oversight

Transportation Coordination: Benefits and Barriers Exist, and Planning Efforts Progress Slowly

Published by the Government Accountability Office on 1999-10-22.

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

                United States General Accounting Office

GAO             Report to Congressional Committees




October 1999
                TRANSPORTATION
                COORDINATION
                Benefits and Barriers
                Exist, and Planning
                Efforts Progress
                Slowly




GAO/RCED-00-1
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Resources, Community, and
      Economic Development Division

      B-281617

      October 22, 1999

      The Honorable Phil Gramm
      Chairman
      The Honorable Paul S. Sarbanes
      Ranking Minority Member
      Committee on Banking,
        Housing, and Urban Affairs
      United States Senate

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

      For several decades, many human services agencies have provided special
      transportation services for seniors, persons with disabilities, and others
      through programs funded and administered by the Department of Health
      and Human Services (HHS). For example, program-related transportation
      services have enabled elderly people who no longer drive to get to sites
      offering nutrition services, ensured that isolated children receive benefits
      from Head Start programs, and transported clients to community health
      centers and welfare recipients to jobs. Local human services agencies
      providing these services have often purchased and operated their own
      vehicles or purchased transportation services from others. The estimates
      of overall spending on transportation by HHS programs in fiscal year 1998
      ranged from about $2 billion to $3.5 billion.1

      Similarly, the Federal Transit Administration (FTA), within the Department
      of Transportation (DOT), awards grants to local transit operators to provide
      assistance for general public transportation systems, such as bus and
      subway systems, and also makes awards for special purposes, such as
      grants and loans for the special needs of elderly individuals and
      individuals with disabilities. FTA’s overall expenditures for transportation
      services are estimated to exceed $4 billion for fiscal year 1998.



      1
       HHS’ and the Federal Transit Administration’s estimated transportation expenditures, as cited in
      Current State and Local Practices in Planning for Coordinated Transportation, Volpe National
      Transportation Systems Center, Department of Transportation (final revised draft, May 1999).



      Page 1                                              GAO/RCED-00-1 Transportation Coordination
                   B-281617




                   HHS’ and FTA’s transportation investments, which totaled over $6 billion in
                   fiscal year 1998, often failed to complement each other because of a lack
                   of coordination. Coordination can range in scope from the shared use of
                   local facilities, equipment, training, and/or maintenance services to the
                   consolidation of various public and social service providers’
                   transportation services. As HHS and FTA have recognized, the lack of
                   coordination among human services transportation providers and public
                   transit operators contributes to the duplication or overlapping of
                   transportation services. Thus, particular clients may be left unserved or
                   underserved, while transportation providers serving other clients may
                   have excess capacity.

                   Section 3034 of the Transportation Equity Act for the 21st Century
                   (TEA-21) (P.L. 105-178) requires that we report on federal agencies that
                   provide nonemergency human services transportation. As agreed with
                   you, we reviewed (1) the benefits and incentives to human services
                   transportation coordination, (2) HHS’ and FTA’s efforts to identify barriers
                   to transportation coordination, and (3) HHS’ and FTA’s efforts to enhance
                   transportation coordination through state and local transportation
                   planning.


                   Transportation coordination can reduce federal transportation program
Results in Brief   costs by clustering passengers, utilizing fewer one-way trips, and sharing
                   the use of transportation personnel, equipment, and facilities. In addition,
                   people in need of transportation often benefit from the greater and higher
                   quality transportation services available when transportation providers
                   coordinate their operations. A study by the Community Transportation
                   Association of America, a nonprofit transportation association, presented
                   five case studies that showed significant reductions in the average cost per
                   passenger and vehicle hour as a result of transportation coordination. In
                   one instance, the local human services agency’s average cost per
                   passenger trip decreased from $7.92 to $4.06, and the average cost per
                   vehicle hour declined from $12.83 to $6.89. In addition, the five case
                   studies showed that following transportation coordination, there was an
                   increase in the number of trips per month and total trips per passenger
                   hour, while the total number of vehicles in the agencies’ fleets held steady
                   or declined.

