oversight

Kennedy Center: Audit Duplication Can Be Prevented

Published by the Government Accountability Office on 1997-08-19.

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

                 United States General Accounting Office

GAO              Report to Congressional Committees




August 1997
                 KENNEDY CENTER
                 Audit Duplication Can
                 Be Prevented




GAO/GGD-97-161
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      General Government Division

      B-277198

      August 19, 1997

      The Honorable John H. Chafee
      Chairman
      The Honorable Max Baucus
      Ranking Minority Member
      Committee on Environment and Public Works
      United States Senate

      The Honorable Bud Shuster
      Chairman
      The Honorable James L. Oberstar
      Ranking Minority Member
      Committee on Transportation and Infrastructure
      House of Representatives

      Since its inception, The John F. Kennedy Center for the Performing Arts
      (the Center) has annually contracted with a public accounting firm (the
      auditor) to perform an audit of its financial statements and provide it with
      a report on whether those statements present fairly the financial position
      of the Center. According to Center officials, the financial statement audit
      is undertaken for several reasons, including the following: first, in
      response to the requirement in 20 U.S.C. 76l (c) that the Board of Trustees
      submit to Congress an annual report of its operations, which includes a
      detailed statement of all public and private money received and disbursed;
      second, to provide grantors from whom the Center receives funding an
      accounting of the use of such funds; and third, to assist the Board in
      carrying out its trust responsibilities under the statute. For these reasons,
      the officials to whom we spoke said that, in their opinion, the general
      fiduciary standards governing the responsibilities of the Kennedy Center
      trustees and officers effectively require an annual audit of its financial
      statements.

      The John F. Kennedy Center Act Amendments of 19941 (the Amendments)
      provide that not less than once every 3 years we are to audit and review
      the accounts of the Center for the purpose of examining expenditures of
      funds appropriated in fiscal years 1995 through 1999 for maintenance,
      repair, and security, and capital projects under the Amendments and for
      compliance with the Amendments’ limitation on the use of those funds for
      performing arts functions. Beginning with the Center’s fiscal year 1995
      financial statements, the appropriations were included in the Center’s


      1
       Section 5(d) of the John F. Kennedy Center Act Amendments of 1994, Public Law 103-279, 108 Stat.
      1409, 1415-1416 (1994), which amended Section 6 of the John F. Kennedy Act, 20 U.S.C. 76l.



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                   financial statements and, therefore, were subject to the financial statement
                   audit. Thus, our initial audit under the Amendments would cover
                   appropriated funds for fiscal years 1995 through 1996, while our
                   subsequent audit would cover fiscal years 1997 through 1999.

                   As we performed the work necessary to plan our own audit, we recognized
                   that because the appropriated funds were included in the financial
                   statements and those financial statements were audited annually, the
                   Center’s use of those funds would, if we performed our audit, be subject to
                   multiple audits. In the past, in other instances of possible multiple audit
                   requirements, Congress and the executive branch have provided guidance
                   that emphasizes the need for the efficient use of audit resources through
                   the coordination of audit work and the elimination of duplication.

                   We discussed with your offices the potential for duplication of effort
                   arising from multiple audit requirements involving the Center’s
                   appropriated funds. We agreed to determine whether we should continue
                   the work necessary to plan and do our own audit, and if continuation of
                   our work did not appear prudent, to seek legislative relief from the audit
                   requirement. In this regard, we looked to see whether the auditor planned
                   and carried out an audit that complied with the standards set forth in the
                   Government Auditing Standards since both our audit and the auditor’s are
                   subject to those standards. We developed information and obtained
                   documentation about the auditor’s planned and executed audit work,
                   reviewed some working papers prepared by the auditor, and obtained the
                   reports on the financial statements and compliance with laws and
                   regulations that the auditor had prepared and issued to Center
                   management.


                   The information and documentation we obtained from the Center and the
Results in Brief   auditor and the auditor’s records we reviewed demonstrated that our
                   audit, if implemented, would duplicate those portions of the auditor’s
                   work involving the understanding of internal controls, sampling of
                   expenditures, and testing for compliance with the limitation on the use of
                   the appropriated funds. Further, the auditor planned and executed the
                   audit under the Government Auditing Standards, which governs our audit
                   work as well.

