
                                                            internal control review tools to strengthen its
                                                            ability to monitor internal controls
Develop and implement controls and requirements         •   Developed, in 2005, the Grant Procedures
for grantees to provide accountability for grant            document, which provides grantees with
expenditures to ensure that funds are spent for their       information on the grants process, allowable
intended purposes                                           expenses, and procedures that grantees must
                                                            follow to be eligible for grants and to ensure
                                                            accountability

                                                        •   Included in this document specific guidance for
                                                            the grantees’ budget calculation and for
                                                            documentation that needs to be provided to Open
                                                            World during grant closing procedures

                                                        •   Required grantees to file a quarterly financial
                                                            report that identifies the amount of grant funds
                                                            expended and unobligated



Page 5                                                  GAO-12-1004R Open World Leadership Center
                                                        •   Required grantees to submit a variance report
                                                            identifying differences between actual expenses
                                                            and the approved grant budget

                                                        •   Prohibited variances of greater than 10 percent
                                                            without approval by Open World in advance

                                                        •   Required each grantee to submit either an
                                                            opinion from its most recent financial statement
                                                            audit or detailed receipts to support its grant
                                                            expenses

                                                        •   Updated the Grant Procedures document
                                                            annually and posted it to Open World’s website
                                                            after approval

Develop and implement plans for routinely preparing     •   Prepared and submitted its financial statements
financial statements that are annually subject to an        to an annual financial statement audit since fiscal
independent audit                                           year 2005

                                                                •     Since 2006, these audits have resulted
                                                                      in clean audit opinions with no material
                                                                      weaknesses or significant deficiencies in
                                                                      internal controls, and no instances of
                                                                      noncompliance with laws and
                                                                      regulations
Consider establishing an audit committee or financial   •   Established an audit committee in 2008 that
management advisory committee to provide the                consisted of three members and adopted a
Board of Trustees and management with                       charter in 2009
independent advice on financial management,
accountability, and internal control issues                     •    Audit committee meets at least annually
                                                                     to discuss internal controls over financial
                                                                     management and communicate with the
                                                                     independent public accountant and the
                                                                     Library of Congress’s Inspector General

                                                                •    Audit committee reports the results of its
                                                                     reviews of internal controls and the
                                                                     financial statement audit to the Board of
                                                                     Trustees

                                                                •     Audit committee currently consists of
                                                                      three members who have the financial
                                                                      and programmatic knowledge necessary
                                                                      to read and understand audit reports
                                                                      and help oversee Open World’s
                                                                      activities. For example, two members
                                                                      have financial management experience
                                                                      and one member has grants-related
                                                                      experience.
Estimate and disclose the value of contributed          •   Developed guidelines for grantees to assess the
services from U.S. volunteers to better reflect the         value of the contributed services in each of their
total scope of the program                                  budget category estimates

                                                        •   Required grantees to report the value of
                                                            contributed services annually

                                                        •   Disclosed the estimated value of contributed
                                                            services in Open World’s Annual Report and
                                                            Budget Justifications
Source: GAO.




Page 6                                                  GAO-12-1004R Open World Leadership Center
Open World Follows Leading Financial Management Practices and Plans to Enhance
Grantee Monitoring

Open World’s financial management controls generally follow leading practices for
financial accountability. For example, Open World has (1) developed appropriate policies,
procedures, techniques, and mechanisms with respect to each of the agency’s activities,
such as grants; (2) developed guidance aimed at ensuring that transactions are properly
documented, approved, and processed; (3) performed ongoing monitoring of its
transactions through annual financial audits; and (4) established a three-member
independent audit committee with relevant financial management experience to assist in
oversight of financial management and internal controls. GAO’s Standards for Internal
Control in the Federal Government state that internal controls should generally be
designed to assure that ongoing monitoring occurs in the course of normal operations. In
addition, GAO’s Internal Control Management and Evaluation Tool states that appropriate
policies and procedures should exist with respect to each of the agency’s activities. Open
World’s Financial Procedures and Directives includes grant procedures for advance
payments, reimbursements, general management, and grant closing. However, we
advised Open World that additional procedures could further enhance Open World’s
ability to determine its grantees’ compliance with requirements outlined in its Grant
Procedures, such as the proper use of funds. Such enhanced policies and procedures to
monitor and evaluate the grantees’ compliance with grant requirements could further
increase accountability and help ensure that funds are being used for their intended
purpose. These procedures are important to Open World because grant obligations
totaled approximately $3.4 million, or 28 percent of its $12.3 million total obligations in
fiscal year 2011. Open World officials agreed that enhancements can be made to further
assure accountability and that they are assessing the best way to provide assurance that
the expenditures of grantees are in compliance with grant agreements. Open World
officials noted that they would develop a process that is risk-based and also noted a
number of activities to augment Open World’s effectiveness in this area. For example,
they cited plans to (1) obtain signed affidavits from the heads of local hosting
organizations, attesting that funds were spent in accordance with the requirements of the
grants; (2) obtain signed statements of assurances completed by each grantee; (3) obtain
summary reports of planned versus actual grant expenditures; (4) obtain reports
evaluating hosting activities; and (5) perform sampling of grant expenditures to monitor
and assess grantees’ compliance with fund expenditure requirements.