                   The most concerted effort by HHS and DOT to identify barriers occurred in
                   1988. At that time, acting through a Coordinating Council established in
                   1986, the agencies identified 64 factors that transportation and human



                   Page 2                                 GAO/RCED-00-1 Transportation Coordination
             B-281617




             services representatives believed were barriers to transportation
             coordination. For each barrier, the Council offered a federal response that,
             in some cases, simply attempted to clarify misunderstandings about
             program requirements. Other responses, however, did not resolve the
             barrier because the issues required legislation, needed additional study, or
             were outside of the control of the Departments. More recently, the
             Coordinating Council held transportation meetings with most states in
             1995 and 1996, but when barriers were addressed in these meetings, the
             comments were often limited to a word or phrase. This level of generality
             made a federal response difficult, and none was undertaken.

             Since 1996, HHS and DOT have been directed by congressional committees
             to advance state and local transportation coordination through joint
             planning guidelines that would address issues such as the expanded use of
             public transit services to deliver human services transportation. In
             response, HHS and DOT, through the Coordinating Council, began
             developing planning guidelines in the spring of 1997. While some progress
             has been made, the joint planning guidelines are still under development.
             The Departments recognize that progress on the guidelines has been slow
             and have assigned a contractor to work with agency officials so the
             guidelines could be issued by the end of 1999. The agencies have also
             concluded that as an entity, the Coordinating Council needs to be
             strengthened. To this end, the two Departments are working on a draft
             strategic plan for the Council that not only lists goals and objectives, but
             specific tasks intended to make the goals and objectives a reality.
             However, this strategic plan has been in draft for several years, and it is
             unclear if and when any of the plan’s proposed tasks will be undertaken.
             In order to focus and expedite the work of the Coordinating Council, this
             report recommends that HHS and DOT issue a prioritized strategic plan by a
             specific date and increase accountability for achieving the work outlined
             in the strategic plan through an action plan and an annual report on the
             Council’s work to the Secretaries of HHS and DOT.


             In many cities, there are numerous public and private providers of
Background   specialized and paratransit services,2 often funded by multiple agencies or
             funding sources.3 All too often, state and local agencies are unaware that

             2
              Paratransit service is more flexible than conventional fixed-route transit service but is more
             structured than the use of private automobiles. It most often refers to wheelchair-accessible,
             demand-response van service.
             3
              Human services transportation systems developed primarily out of a lack of available service for
             agency clients, and this need continues in many areas, as HHS notes that 40 percent of counties do not
             have any public transit service.



             Page 3                                               GAO/RCED-00-1 Transportation Coordination
B-281617




they are, in certain cases, providing transportation services identical and
parallel to those of another agency. As participating agencies coordinate,
the current schedules and passenger loads for each carrier/provider are
analyzed to identify where opportunities exist to consolidate routes,
develop ride-sharing or comingling agreements, and eliminate duplication
and thereby realize efficiencies of scale.

During oversight hearings on rural transportation in 1985, a congressional
committee heard testimony prompted by concerns about the lack of
transportation coordination between federal programs such as those
managed by DOT and HHS.4 Witnesses documented the complexity of the
problems, such as a wide range of programs, diverse client populations,
different administrative practices, and different agencies involved at
federal, state, and local levels. Federal agency heads, state officials, and
program operators also cited instances where coordination had improved
the cost-effective delivery of human services. They called, almost in
unison, for federal leadership to halt fragmentation, duplication, and the
waste of taxpayers’ dollars. One solution proposed by DOT during the
hearings was the establishment of a joint coordinating council between
DOT and HHS.


In October 1986, the Secretaries of Health and Human Services and
Transportation signed an agreement establishing a Joint DOT/HHS
Coordinating Council on Human Services Transportation (Coordinating
Council). The Coordinating Council was established to improve the
efficiency and effectiveness of specialized and human services
transportation by coordinating related programs at the federal level
wherever possible and promoting the maximum feasible coordination at
the state and local levels. The two Departments agreed to work in concert
to promote five goals that include achieving the most cost-effective use of
federal, state, and local resources for specialized and human services
transportation, and six objectives that include removing barriers that
adversely affect the coordination of transportation services. In 1998, the
Council was renamed the Coordinating Council on Mobility and Access,
which, in recent years, has tried to convene for quarterly meetings.
Officials from various HHS and DOT program offices support the Council on
a part-time basis, and their efforts are supplemented by assistance from
contractors.



4
 Hearings on Rural Transportation: The Role of Public and Non-Profit Providers, U.S. House of
Representatives, Committee on Public Works and Transportation, Subcommittee on Oversight and
Investigation (May 1985).



