oversight

Critical Infrastructure Protection: Summary of DHS Actions to Better Manage Its Chemical Security Program

Published by the Government Accountability Office on 2012-09-20.

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

                               United States Government Accountability Office

GAO                            Testimony
                               Before the Subcommittee on Homeland
                               Security, Committee on Appropriations,
                               House of Representatives

For Release on Delivery
Expected at 10:00 a.m. EDT
Thursday, September 20, 2012
                               CRITICAL
                               INFRASTRUCTURE
                               PROTECTION
                               Summary of DHS Actions to
                               Better Manage Its Chemical
                               Security Program
                               Statement of Stephen L. Caldwell, Director
                               Homeland Security and Justice




GAO-12-1044T
                                               September 2012

                                               CRITICAL INFRASTRUCTURE PROTECTION
                                               Summary of DHS Actions to Better Manage Its
                                               Chemical Security Program
Highlights of GAO-12-1044T, a testimony
before the Subcommittee on Homeland
Security, Committee on Appropriations, House
of Representatives.



Why GAO Did This Study                         What GAO Found
The events of September 11, 2001,              The November 2011 memorandum that discussed the management of the
triggered a national re-examination of         Chemical Facility Anti-Terrorism Standards (CFATS) program was prepared
the security of facilities that use or         based primarily on the observations of the former Director of the Department of
store hazardous chemicals in                   Homeland Security’s (DHS) Infrastructure Security Compliance Division (ISCD),
quantities that, in the event of a             a division of the Office of Infrastructure Protection (IP) within the National
terrorist attack, could put large              Protection and Programs Directorate (NPPD). The memorandum was intended to
numbers of Americans at risk of                highlight various challenges that have hindered ISCD efforts to implement the
serious injury or death. As required by        CFATS program. According to the former Director, the challenges facing ISCD
statute, DHS issued regulations that
                                               included not having a fully developed direction and plan for implementing the
establish standards for the security of
                                               program, hiring staff without establishing need, and inconsistent ISCD
high-risk chemical facilities. DHS
established the CFATS program to
                                               leadership—factors that the Director believed place the CFATS program at risk.
assess the risk posed by these                 These challenges centered on three main areas: (1) human capital issues,
facilities and inspect them to ensure          including problems hiring, training, and managing ISCD staff; (2) mission issues,
compliance with DHS standards. ISCD,           including problems reviewing facility plans to mitigate security vulnerabilities; and
a division of IP, manages the program.         (3) administrative issues, including concerns about NPPD and IP not supporting
A November 2011 internal ISCD                  ISCD’s management and administrative functions.
memorandum, prepared by ISCD                   ISCD has begun to take various actions intended to address the issues identified
senior managers, expressed concerns
                                               in the ISCD memorandum and has developed a 94-item action plan to track its
about the management of the program.
                                               progress. According to ISCD managers, the plan appears to be a catalyst for
This statement addresses (1) how the
memorandum was developed and any               addressing some of the long-standing issues the memorandum identified. As of
challenges identified, (2) what actions        June 2012, ISCD reported that 40 percent (38 of 94) of the items in the plan had
are being taken in response to any             been completed. These include requiring ISCD managers to meet with staff to
challenges identified, and (3) the             involve them in addressing challenges, clarifying priorities, and changing ISCD’s
extent to which ISCD’s proposed                culture; and developing a proposal to establish a quality control function over
solutions require collaboration with           compliance activities. The remaining 60 percent (56 of 94) that were in progress
NPPD or IP. GAO’s comments are                 include those requiring longer-term efforts—i.e., streamlining the process for
based on recently completed work               reviewing facility security plans and developing facility inspection processes;
analyzing the memorandum and                   those requiring completion of other items in the plan; or those awaiting action by
related actions. GAO reviewed laws,            others, such as approvals by ISCD leadership. ISCD appears to be heading in
regulations, DHS’s internal                    the right direction, but it is too early to tell if individual items are having their
memorandum and action plans, and               desired effect because ISCD is in the early stages of implementing them and has
related documents, and interviewed             not yet established performance measures to assess results.
DHS officials.
                                               According to ISCD officials, almost half of the action items included in the June
In a July 2012 report, GAO                     2012 action plan require ISCD collaboration with or action by NPPD and IP. The
recommended that ISCD explore                  ISCD memorandum stated that IP and NPPD did not provide the support needed
opportunities to develop measures,             to manage the CFATS program when the program was first under development.
where practical, to determine where
                                               ISCD, IP, and NPPD officials confirmed that IP and NPPD are now providing
actual performance deviates from
                                               needed support and stated that the action plan prompted them to work together
expected results. ISCD concurred and
has taken action to address the                to address the various human capital and administrative issues identified.
recommendation.