                   In the future, according to Center officials, the Center plans both to
                   continue to annually contract with a public accounting firm for a financial
                   statement audit that will include the use of appropriated funds and to



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             require that its auditor’s work be subject to the Government Auditing
             Standards. Further, at our suggestion, Center officials revised the contract
             with the auditor, beginning with the fiscal year 1997 audit, to require that
             the auditor’s report specifically state the tests undertaken for compliance
             with the limitation on the use of appropriated funds and the results of
             those tests.

             On the basis of the information we developed, we believe that efficient use
             of our audit resources would best be achieved by the Center’s continued
             contracting for a single annual audit of its financial statements subject to
             the Government Auditing Standards. This audit would include both the use
             of the appropriated funds and compliance with limitations on the use of
             those funds. Therefore, as agreed with your offices, we are seeking
             legislative relief from the requirement for us to periodically audit the
             Center’s use of appropriated funds.


             The Kennedy Center, established in 19642 as both a national cultural arts
Background   center and a living memorial to the 35th President, opened in
             September 1971. Shortly thereafter, in 1972, the Secretary of the Interior,
             through the National Park Service, assumed responsibility for building
             maintenance, security, interpretative, janitorial, and all other services
             necessary for the operations of the Kennedy Center not related to the
             performing arts.

             In 1994, the Amendments transferred responsibility for the work
             performed by the National Park Service to the Kennedy Center Board of
             Trustees and also authorized the appropriation of funds, beginning in
             fiscal year 1995, to the Board for this work. The Center’s financial
             statements for fiscal years 1995 and 1996 reflected the appropriation
             received as either operating revenue and expense or capital assets.

             Under 31 U.S.C. 712, we are authorized to “investigate all matters related
             to the receipt, disbursement, and use of public money.” In addition, the
             John F. Kennedy Center Act Amendments of 1994 provide that we are to
             audit and review the accounts funded by appropriations authorized by
             those amendments at least once every 3 years.




             2
             In 1958, The National Cultural Center Act, authorized a National Cultural Center in the District of
             Columbia, which on Jan. 23, 1964, was renamed the John F. Kennedy Center for the Performing Arts.



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                         As agreed with your offices, our objective was to determine whether an
Objectives, Scope,       audit by us would duplicate work done by the Center’s auditor. Further, if
and Methodology          we determined that duplication was a problem we would seek legislative
                         relief from the requirement to do our own audit of the Center’s use of
                         appropriated funds.3 In this regard, we

                     •   examined the auditor’s audit scope and plan;
                     •   reviewed the reports issued by the auditor;
                     •   developed independently our own understanding of the Center’s internal
                         control process for managing federal appropriations authorized by the
                         Amendments; and
                     •   developed an understanding of the auditor’s actual performance of the
                         audit through (1) discussions with staff of the auditor and Center staff
                         involved in the audit, (2) comparison with requirements in the
                         Government Auditing Standards, and (3) review of selected working
                         papers prepared by the auditor and documentation related to the audit
                         provided by the auditor and the Center.

                         The field work standards in the Government Auditing Standards set forth
                         general guidelines for undertaking the detailed audit work necessary to
                         evaluate an auditee’s financial statements. The field work standards
                         include properly planning the audit to (1) consider materiality in
                         determining the audit procedures, (2) follow up on prior findings and
                         recommendations, (3) obtain a sufficient understanding of internal
                         controls to plan the audit, and (4) provide reasonable assurance of
                         detecting irregularities that have a direct and material impact on the
                         financial statements.

                         The Government Auditing Standards also contain general guidelines for
                         reporting on financial audits. Regarding reporting on compliance with
                         laws and regulations, the reporting standards require that the auditor
                         report both the scope of testing of compliance with laws and regulations
                         and the results of those tests either in the financial statement report or a
                         separate report.

                         Because both our work and that of the Center’s auditor are subject to the
                         Government Auditing Standards, we looked for elements of the standards
                         in the audit scope and plan of the auditor. Our rationale was that the
                         presence of these elements in the auditor’s planned work would constitute

                         3
                          Our approach was discussed in our May 28, 1997, letter to the Chairmen and Ranking Minority
                         Members of the Senate Subcommittee on Transportation and Infrastructure and the House
                         Subcommittee on Public Buildings and Economic Development, in which we described our objectives,
                         scope, and methodology for this assignment.