Page 4                                           GAO/RCED-00-1 Transportation Coordination
                     B-281617




                     The Coordinating Council has sought to encourage state-level actions to
                     promote coordination as a key strategy in its effort to promote the
                     coordinated delivery of transportation services. In 1986, when the Council
                     was established, only seven states reported any involvement with
                     transportation coordination, according to DOT officials. State involvement
                     has increased over the years. A 1999 draft report prepared for the
                     Coordinating Council cited various policies for coordinating
                     transportation at the state level, including executive orders establishing
                     statewide coordinating committees and interagency agreements.5 For
                     some states, however, the relevance of the activity listed in this draft
                     report for coordinating transportation was unclear—examples included no
                     formal agreement, an expired executive order, and informal interagency
                     cooperation.

                     In recent years, the Congress has endorsed increased transportation
                     coordination, as reflected by several provisions in TEA-21 supporting this
                     coordination. For instance, one provision directs DOT to encourage
                     transportation coordination through the metropolitan planning process.
                     Another provision states that eligible projects funded through job access
                     and reverse commute grants are to be part of a coordinated public
                     transit-human services transportation planning process. In addition,
                     another TEA-21 provision provides that to the extent feasible, governmental
                     agencies and nonprofit organizations that receive assistance from
                     government sources other than DOT for nonemergency transportation
                     services shall coordinate the design and delivery of transportation services
                     and be included in the planning for those services.


                     Coordinated transportation services encourage efficiency by clustering
Transportation       passengers, utilizing fewer one-way trips, and reducing costs through the
Coordination Has     shared use of personnel, equipment, and facilities. As the Coordinating
Been Shown to Have   Council notes, transportation coordination can also improve overall
                     mobility within a community, particularly in instances when human
Numerous Benefits    service agencies are separately providing transportation for their own
                     clients. Coordination works by reducing the inefficiencies arising from the
                     disparate operations and service patterns that often result from a
                     multiplicity of providers. As the Council observes, coordination can lead
                     to significant reductions in per-trip costs. Furthermore, people in need of
                     transportation often benefit from the greater and higher-quality



                     5
                       Survey of State Coordination Programs and Policies, American Public Works Association,
                     Ecosometrics Inc., and National Transportation Consortium of States (draft, Apr. 1999).



                     Page 5                                            GAO/RCED-00-1 Transportation Coordination
                                          B-281617




                                          transportation services available when transportation providers
                                          coordinate their operations.

                                          In a comparison of the cost and efficiency of transportation services
                                          before and after coordination, a 1992 study by the Community
                                          Transportation Association of America,6 funded by HHS and FTA, presented
                                          case studies from five sites that showed dramatic reductions in passenger
                                          trip costs and vehicle-hour costs after coordination activities were
                                          undertaken.7 In addition, the study showed an increase for all five sites in
                                          the number of passengers per vehicle hour and for total trips while the
                                          number of vehicles in the fleet held steady or decreased. Table 1 shows the
                                          results of the study.


Table 1: Comparison of the Cost and Efficiency of Transportation Services Before and After Coordination/Consolidation at
Five Sites
                                      Grand Rapids/ Kent Washington County, Greenville County,
                Howard County, Md.        County, Mich.              Pa.                   S.C.           Pitt County, N.C.
Measure            Before       After    Before         After       Before         After       Before          After      Before          After
Average cost
per passenger
trip                $7.92       $4.06      $6.11        $5.70       $28.46         $6.25         $6.31        $2.01         $7.13        $3.59
Average cost
per vehicle hour    12.83        6.89      26.27        18.94        22.24         13.28         21.36        12.15         10.66        12.06
Average trips
per month           2,236       4,713    12,180       54,762         2,800         6,300       12,558        15,850         3,880        5,126
Average
passenger per
vehicle hour           2.1        3.4         4.3        12.8           2.9           9.1          2.4          6.04           1.5            3.36
Number of
vehicles               12         12          132         132          N/A           N/A            65            12           41              15
                                          Legend

                                          N/A = not applicable

                                          Source: An Analysis of Human Services Transportation: America’s Other Transit Network, CGA
                                          Consulting Services, Inc., for Community Transportation Association of America (Feb. 1992).



                                          Medicaid transit pass programs initiated at several locations around the
                                          country provide another example of the value of increased transportation

                                          6
                                           The Community Transportation Association of America is an organization consisting primarily of
                                          rural and small community transportation providers, and it serves the dual role of transportation
                                          industry representative and mobility advocate.
                                          7
                                          See An Analysis of Human Services Transportation: America’s Other Transit Network, CGA
                                          Consulting Services, Inc., Community Transportation Association of America (Feb. 1992).