View GAO-12-1044T. For more information,
contact Stephen L. Caldwell, (202) 512-9610,
CaldwellS@gao.gov.



                                                                                        United States Government Accountability Office
Chairman Aderholt, Ranking Member Price, and Members of the
Subcommittee:

I am pleased to be here today to discuss the Department of Homeland
Security’s (DHS) efforts to address the various challenges in
implementing and managing the Chemical Facility Anti-Terrorism
Standards (CFATS) program. My statement today summarizes the
testimony I delivered on July 26, 2012, before this Subcommittee. 1 The
events of September 11, 2001, triggered a national re-examination of the
security of facilities that use or store hazardous chemicals in quantities
that, in the event of a terrorist attack, could put large numbers of
Americans at risk of serious injury or death. Chemicals held at these
facilities can be used to cause harm to surrounding populations during
terrorist attacks; can be stolen and used as chemical weapons or as
precursors (the ingredients for making chemical weapons); or stolen and
used to build an improvised explosive device. To mitigate this risk, the
DHS appropriations act for fiscal year 2007 2 required DHS to issue
regulations to establish risk-based performance standards for securing
high-risk chemical facilities, among other things. 3 DHS established the
CFATS program to assess the risk, if any, posed by chemical facilities;
place high-risk facilities in one of four risk-based tiers; require high-risk
facilities to develop security plans; review these plans; and inspect the
facilities to ensure compliance with the regulatory requirements. DHS’s
National Protection and Programs Directorate (NPPD) is responsible for
the CFATS program. Within NPPD, the Infrastructure Security
Compliance Division (ISCD), a division of the Office of Infrastructure
Protection (IP), manages the program.

A November 2011, internal ISCD memorandum, prepared by ISCD’s
former Director in consultation with the former Deputy Director 4 and


1
 GAO, Critical Infrastructure Protection: DHS Is Taking Action to Better Manage Its
Chemical Security Program, but It Is too Early to Assess Results, GAO-12-515T
(Washington, D.C.: July 2012).
2
Pub. L. No. 109-295, § 550, 120 Stat. 1355, 1388 (2006).
3
 According to DHS, a high-risk chemical facility is one that, in the discretion of the
Secretary of Homeland Security, presents a high risk of significant adverse consequences
for human life or health, national security, or critical economic assets if subjected to a
terrorist attack, compromise, infiltration, or exploitation. 6 C.F.R. § 27.105.
4
 The ISCD director who prepared the internal memorandum is no longer in that position,
and the deputy director who assisted with the internal memorandum is now the director.




Page 1                                                                      GAO-12-1044T
designated by DHS as “for official use only” (FOUO), expressed concerns
about the management of the CFATS program. The ISCD memorandum,
which was leaked to the media in December 2011, cited an array of
challenges that, according to these officials, hindered ISCD’s ability to
implement and manage the CFATS program. 5 My statement today
discusses: (1) how the memorandum was developed and what
challenges were identified; (2) what actions are being taken to address
the challenges identified; and (3) the extent to which ISCD’s planned
actions and proposed solutions require action to be taken by or in
collaboration with NPPD or IP.

This statement is based on work we recently completed for this
subcommittee on the ISCD memorandum and related actions. To conduct
this work, we reviewed applicable laws and regulations, as well as NPPD,
IP, and ISCD policies and procedures for administering the CFATS
program, analyzed the ISCD memorandum prepared by the former ISCD
Director in consultation with the former Deputy Director, compared it with
the proposed action plan ISCD officials prepared to address the
challenges identified, and compared subsequent action plans to monitor
ISCD’s progress. 6 Our results are based on the ISCD’s action plan as of
June 2012 so these results reflect the status of ISCD’s progress up to that
point in time. The details of our scope and methodology can be found in
our July 2012 statement. In August 2012, ISCD provided us with an
updated action plan which we used to document the additional action
items completed between June 2012 and August 2012. We did not verify
that the status of these action items.

We conducted this performance audit from February 2012 to July 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 analysis based
on our audit objectives.