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    evidence of the duplication that would have occurred when we prepared
    and carried out our audit scope and plan in accordance with the standards.
    To ensure that the auditor performed the audit work detailed in its audit
    plan, we checked for evidence of this work in the auditor’s records
    involving sampled expenditure transactions.

    To address how to proceed when we were confronted with the multiple
    audit situation at the Center, we looked at selected federal program audit
    guidance.4 We found that this guidance, both in federal law and executive
    branch policy, provides direction regarding what an auditor is to do when
    confronted with an auditee subject to multiple audits. This direction is as
    follows:

•   Audits by different auditors should be coordinated,
•   Duplication of audit work should be avoided,
•   Auditors should reduce the burden on the auditee, and
•   Audit resources should be efficiently used.

    To document the scope of the auditor’s plan for staffing and undertaking
    the audit work in accordance with Government Auditing Standards, we
    obtained

•   the audit plan for testing appropriated funds;
•   the internal control memorandum prepared by the auditor in planning the
    work;
•   reports issued to the Center as a result of the work;
•   documentation on the audit staff’s qualifications, independence, and prior
    experience at the Center and with federal appropriated funds audits; and
•   the external critique of the auditor’s practice as reflected by the external
    peer review opinion.

    We did not, as part of our work, perform a detailed review of all of the
    documentation contained in the auditor’s files supporting its audit of
    appropriated funds nor reperform tests conducted by the auditor because
    it was not our intent to use the auditor’s work to develop our own report
    or opinion on the Center’s use of appropriated funds and its compliance
    with the restrictions on the use of the appropriations. However, we
    completed the work we deemed necessary to confirm the auditor’s
    documented understanding of internal controls. In addition, we did

    4
    The Single Audit Act of 1984, 31 U.S.C. 7501-7507; Audits of State and Local Governments, Office of
    Management and Budget, Circular No. A-128, Apr. 12, 1985; and Audits of Institutions of Higher
    Education and Other Nonprofit Institutions, Office of Management and Budget, Circular No. A-133,
    Mar. 8, 1990.



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                             conduct a limited review of the auditor’s documentation for some of the
                             sampled transactions and held discussions with the auditor’s and Center’s
                             staffs to obtain an understanding of the work performed concerning
                             compliance with appropriation law. For example, we reviewed some of
                             the auditor’s records to verify that they contained evidence of an
                             examination of a sample of the Center’s appropriated funds transactions.

                             On August 5, 1997, we provided a draft of this report to the Chairman of
                             the Kennedy Center for review and comment. The Center’s comments are
                             discussed at the end of this report.


                             We assessed the potential for our duplicating the auditor’s work by
The Work of the              focusing on the objectives and audit work envisioned by the two
Auditor Was                  documents that guided that work—the engagement letter (the contractual
Governed by                  agreement) and the audit plan. These documents established the
                             objectives that the audit had to fulfill and defined how the auditor was to
Contractual                  proceed to achieve those objectives. The letter specified (1) the
Agreement and                agreed-upon scope of work, (2) the general limitations of the audit, and
                             (3) the reports to be provided to the Center as a result of the general work.
Implemented Using            To implement the terms and conditions of the engagement letter, the
an Audit Plan                auditor developed a detailed plan, known as the audit plan, that laid out
                             the specific steps for testing appropriated expenditures, including sample
                             selection, tests of sampled transactions, and internal summaries and
                             documents to be produced.


The Engagement Letter        We obtained the July 21, 1996, engagement letter between the Center and
Established the Financial    the auditor that set forth the contractual terms for the Center’s fiscal year
Statement Audit Objectives   1996 financial statement audit. The engagement letter included both a
                             statement of the scope of the audit and the terms and conditions for
                             completing the work. The auditor’s scope included work at The John F.
                             Kennedy Center for the Performing Arts; the National Symphony
                             Orchestra; the Kennedy Center Productions, Inc.; and the Kennedy Center
                             Electronic Media Technologies, Inc.

                             Reflecting the field work standard requirements of the Government
                             Auditing Standards, the engagement letter set forth the terms of the audit
                             in a section entitled Audit Responsibilities and Limitations. This section
                             required that (1) the audit be conducted in accordance with generally
                             accepted auditing standards, the standards contained in the Government




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                                  Auditing Standards;5 and OMB Circular A-133, “Audits of Institutions of
                                  Higher Education and Other Non-Profit Institutions;” (2) the auditor
                                  conduct the audit by examining, on a test basis, the evidence supporting
                                  the amounts and disclosures in the financial statements; and (3) in
                                  addition to the opinion on the financial statements, a report, or reports, on
                                  the Center’s internal controls and compliance with laws and regulations be
                                  issued to Center management.