                                          Page 6                                             GAO/RCED-00-1 Transportation Coordination
B-281617




coordination. Medicaid is the largest source of funding for medical and
health-related services for America’s poorest people. In 1996, it provided
health care assistance for more than 36 million persons, at a cost of
$160 billion. As HHS officials noted, federal regulations mandate that each
state Medicaid agency must describe how the agency will ensure
necessary transportation for clients to and from providers for clients
without their own transportation. The most frequent users of
Medicaid-funded transportation services are disabled individuals, elderly
persons, children who are receiving counseling or other services on a
regular basis, and individuals who travel regularly to medical
appointments for services such as dialysis, mental health treatment,
chemotherapy, or physical therapy if they are severely disabled. When
Medicaid provides participants with paratransit service, it often costs
about 10 times the cost of transit fares. But instead of paying for
paratransit services for physically able clients, HHS and DOT note that
Medicaid could provide these clients with monthly bus passes, if they can
access a bus route. HHS’ Health Care Financing Administration sent a letter
to state Medicaid Directors in December 1996 advising them that a
monthly bus pass program can be used if it is cost-effective and
appropriate to the individual’s needs and personal situation. In the
summer of 1999, HHS and DOT issued a brochure on the results of Medicaid
bus pass usage in six states.

According to DOT’s Volpe Center, a notable example of the merits of such
an approach is the Metro Pass program in Dade County, Florida. The Dade
County program encourages those Medicaid recipients who can use the
public transit system to use the monthly Metro Pass, which gives them
unlimited transportation on the fixed-route system at a cost of $30 to $50
per month (including administrative fees). A sample calculation of
monthly savings from the use of the Metro Pass program is provided in
table 2.




Page 7                                GAO/RCED-00-1 Transportation Coordination
                                        B-281617




Table 2: Comparison of Medicaid
Recipient Transportation Costs Before   Time period          Registered          Number of
and After a Metro Pass Program          October 1998         users               trips               Cost per user                    Total
                                        Before Metro         5,084               52,752              $15.28 per trip             $806,051
                                        Pass Program
                                        After Metro Pass     5,084               Unlimited           $38.05 per                  $193,458
                                        Program                                                      montha
                                        Total cost                                                                               $612,592
                                        savings for
                                        October 1998
                                        a
                                        Average cost of monthly pass.

                                        Source: Current State and Local Practices in Planning for Coordinated Transportation, Volpe
                                        National Transportation Systems Center, Department of Transportation (final revised draft,
                                        May 1999).



                                        As table 2 shows, and as estimated by the community transportation
                                        coordinator for Florida’s Dade County, the program saved approximately
                                        $600,000 in October 1998. Furthermore, the local coordinator estimates
                                        that the program has saved $24.6 million since its implementation in 1993.

                                        HHS and DOT reported that on the basis of states’ experiences so far, if 1
                                        percent of the Medicaid recipients in the nation’s 20 largest metropolitan
                                        areas were shifted to transit passes, the savings would be about
                                        $215 million per year. Furthermore, HHS and DOT projected that additional
                                        fares to transit agencies in the nation’s 20 largest metropolitan areas
                                        would be from $21 million to $43 million annually. However, HHS and DOT
                                        cautioned that while transit passes offer the opportunity of multiple trips
                                        per month at great savings to the Medicaid program, local conditions
                                        would affect specific breakeven points. Such conditions include the
                                        proportion of Medicaid recipients in the local community, the number of
                                        medical trips per month required, and the local costs of monthly transit
                                        passes.