5
 According to DHS officials, the ISCD memorandum was never intended to be publically
released.
6
 We initially reviewed an ISCD action plan developed in January 2012. ISCD periodically
updated the plan to monitor progress on the action items and we reviewed 8 versions of
the action plan up to and including one developed in June 2012.




Page 2                                                                    GAO-12-1044T
             Section 550 of the DHS appropriations act for fiscal year 2007 7 requires
Background   DHS to issue regulations establishing risk-based performance standards 8
             for the security of facilities that the Secretary determines to present high
             levels of security risk, among other things. The CFATS rule was published
             in April 2007 9 and Appendix A to the rule, published in November 2007,
             listed 322 chemicals of interest and the screening threshold quantities for
             each. 10 ISCD has direct responsibility for implementing DHS’s CFATS rule,
             including assessing potential risks and identifying high-risk chemical
             facilities, promoting effective security planning, and ensuring that final high-
             risk facilities meet the applicable risk-based performance standards
             through site security plans approved by DHS. ISCD is managed by a
             Director and a Deputy Director and operates five branches that are, among
             other things, responsible for information technology operations, policy and
             planning, and providing compliance and technical support. From fiscal
             years 2007 through 2012, DHS dedicated about $442 million to the CFATS
             program. During fiscal year 2012, ISCD was authorized 242 full-time-
             equivalent positions. For fiscal year 2013, DHS’s budget request for the
             CFATS program was $75 million and 242 positions.




             7
              Pub. L. No. 109-295, § 550, 120 Stat. 1355, 1388 (2006).
             8
              The CFATS rule establishes 18 risk-based performance standards that identify the areas
             for which a facility’s security posture are to be examined, such as perimeter security,
             access control, and cyber security. To meet these standards, facilities are free to choose
             whatever security programs or processes they deem appropriate so long as DHS
             determines that the facilities achieve the requisite level of performance in each applicable
             standard.
             9
              72 Fed. Reg. 17,688 (Apr. 9, 2007) (codified at 6 C.F.R. pt. 27).
             10
               72 Fed. Reg. 65,396 (Nov. 20, 2007). According to DHS, CFATS not only covers
             facilities that manufacture chemicals but also covers facilities that store or use certain
             chemicals as part of their daily operations. This can include food-manufacturing facilities
             that use chemicals of interest in the manufacturing process, farms that use certain
             quantities of ammonium nitrate or urea fertilizers, or universities that use chemicals to do
             experiments.




             Page 3                                                                         GAO-12-1044T
Senior ISCD Leaders
Developed the ISCD
Memorandum to
Highlight Various
Challenges Hindering
CFATS
Implementation

ISCD’s Memorandum        Our review of the ISCD memorandum and discussions with ISCD officials
Based Largely on         showed that the memorandum was developed during the latter part of
Observations of Senior   2011 and was developed primarily based on discussions with ISCD staff
                         and the observations of the ISCD former Director in consultation with the
ISCD Managers            former Deputy Director. In November 2011, the former Director and
                         Deputy Director provided the Under Secretary with the ISCD
                         memorandum entitled “Challenges Facing ISCD, and the Path Forward.”
                         These officials stated that the memorandum was developed to inform
                         leadership about the status of ISCD, the challenges it was facing, and the
                         proposed solutions identified to date. In transmitting a copy of the
                         memorandum to congressional stakeholders following the leak in
                         December 2011, the NPPD Under Secretary discussed caveats about the
                         memorandum, including that it had not undergone the normal review
                         process by DHS’s Executive Secretariat and contained opinions and
                         conclusions that did not reflect the position of DHS.

                         The former ISCD Director stated that the memo was intended to begin a
                         dialog about the program and challenges it faced. The former Director
                         confirmed that she developed the memorandum by (1) surveying division
                         staff to obtain their opinions on program strengths, challenges, and
                         recommendations for improvement; (2) observing CFATS program
                         operations, including the security plan review process; and (3) analyzing
                         an internal DHS report on CFATS operations, 11 which, according to the
                         former Director served as a basis for identifying some administrative


                         11
                           DHS Office of Compliance and Security, National Protection and Programs Directorate,
                         Infrastructure Security Compliance Division (ISCD) Program Inspection, April-September,
                         2011.