The Audit Plan Laid Out           To manage the work necessary to meet the requirements of the audit as
the Steps for Achieving the       specified in the engagement letter, the auditor developed a step-by-step
Audit Objectives                  audit plan for testing of appropriated expenditures. The audit plan
                                  included specific objectives for the work, such as determining whether
                                  (1) appropriations were properly recorded; (2) accounting procedures and
                                  controls conformed to established procedures, and that such procedures
                                  were operating effectively and provided proper control over appropriated
                                  funds disbursements; and (3) capital project fund balances had been
                                  properly classified using the following categories: invested capital,
                                  obligated but not invoiced, and unobligated.

                                  The audit plan laid out the specific steps to be undertaken to test
                                  expenditures of appropriated funds. These steps included

                              •   obtaining an understanding of the flow of federal transactions through
                                  discussions with appropriate personnel;
                              •   completing a random disbursement test for operation and maintenance
                                  and capital expenditures by sampling the universe of each type of
                                  transaction;
                              •   obtaining documentation for each sample transaction and testing it for
                                  approvals, signatures, recording of vendor and amount in the financial
                                  records, receipt of purchased item(s); and
                              •   testing compliance with statutory limitations on the use of appropriations.

                                  Our review of some auditor documentation of its tests, discussions with
                                  the auditor’s staff about those tests, and discussions with audited Center
                                  staff confirmed that the auditor did carry out the audit steps set forth in its
                                  audit plan regarding the Center’s use of appropriated funds.




                                  5
                                    The Government Auditing Standards for financial audits incorporate the American Institute of
                                  Certified Public Accountants Statements on Auditing Standards, often referred to as generally
                                  accepted auditing standards (GAAS).



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Auditor Issued Various          The auditor’s engagement letter, reflecting the reporting standards in the
Reports to Kennedy Center       Government Auditing Standards, provided that the auditor was to issue
Managers at Audit               several reports to Center management at the conclusion of its work, which
                                gave the Kennedy Center a clean opinion on its financial statements for
Conclusion                      fiscal years 1995 and 1996. On November 27, 1996, the auditor issued
                                reports covering the financial statements audit as well as work done as
                                part of the financial statement work on internal controls and compliance
                                with laws and regulations. Specifically, these reports were entitled

                                (1) Financial Statements As of September 29, 1996, and October 1, 1995,
                                Together With Auditors’ Report, to the Board of Trustees;

                                (2) OMB Circular A-133 Supplementary Financial Report For the Fiscal
                                Year Ended September 29, 1996, Together with Auditors’ Reports, to the
                                Board of Trustees; and

                                (3) Comments and Suggestions for Consideration For the Year Ended
                                September 29, 1996, to the President of the Kennedy Center.

                                We also noted that the auditor, again reflecting the reporting requirements
                                of the Government Auditing Standards, included an update of prior-year
                                audit comments and suggestions in the Comments and Suggestions letter.


                                The work we undertook in planning our own audit convinced us that had
Areas of Potential              we performed our own audit of the Center’s use of appropriated funds, we
Duplication Exist in            would have duplicated the work of the auditor. The areas of duplication
Our Work and the                included

Work of the Auditor         •   developing an understanding of the Center’s internal control process for
                                appropriated expenditures;
                            •   testing expenditure transactions for compliance with law and with the
                                limitation on the use of appropriated funds; and
                            •   preparing and issuing a report, or reports, on the use of appropriated
                                funds, internal controls, and compliance with the law and the limitation on
                                the use of these funds.

                                To assess the likelihood of duplication, we obtained documentation from
                                the auditor, reviewed some documentation in the auditor’s records of the
                                testing of sampled transactions, and discussed the audit work with the
                                auditor’s staff and Center staff involved in the audit. We focused on the




                                Page 8                                        GAO/GGD-97-161 Audit Duplication
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                            auditor’s understanding of internal controls, tests of transactions, and
                            compliance with the limitation on the use of the appropriated funds.