                                        When HHS and DOT formed the Coordinating Council in 1986, one of the
HHS’ and FTA’s                          primary objectives established for the Council was the elimination of
Efforts to Identify and                 barriers to the coordination of transportation services. In this context, the
Resolve Barriers to                     Council undertook an early effort to identify and respond to 64 factors that
                                        transportation and human services representatives believed were barriers
Transportation                          to transportation coordination. For each barrier, the Council offered a
Coordination Have                       federal response that in some cases simply attempted to clarify
                                        misunderstandings about program requirements. Other responses,
Been Limited


                                        Page 8                                            GAO/RCED-00-1 Transportation Coordination
                                B-281617




                                however, did not resolve the barrier because issues required legislation,
                                needed additional study, or were outside of the Departments’ control.
                                More recently, the Coordinating Council held transportation meetings with
                                most states in 1995 and 1996, but when barriers were addressed in these
                                meetings, the comments were often limited to a word or phrase. This level
                                of generality made a federal response difficult, and none was undertaken.
                                However, the Council is undertaking several general efforts to improve
                                transportation coordination. For example, the National Transit Resource
                                Center, funded by HHS and FTA, disseminates information on transportation
                                coordination, and HHS is funding another effort related to reporting and
                                recording burdens that may be thwarting transportation coordination.


Most Concerted Effort to        In 1988, the Coordinating Council initiated a nationwide effort to identify
Identify Barriers Occurred      statutory, regulatory, and programmatic barriers to the coordination of
Over a Decade Ago               transportation services. With the assistance of 10 Regional Working
                                Groups—each group included one transportation representative and one
                                human services representative from each of the states—the Coordinating
                                Council solicited the viewpoints of a broad array of individuals and
                                organizations, including transportation providers, local human services
                                agencies, state agencies, and industry associations. The Regional Working
                                Groups forwarded these findings to the Coordinating Council, which, in
                                turn, submitted them to the appropriate offices within HHS and FTA.8 A total
                                of 64 barriers were identified. For each barrier, the Council offered a
                                federal response that in some cases simply attempted to clarify
                                misunderstandings about program requirements. Other responses,
                                however, did not resolve the barrier because issues required legislation,
                                needed additional study, or were outside of the Departments’ control.
                                Examples of the issues that were identified as barriers along with the
                                federal responses follow.

Uncertainty Regarding Federal   One barrier to transportation coordination that was identified was unclear
Responsibilities for            federal roles and responsibilities for transportation, particularly when
Transportation                  individuals are clients of multiple programs. This can lead individual
                                programs to attempt to shift their client transportation costs to other
                                programs, thus reducing the former’s own costs. For example, several
                                states expressed concern that FTA funds were being used to transport
                                clients of human services programs, thus replacing state or local funds
                                that had formerly been provided through HHS programs. HHS and FTA did
                                not address this issue head on. Instead, they noted that it was impossible

                                8
                                 The Urban Mass Transportation Administration had responsibility for transit at this time but was
                                renamed the Federal Transit Administration, which is the term used throughout this report.



                                Page 9                                              GAO/RCED-00-1 Transportation Coordination
                                 B-281617




                                 for them to control the amount of funding that local human services
                                 agencies elect to devote to clients’ transportation or to prevent reductions
                                 in their transportation expenditures. HHS and FTA noted that the larger
                                 question—“Where does DOT’s responsibility end and HHS’ begin?”—in the
                                 area of specialized or human services transportation is also unanswerable,
                                 except to say in broad terms that there is joint responsibility and that both
                                 Departments acknowledge this.

Fragmented Accounting and        Another barrier cited was the lack of standardized accounting and
Reporting                        reporting procedures. Many states complained that there was no
                                 standardized accounting system that human services providers can use for
                                 all of their federal programs. In addition, they said that different programs
                                 have different reporting requirements, resulting in excessive paperwork
                                 for small operators and too many financial and program audits for the
                                 same system. In their view, this fosters a lack of accountability and
                                 coordination at the state level. In response, HHS and FTA pointed to
                                 simplified accounting procedures that they have suggested for use by rural
                                 and specialized transportation. Furthermore, FTA and HHS noted that they
                                 would continue to discuss existing reporting requirements and explore the
                                 development of more common performance standards, accounting, and
                                 reporting for all transportation components of FTA and HHS programs.

Uncertainty in Using Resources   Some grantees stated that they believed that governmentwide regulations
for Other Than Program           prohibit the use of equipment (vehicles) and facilities acquired under one
Constituents                     grant to meet some of the needs of projects supported by different grants.
                                 HHS responded by noting that while there have been statutes governing
                                 individual grant programs that restricted use of grant equipment and
                                 facilities to activities supported by the grant, there is no general
                                 governmentwide regulation prohibiting shared use. HHS also noted that the
                                 governmentwide “common rules” on the fiscal and administrative aspects
                                 of grants require only that first priority for use of the equipment or
                                 facilities go to the grant project.