                         Page 4                                                                    GAO-12-1044T
                           challenges and corrective action. The senior ISCD and NPPD officials we
                           contacted said that they generally agreed with the material that they saw,
                           but noted that they believed the memorandum was missing context and
                           balance. For example, one NPPD official stated that that the tone of the
                           memorandum was too negative and the problems it discussed were not
                           supported by sound evaluation. However, the official expressed the view
                           that the CFATS program is now on the right track.


ISCD Management Was        The ISCD memorandum discussed numerous challenges that, according to
Concerned That             the former Director, pose a risk to the program. The former Director pointed
Challenges Place the       out that, among other things, ISCD had not approved any site security
                           plans or carried out any compliance inspections on regulated facilities. The
CFATS Program at Risk      former Director attributed this to various management challenges, including
                           a lack of planning, poor internal controls, and a workforce whose skills were
                           inadequate to fulfill the program’s mission, and highlighted several
                           challenges that have had an impact on the progress of the program. In
                           addition, the memorandum provided a detailed discussion of the issues or
                           problems facing ISCD, grouped into three categories: (1) human capital
                           management, such as poor staffing decisions; (2) mission issues, such as
                           the lack of an established inspection process; and (3) administrative issues,
                           such as a lack of infrastructure and support, both within ISCD and on the
                           part of NPPD and IP.



ISCD Has Begun to
Take Various Actions
Intended to Address
Challenges Identified

ISCD’s Action Plan         ISCD is using an action plan to track its progress addressing the
Included Time Frames and   challenges identified in the memorandum, and, according to senior
Appears to be Helping      division officials, the plan may be helping them address some legacy
                           issues that staff were attempting to deal with before the memorandum
Address Some Legacy        was developed. The January 2012 version of the proposed action plan
Issues                     listed 91 actions to be taken categorized by issue—human capital
                           management issues, mission issues, or administrative issues—that,
                           according to the former ISCD Director, were developed to be consistent
                           with the ISCD memorandum. However, the January 2012 version of the



                           Page 5                                                           GAO-12-1044T
                          action plan did not provide information on when the action was started or
                          to be finished. Eleven of the 12 ISCD managers (other than the former
                          Director and Deputy Director) assigned to work as the coordinators of the
                          individual action items told us that even though they were not given the
                          opportunity to view the final version of the ISCD memorandum, the former
                          Director provided them the sections of the action plan for which they were
                          responsible to help them develop and implement any corrective actions.
                          They said that they agreed that actions being taken in the plan were
                          needed to resolve challenges facing ISCD. Our discussions with these
                          officials also showed that about 39 percent (37 of 94) of the items in the
                          March and June 2012 action plans addressed some legacy issues that
                          were previously identified and, according to these officials, corrective
                          actions were already underway for all 37 of these items.


ISCD’s June 2012 Plan     Our analysis of the June 2012 version of the ISCD action plan showed
Update Showed 38 Action   that 40 percent of the items in the plan (38 of 94) had been completed.
Items Completed           The remaining 60 percent (56 of 94) were in progress. Of the 38
                          completed items, we determined that 32 were associated with human
                          capital management and administrative issues, including those involving
                          culture and human resources, contracting, and documentation. The
                          remaining 6 of 38 action items categorized by ISCD as completed were
                          associated with mission issues. Figure 1 shows the status of action items
                          by each of the three categories as of June 2012.




                          Page 6                                                        GAO-12-1044T
Figure 1: Status of ISCD Action Plan by Category, as of June 2012




                                         For the remaining 56 items that were in progress as of June 2012, 40
                                         involved human capital management and administrative issues.
                                         According to ISCD officials, these 40 issues generally involved longer-
                                         term efforts—such as organizational realignment—or those that require
                                         approval or additional action on the part of IP or NPPD. Sixteen of 56
                                         remaining actions items in progress covered mission issues that will likely
                                         also require long-term efforts to address.

                                         As of August 2012, ISCD reported that it had completed another 21 action
                                         items, of which 8 were to address mission-related issues. We did not
                                         verify ISCD’s efforts to complete actions since June 2012. However, we
                                         have recently begun a follow-up review of CFATS at the request of this
                                         and other committees, which will focus on DHS’s efforts to address
                                         mission-related issues. We expect to report the results of these efforts
                                         early in 2013.