Open World Has Taken Steps to Address Our Recommendations on Performance
Measurement, and These Actions Reflect Several Leading Practices

Open World Has Taken Actions to Strengthen Performance Measurement

Since our 2004 report, Open World has taken steps to improve its efforts to measure
performance. In addition, Open World has taken a number of steps to strengthen its
mechanisms for collecting data and reporting on performance, such as reporting to its
Board the results achieved for each of its performance measures and requiring periodic
reports on performance from program stakeholders (see table 2).




Page 7                                         GAO-12-1004R Open World Leadership Center
Table 2: Actions Taken by Open World to Address GAO’s 2004 Performance Measurement
Recommendations
2004 GAO recommendations on performance                 Open World actions to address recommendations
measurement
Establish strategic and performance plans that          •     Established its first Strategic Plan for Fiscal Years
articulate Open World’s direction and set                     2007-2011. The plan contained:
measureable goals and indicators
                                                                  o    mission statement,
                                                                  o    goals, and
                                                                  o    performance indicators
                                                        •     Developed its second Strategic Plan for Fiscal
                                                              Years 2012-2016, which also includes the
                                                              elements that we recommended
Strengthen the program’s mechanisms for collecting      •     Presented at the February 2012 Board meeting
data and reporting on program performance                     Open World’s first comprehensive quantitative
                                                              analysis of annual achievement on each of its
                                                              performance measures for fiscal years 2007 to
                                                              2011
                                                        •     Implemented periodic reports from program hosts,
                                                              facilitators, and contractors to ensure that
                                                              management receives standardized information
                                                              and feedback about program performance and
                                                              results
                                                        •     Launched efforts to convert Open World’s
                                                              performance databases to a web-based system
                                                              intended to reduce time needed to find, utilize,
                                                              and report on program feedback and performance
                                                              data
                                                        •     Established targets for each performance
                                                              measure in its Strategic Plan for Fiscal Years
                                                              2012-2016
Source: GAO.




Open World’s Performance Measurement Efforts Are Generally Consistent with Several
Leading Practices

Open World’s efforts to measure performance are generally consistent with several
leading practices, and it has plans to further strengthen its performance measurement
mechanisms to better align them with leading practices. Although not required for Open
World, the Government Performance and Results Act’s (GPRA) requirement for executive
branch agencies to establish measures of performance serves as a leading practice for all
federal agencies. 11

In a previous report, we identified nine key attributes of successful performance measures
and used them to assess the indicators agencies use to measure their performance. 12 As

11
 Government Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285, as amended by
GPRA Modernization Act of 2010, Pub. L. No. 111-352, 124 Stat. 3866 (2011).
12
   GAO-03-143. The key attributes of successful performance measures are (1) objectivity, (2) clarity, (3)
linkage between measure and agencywide goals, (4) measurable target, (5) reliability, (6) covering core
program activities, (7) limited overlap, (8) balance, and (9) covering governmentwide priorities.