Prohibition Against Charging     Some states believed that elderly riders should be charged a fare to
Fares Under the Older            provide the needed local match for federal money. HHS noted, however,
Americans Act                    that the Older Americans Act strictly prohibits means testing and denial of
                                 services because an older person cannot or will not pay for services. HHS
                                 noted that it proposed changing this provision in the past, but the
                                 necessary legislative action has not been taken. Nonetheless, HHS stated
                                 that each older person receiving a service under its programs should have
                                 the opportunity to make a contribution, but only the individual older
                                 person should determine whether to contribute and how much.



                                 Page 10                                GAO/RCED-00-1 Transportation Coordination
                           B-281617




Recent Efforts to Follow   Since the 1988 effort by the Coordinating Council, little action has been
Up on Earlier Barrier      taken to identify and resolve transportation coordination barriers, and
Identification Have Been   problems continue to be reported in realizing transportation coordination
                           between HHS and FTA programs. For example, the Council took no specific
Limited                    action after a 1992 Community Transportation Association of America
                           report, funded by HHS and FTA, used two focus groups to identify factors
                           that prevent or impede transportation coordination. Among the most
                           significant issues cited by focus group participants were those dealing
                           with unclear federal guidelines on vehicle use by riders outside the
                           funding agencies’ constituencies, a prohibition against charging fares
                           under the Older Americans Act, the lack of uniform cost measurement
                           systems, and record-keeping and accounting burdens.

                           In 1995 and 1996, HHS and DOT sponsored another nationwide
                           transportation coordination outreach effort. State transportation
                           coordination meetings were held in 9 of 10 national regions,9 which were
                           attended by national and regional representatives of HHS and DOT, their
                           counterparts within the states, plus other invited experts and guests.
                           Topics addressed at some of the meetings included respective levels of
                           progress toward interagency coordination of transportation services,
                           barriers to coordination, important problem areas and issues, and plans
                           for action. This effort differed from the 1988 effort in that not all the states
                           addressed barriers to transportation coordination. Furthermore, when
                           barriers were addressed in these later state meetings, the comments were
                           often limited to a word or a phrase, such as “turf protection” or
                           regulations. This level of generality made a federal response difficult, and
                           none was undertaken. However, the meetings did encourage
                           transportation coordination efforts in some states. In particular, DOT noted
                           that the meetings held in Maryland and New Jersey stimulated vigorous
                           statewide efforts to develop coordination mechanisms, such as a state
                           coordinating council. In addition, HHS noted that several items were
                           identified for federal action following these regional meetings, such as
                           case studies on how to incorporate services for Medicaid clients into local
                           public transportation.

                           While not planning any systematic efforts to identify the extent of
                           transportation coordination barriers, the Council is undertaking other
                           general efforts to improve transportation coordination. For example, the
                           Community Transportation Assistance Project, funded by HHS, and the
                           Rural Technical Assistance Program, funded by FTA, support, among other

                           9
                           Region 9 did not hold a meeting, but two of the Region 9 states—Arizona and Nevada—attended
                           meetings held in other regions.



                           Page 11                                          GAO/RCED-00-1 Transportation Coordination
B-281617




efforts, a National Transit Resource Center that compiles and disseminates
information to help agencies and communities develop better access and
more cost-effective transportation. The Rural Technical Assistance
Program, for example, supported the development of a training video
entitled Transportation Coordination: A Guide to Making It Work for You
that promotes the benefits of coordinated community and human services
transportation by showing interviews with a number of individuals
working in, or served by, such systems. Another effort is a 1996 report
funded by the Community Transportation Assistance Project that
identifies transportation funding sources in federal programs.10

Furthermore, on occasion, specific barriers to transportation coordination
are discussed at HHS and DOT coordinating meetings. For instance, the
issue of burdensome reporting and record-keeping was discussed at a
July 1998 planning meeting, which led HHS to task a contractor,
Ecosometrics, Inc., with doing some preliminary work at four locations to
better analyze the problem. In the summer of 1999, the contractor was
analyzing the results from these case studies. An initial finding from the
case studies is that it is not so much any particular requirement that
creates concerns but, rather, the weight of them together that frustrates
transportation providers. In addition, the case studies indicate that the
role of state reporting requirements may be contributing to reporting
burdens to a greater extent than federal requirements. HHS considers these
case studies to be the first phase of a larger project. HHS officials noted
that they had received a draft report for this first phase of the project and
expect to receive the final report by October 31, 1999. A representative of
Ecosometrics stated that his firm expects to continue this effort with more
case studies in 2000.