                                         Page 7                                                          GAO-12-1044T
Almost Half of ISCD’s     Our analysis of the April and June versions of the plan shows that the
Action Item Completion    division had extended the estimated completion dates for nearly half of
Dates Had Been Extended   the action items. Estimated completion dates for 52 percent (48 of 93
                          items) 12 either did not change (37 items) or the date displayed in the June
since April 2012
                          2012 plan was earlier than the date in the April 2012 version of the plan
                          (11 items). Conversely, 48 percent (45 of 93) of the items in the June
                          2012 version of the plan had estimated completion dates that had been
                          extended beyond the date in the April 2012 plan. Figure 2 shows the
                          extent to which action plan items were completed earlier than planned,
                          did not change, or were extended, from April 2012 through June 2012, for
                          the human capital management, mission, and administrative issues
                          identified in the plan.




                          12
                             ISCD data showed that 93 of 94 action items were consistent between the April 2012
                          and June 2012 action plans; therefore, computation of the estimated completion dates
                          was based on 93 total items. One action item in the April 2012 plan dealing with strategies
                          for managing ISCD funding levels was removed from the June 2012 plan because after
                          the analysis was prepared and submitted to NPPD, the decision was made to delete the
                          item from the plan. The funding action item was replaced in the June 2012 action plan with
                          an action item to conduct a peer review of the facility tiering process and formula. For
                          purposes of this analysis, we used the 93 action items (instead of 94 action items) that
                          were consistent between the April and June 2012 action plans.




                          Page 8                                                                       GAO-12-1044T
Figure 2: Change in CFATS Action Plans Estimated Completion Dates from April 2012 to June 2012




                                       a
                                        ISCD data showed that 93 of 94 action items were consistent between the April 2012 and June 2012
                                       action plans, therefore, computation of the estimated completion dates was based on 93 total items.
                                       One action item in the April 2012 plan dealing with strategies for managing ISCD funding levels was
                                       removed from the June 2012 plan because after the analysis was prepared and submitted to NPPD,
                                       the decision was made to delete the item from the plan. The funding action item was replaced in the
                                       June 2012 with an action item to conduct a peer review of the facility tiering process and formula. For
                                       purposes of this analysis, we used the 93 action items that were consistent between the April and
                                       June 2012 action plans.


                                       ISCD officials told us that estimated completion dates had been extended
                                       for various reasons. For example, one reason for moving these dates was
                                       that the work required to address some items was not fully defined when
                                       the plan was first developed and as the requirements were better defined,
                                       the estimated completion dates were revised and updated. In addition,
                                       ISCD officials also stated that timelines had been adversely affected for
                                       some action items because staff had been reassigned to work on higher
                                       priority responsibilities, such as reducing the backlog of security plans
                                       under review.




                                       Page 9                                                                                 GAO-12-1044T
Action Plan Performance   ISCD, through its action plan, appears to be heading in the right direction
Measures Could Help       towards addressing the challenges identified, but it is too early to tell if the
Gauge Progress            action plan is having the desired effect because (1) the division had only
                          recently completed some action items and continues to work on
                          completing more than half of the others, some of which entail long-term
                          changes, and (2) ISCD had not yet developed an approach for measuring
                          the results of its efforts. ISCD officials told us that they had not yet begun
                          to plan or develop any measures, metrics, or other documentation
                          focused on measuring the impact of the action plan on overall CFATS
                          implementation because they plan to wait until corrective action on all
                          items has been completed before they can determine the impact of the
                          plan on the CFATS program. For the near term, ISCD officials stated that
                          they plan to assess at a high level the impact of the action plan on
                          CFATS program implementation by comparing ISCD’s performance rates
                          and metrics pre-action plan implementation and post-action plan
                          implementation. 13 However, because ISCD will not be completing some
                          action items until 2014, it will be difficult for ISCD officials to obtain a
                          complete understanding of the impact of the plan on the program using
                          this comparison only.

                          In our July 2012 statement, we recommended that ISCD look for
                          opportunities, where practical, to measure results of their efforts to
                          implement particular action items, and where performance measures can
                          be developed, periodically monitor these measures and indicators to
                          identify where corrective actions, if any, are needed. The agency
                          concurred with our recommendation and developed a new action item
                          (number 95) intended to develop metrics for measuring, where practical,
                          results of efforts to implement action plan items, including processes for
                          periodic monitoring and indicators for corrective actions. This action item
                          is in progress.




                          13
                            According to ISCD officials, ISCD uses a performance measure to track the
                          performance of the CFATS program overall, but as of June 2012 did not have
                          performance measures in place to track the progress of the action plan, or particular
                          action items.