Auditor Developed           The auditor, in applying the field work standards for developing an
Understanding of Internal   understanding of internal controls, prepared an August 19, 1996, internal
Controls in Planning        control memorandum entitled “Purchasing Procedures for Federal
                            Acquisitions.” The memorandum, according to auditor staff, represented
Audit Work                  the auditor’s understanding, from discussions with Center staff, of the
                            process by which the Center makes purchases using the appropriated
                            funds.

                            In completing the work necessary in planning our own audit, we discussed
                            appropriated funds procedures with Center staff and obtained Center
                            appropriated funds financial reports and documentation from several
                            purchase/contract files to develop our own understanding of the Center’s
                            process for making purchases using appropriated funds. Although we did
                            not prepare an internal control memorandum, we were able to confirm the
                            process that the auditor presented in the August 19, 1996, memorandum.
                            We found the auditor’s memorandum accurately reflected our own
                            understanding of the Center’s controls over the use of appropriated funds.


Auditor Tested Samples of   The auditor, in applying the field work standards for testing of
Appropriation Expenditure   transactions, selected a sample of the operation and maintenance and
Transactions                capital improvement appropriations expenditures for use in testing
                            transactions. The auditor advised us that its sample was selected from the
                            universe of expenditures in the fiscal year for each type of funding. To
                            plan for our own tests of the use of appropriated funds, we identified and
                            obtained expenditure records from the Center that provided the universe
                            of expenditures by fiscal year and type of funding. Although we did not
                            proceed to select and test our own sample, on the basis of the auditor’s
                            audit plan and the sampling used by the auditor, we concluded that the
                            auditor’s planned procedures were adequate.

                            By reviewing the auditor’s plan and the documentation we obtained from
                            the records prepared by the auditor related to the testing of transactions,
                            and our discussions with both the auditor’s staff and staff at the Center,
                            we developed an understanding of the work performed by the auditor in
                            its specific testing of documentation supporting each sampled
                            expenditure. The auditor’s plan included verifying that documentation
                            existed, that appropriate signatures and approvals were thereon, and that



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                             the financial aspects of the transaction were recorded. The documentation
                             we obtained from the auditor showed that it sampled 37 maintenance,
                             repair, and security expenditure transactions and 36 capital projects
                             expenditure transactions. We believe that had we proceeded to do our
                             own audit, our approach would have been similar to the one used by the
                             Center’s auditor.


Auditor’s Report Did Not     In addition to the uses for which funds were authorized—namely,
Specifically Reflect         maintenance, repair, and security, and capital projects—the Amendments
Coverage of Tests for        imposed a specific limitation on the use of funds to support performing
                             functions. This limitation provided that
Compliance With
Limitation on Use of Funds   “No funds appropriated pursuant to this section may be used for any direct
                             expense incurred in the production of a performing arts attraction, for
                             personnel who are involved in performing arts administration (including
                             any supply or equipment used by the personnel), or for production,
                             staging, public relations, marketing, fundraising, ticket sales, or
                             education.”6

                             The auditor’s plan, audit records, and our discussions with both the
                             auditor’s staff and staff of the Center provided us with an understanding of
                             the work both planned and performed by the auditor in the testing of
                             compliance with the limitation on the use of appropriated funds in support
                             of performing functions. For each sampled transaction, the auditor
                             considered whether the expenditure was consistent with the act’s
                             limitation. Had we continued with the work necessary to plan and do our
                             own audit, we would have developed and executed tests to determine
                             whether expenditures were consistent with the Amendments’ limitation.

                             Although the auditor tested transactions for compliance with the statutory
                             limitation on the use of appropriated funds, its report on compliance with
                             provisions of laws neither listed this limitation among those for which
                             compliance was tested nor provided information specifically relating to
                             the Center’s compliance with the limitation as evidenced by the auditor’s
                             tests. We brought this matter to the attention of Center officials. We
                             suggested that they include a contractual requirement in future financial
                             statement audit engagement letters requiring that the auditor include in its
                             report to the Center information about specific tests of compliance with



                             6
                              Section 12(c) of the John F. Kennedy Center Act Amendments of 1994, Public Law 103-279, 108 Stat.
                             1409, 1416 (1994), 20 U.S.C. 76r.



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             the limitation on the use of funds that it had undertaken and a statement of
             the results of those tests.