Page 8                                                      GAO-12-1004R Open World Leadership Center
of August 2012, Open World’s performance measures were consistent with several of
these key attributes, and Open World had plans to further align them with the attributes.
For example, most performance measures in Open World’s Strategic Plan for 2012-2016
were clearly stated. All of the 23 measures clearly required either a number, percentage,
or amount. In addition, Open World’s measures allowed the collection of objective data.
For example, the measures focused on objective counts, such as number of projects
undertaken, number of partnerships sustained or formed, and the value of cost-shares as
a percentage of the total appropriation. However, Open World’s strategic plan included
some intended outcomes that did not link to corresponding measures or program activities
that contribute to achieving these outcomes. One such intended outcome was that the
“nominations process is transparent and produces delegates with superior professional
qualifications.” Without a corresponding performance measure, management may be less
able to gauge progress and determine whether those outcomes have actually been
achieved. When we discussed this finding with Open World officials in August 2012, they
stated that they planned to revise their performance measures to ensure that the
measures directly link the activities of the program to the objectives in their strategic plan.
Commenting on a draft of this report in September 2012, Open World officials stated that
they had revised their performance measures to address this issue. 13

Open World has recently taken steps to report more systematically on its performance
and has plans to make further improvements to reflect leading practices. We have
previously reported that performance data can have real value only if they are used to
identify the gap between an organization’s actual performance level and the performance
level it has identified as its goal. 14 Once the performance gaps are identified, managers
can determine where to target their resources to improve overall mission accomplishment.
A leading practice in GPRA directs agencies to release an annual performance update
that compares actual performance with goals. Before 2012, Open World did not
systematically report the results for its performance measures. 15 In February 2012, Open
World shared for the first time with its Board annual numerical results for each of the
indicators in its Strategic Plan for Fiscal Years 2007-2011, but it had not previously
reported annual performance goals for those years against which it could compare the
actual results. In June 2012, Open World finalized both 2011 baseline values for each of
its performance measures and annual targets for fiscal years 2012 through 2016 that
would allow management to systematically track future performance against program
goals. When we shared our preliminary findings with Open World officials in August 2012,
Open World did not have a performance plan that explained the basis for comparing
results with goals. The officials stated that they planned to use their newly established
targets to develop an agency performance plan and publicly report on its annual
performance against such goals. They stated that these actions would better align their
performance measurement efforts with leading practices. Commenting on a draft of this



13
 Open World revised its performance measures after we completed our audit work. We therefore did not
assess the revised measures.

14
 GAO, Executive Guide: Effectively Implementing the Government Performance and Results Act, GAO/GGD-
96-118 (Washington, D.C.: June 1996).

15
  Open World’s annual reports contain anecdotal results of program activities, but do not systematically
assess results achieved for each of its performance measures.




Page 9                                                   GAO-12-1004R Open World Leadership Center
report in September 2012, Open World officials stated that they had finalized an annual
performance plan for 2012. 16

Agency Comments

Open World provided written comments on a draft of this report (see Enclosure I). Open
World generally agreed with our findings. Regarding financial management, Open World
stated that the enhancements it will undertake as a result of our observations will
strengthen its financial oversight of its grants. Regarding performance measurement,
Open World stated that our report provides some useful suggestions on linking strategic
plan objectives to measures of performance. Open World also reviewed the draft report
for technical accuracy. Its technical comments have been incorporated into this report, as
appropriate.
                                             -----

We are sending copies of this report to appropriate congressional committees and the
Executive Director of the Open World Leadership Center. In addition, this report will be
available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions concerning this report, please contact Michael
Courts at (202) 512-8980, or courtsm@gao.gov, or Beryl H. Davis at (202) 512-2623, or
davisbh@gao.gov. Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff who made major
contributions to this report are listed in enclosure II.




Michael J. Courts
Acting Director
International Affairs and Trade




16
 Open World finalized its new performance plan after we completed our audit work. We therefore did not
assess the new performance plan.


Page 10                                                 GAO-12-1004R Open World Leadership Center
Enclosure I


              Comments from the Open World Leadership Center




Page 11                                GAO-12-1004R Open World Leadership Center
Enclosure I




Page 12       GAO-12-1004R Open World Leadership Center
Enclosure II


                    GAO Contacts and Staff Acknowledgments


GAO Contacts
Michael J. Courts, (202) 512-8980
Beryl H. Davis, (202) 512-2623


Staff Acknowledgments
In addition to the persons named above, Jeffrey Baldwin-Bott, Elizabeth Curda, Martin De
Alteriis, Karen Deans, Cole Haase, David Hancock, James Healy, Joy Labez, Grace Lui,
and Elizabeth Martinez made key contributions to this report.




(320908)



Page 13                                       GAO-12-1004R Open World Leadership Center
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