                          Page 10                                                                      GAO-12-1044T
                        According to ISCD officials, almost half of the action items included in the
ISCD Officials Stated   June 2012 action plan either require ISCD to collaborate with NPPD and IP
That Almost Half of     or require NPPD and IP to take action to address the challenges identified
                        in the ISCD memorandum. NPPD, IP, and ISCD officials have been
the Action Items        working together to identify solutions to the challenges the memorandum
Required                identified and to close pertinent action items. According to division officials,
Collaboration with or   46 of the 94 action items included in the June 2012 action plan required
                        action either by NPPD and IP or collaboration with NPPD and IP. This
Action by NPPD or IP    includes collaborating with NPPD officials representing the NPPD human
                        capital, facilities, and employee and labor relations offices, among others,
                        and with IP’s Directorate of Management Office. 14 As of June 2012, 13 of
                        the 46 items that require action by or collaboration with NPPD or IP were
                        complete; 33 of 46 were in progress. As of August 2012, ISCD reported
                        that it had completed 8 more of these action items, such that 21 of the 46
                        were complete and 25 were in progress. We did not verify ISCD’s efforts to
                        close these additional action items.


                        Chairman Aderholt, Ranking Member Price, and members of the
                        subcommittee, this completes my prepared statement. I would be happy
                        to respond to any questions you may have at this time.


                        For information about this statement please contact Steven L. Caldwell,
GAO Contact and         Director, Homeland Security and Justice, at (202) 512-9610 or
Staff                   CaldwellS@gao.gov. Contact points for our Offices of Congressional
                        Relations and Public Affairs may be found on the last page of this
Acknowledgements        statement. Other individuals making key contributions include John F.
                        Mortin, Assistant Director; Ellen Wolfe, Analyst-in-Charge; Charles
                        Bausell; Jose Cardenas; Andrew M. Curry; Michele Fejfar; Tracey King;
                        Marvin McGill; Mona E. Nichols-Blake; and Jessica Orr.




                        14
                          The IP Directorate of Management Office is responsible for providing IP divisions with
                        program management support such as training and facilities management.




(441111)
                        Page 11                                                                      GAO-12-1044T
This is a work of the U.S. government and is not subject to copyright protection in the
United States. The published product may be reproduced and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be
necessary if you wish to reproduce this material separately.
GAO’s Mission         The Government Accountability Office, the audit, evaluation, and
                      investigative arm of Congress, exists to support Congress in meeting its
                      constitutional responsibilities and to help improve the performance and
                      accountability of the federal government for the American people. GAO
                      examines the use of public funds; evaluates federal programs and
                      policies; and provides analyses, recommendations, and other assistance
                      to help Congress make informed oversight, policy, and funding decisions.
                      GAO’s commitment to good government is reflected in its core values of
                      accountability, integrity, and reliability.

                      The fastest and easiest way to obtain copies of GAO documents at no
Obtaining Copies of   cost is through GAO’s website (http://www.gao.gov). Each weekday
GAO Reports and       afternoon, GAO posts on its website newly released reports, testimony,
                      and correspondence. To have GAO e-mail you a list of newly posted
Testimony             products, go to http://www.gao.gov and select “E-mail Updates.”

Order by Phone        The price of each GAO publication reflects GAO’s actual cost of
                      production and distribution and depends on the number of pages in the
                      publication and whether the publication is printed in color or black and
                      white. Pricing and ordering information is posted on GAO’s website,
                      http://www.gao.gov/ordering.htm.
                      Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
                      TDD (202) 512-2537.
                      Orders may be paid for using American Express, Discover Card,
                      MasterCard, Visa, check, or money order. Call for additional information.
                      Connect with GAO on Facebook, Flickr, Twitter, and YouTube.
Connect with GAO      Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.
                      Visit GAO on the web at www.gao.gov.
                      Contact:
To Report Fraud,
Waste, and Abuse in   Website: http://www.gao.gov/fraudnet/fraudnet.htm
                      E-mail: fraudnet@gao.gov
Federal Programs      Automated answering system: (800) 424-5454 or (202) 512-7470

                      Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-
Congressional         4400, U.S. Government Accountability Office, 441 G Street NW, Room
Relations             7125, Washington, DC 20548

                      Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800
Public Affairs        U.S. Government Accountability Office, 441 G Street NW, Room 7149
                      Washington, DC 20548




                        Please Print on Recycled Paper.