             In response, Center officials agreed with our suggestion to revise future
             contracts and included a requirement in the fiscal year 1997 financial
             statement audit contract that the auditor, in its report, include specific
             information about tests conducted and the results of those tests.


             The funds appropriated to the Center for maintenance, repair, and
Conclusion   security, and capital projects are currently subject to duplicative audit
             work. The Amendments provide that we are to review and audit the
             accounts that use these appropriated funds. But because these
             appropriated funds are also included in the financial statements of the
             Center, they are also subject to the Center’s annual financial statement
             audit.

             Our discussions with Center officials and the auditor’s staff, as well as our
             review of the auditor’s audit plan, documentation from the auditor’s
             records, and Center documents, convinced us that our audit would have
             duplicated the work of the auditor, would not have been an efficient use of
             our audit resources, and would have imposed an unnecessary burden on
             Center staff.

             As long as Center officials continue retaining an auditor whose work is
             subject to Government Auditing Standards, and Center officials require the
             auditor to specifically address its tests of compliance with the limitation
             on the use of appropriated funds and the results of those tests in its audit
             report, we believe Congress would receive little, if any, benefit from our
             duplicative audit of funds appropriated to the Center. If Congress is
             concerned that the Center may not continue to retain an auditor to
             perform an annual audit in compliance with the Government Auditing
             Standards, it could impose a statutory requirement that the Kennedy
             Center continue to have annual audits performed. Furthermore, even if the
             statutory language that specifically provides for audits by the Comptroller
             General of the Center’s use of appropriated funds is repealed, Congress
             could still request that we review and examine the Center’s use of those
             funds under our general authority in 31 U.S.C. 712.




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                  We recommend that Congress delete the requirement that the Comptroller
Recommendation    General audit the funds appropriated. To statutorily ensure continued
                  audits of those funds, Congress may wish to consider including, in the
                  reauthorization legislation, a requirement that the Center (1) continue
                  contracting for annual financial statement audits, subject to the
                  Government Auditing Standards, to ensure that appropriated funds are
                  properly obligated and expended in compliance with statutory authorities
                  and limitations and (2) communicate the results of such audits to
                  Congress annually.


                  We provided copies of a draft of this report to the Chairman, John F.
Agency Comments   Kennedy Center, for comment. On August 11, 1997, the Center’s Vice
                  President, Facilities; Chief Financial Officer; General Counsel; and
                  Controller provided us with oral comments on the draft report. These
                  officials advised us that they generally agreed with the information in the
                  report and the recommendation to Congress. They also stated that in the
                  Kennedy Center’s view, it is not necessary to amend the Kennedy Center
                  Act to specify auditing requirements because the trustees and officers
                  already have an obligation to ensure that expenditures of funds are
                  audited in accordance with current auditing standards. However, they said
                  that the Kennedy Center has no objection to amending the act as
                  recommended.

                  The Kennedy Center officials also provided comments to clarify some of
                  the information presented in the report, which we have incorporated
                  where appropriate.


                  We are sending copies of this report to the Chairman of the Senate
                  Subcommittee on Transportation and Infrastructure, Committee on
                  Environment and Public Works; the Chairman and Ranking Minority
                  Member of the House Subcommittee on Public Buildings and Economic
                  Development, Committee on Transportation and Infrastructure; the
                  Chairman of the John F. Kennedy Center for the Performing Arts; and
                  other interested committees and subcommittees. Copies will be made
                  available to others upon request.




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Major contributors to this report are listed in the appendix. If you have any
questions about the report, please call me on (202) 512-8387.




Bernard L. Ungar
Director, Government Business
   Operations Issues




Page 13                                        GAO/GGD-97-161 Audit Duplication
Appendix

Major Contributors to This Report


                        Ronald King, Assistant Director
General Government      Thomas Johnson, Evaluator-in-Charge
Division, Washington,   Hazel Bailey, Communications Analyst
D.C.                    John Parulis, Senior Evaluator

                        Robert Gramling, Director of Corporate Audits and Standards
Accounting              Jeannette Franzel, Assistant Director, Corporate Audits and Standards
Information
Management Division
                        Alan Belkin, Acting Associate General Counsel
Office of the General   Susan Michal-Smith, Senior Attorney
Counsel




(240221)                Page 14                                      GAO/GGD-97-161 Audit Duplication
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