One recent communication tool employed by the Coordinating Council
that could have an impact on the elimination of coordination barriers is an
Internet site developed for the Council by a contractor in the spring of
1999. The Council’s Internet site contains information about the
Coordinating Council, the reasons for coordinating transportation
services, transportation coordination strategies, a listing of publications
about coordinated transportation, and related sites of interest. The site
also solicits questions or comments about the Coordinating Council, thus
providing an opportunity to clarify misconceptions that could be
hampering transportation coordination efforts. The utility of the site for
resolving barriers, however, is limited by two design weaknesses. First, as

10
   Building Mobility Partnerships: Opportunities for Federal Funding, prepared for the Community
Transportation Assistance Project by the Community Transportation Association of America
(May 1996).



Page 12                                            GAO/RCED-00-1 Transportation Coordination
                               B-281617




                               of August 1999, the Council’s Internet site had not yet been linked to the
                               main HHS or FTA Internet sites, although it can be accessed directly when
                               the specific Internet address is known (www.ccamweb.org). Second,
                               while the site is designed to enable users to search on key words, our tests
                               indicated that this design component was not working. HHS and FTA
                               officials recognized the site’s weaknesses and said the Internet site is still
                               developmental, and they hope to develop the search feature for the site as
                               well as develop a “frequently asked question” section that could help to
                               mitigate barriers to transportation coordination.


                               The Coordinating Council has been working on developing joint state and
Improved                       local planning guidelines to advance transportation coordination, as
Transportation                 directed by congressional committees since 1996. While some progress has
Coordination Through           been made, the joint planning guidelines are still under development and
                               have a tentative issue date set for the end of 1999. In addition, TEA-21
State and Local                directs DOT to encourage transportation coordination through the
Planning Guidance              metropolitan planning process. A revised DOT planning regulation is
                               expected to address transportation coordination, and DOT expects to issue
Not Yet Realized               a proposed rule by the end of 1999. The Departments also recognize that
                               the Coordinating Council, as an entity, needs to be strengthened. To this
                               end, the two Departments are working on a draft strategic plan for the
                               Council that not only lists goals and objectives, but specific tasks intended
                               to make the goals and objectives a reality. However, this strategic plan has
                               been in draft for several years, and it is unclear if and when any of the
                               plan’s proposed tasks will be undertaken.


Transportation                 Since 1996, congressional committees have repeatedly directed HHS and
Coordination Planning          DOT to develop guidelines for state and regional planning to achieve

Guidelines Still in Progress   specific transportation coordination objectives. For example, in reports
                               accompanying the DOT appropriations bills for fiscal years 1997 and 1998,
                               the Senate Committee on Appropriations noted that the coordination of
                               transportation for persons with disabilities, seniors, and others funded by
                               HHS programs or by public transit authorities must be planned and
                               implemented at the state and regional levels in order to ensure
                               cost-effective service delivery and improve access to HHS program
                               services. Specifically, the Committee directed the Secretary of
                               Transportation, working with the Secretary of Health and Human Services
                               through the Coordinating Council, to develop guidelines for state and
                               regional planning to achieve specific transportation coordination
                               objectives, including, but not limited to,



                               Page 13                                GAO/RCED-00-1 Transportation Coordination
    B-281617




•   the joint identification of the transportation needs of human services
    clients and the appropriate mix of transportation services to meet those
    needs,
•   the expanded use of public transit services for human services
    transportation, and
•   cost-sharing arrangements for HHS program clients transported by
    Americans With Disabilities Act paratransit systems based on a uniform
    accounting system.

    In the spring of 1997, the Coordinating Council established a working
    group to develop transportation coordination guidelines. The working
    group focused on three principal efforts. First, a report on developing a
    framework for state and local human services transportation planning was
    prepared by a consultant.11 The report noted fundamental differences in
    the role of transportation for the recipients of funding from HHS and DOT.
    As the report explains, transportation is the primary or even sole mission
    for most of the recipients of FTA funds; whereas, many recipients of HHS
    funding are multiservice organizations. For these multiservice
    organizations, transportation is seen as an ancillary service enabling them
    to accomplish their key missions; transportation is only one of many
    services offered to their clients. For FTA, the report identifies and provides
    background information on seven programs. For HHS, the report identifies
    and provides background information on 12 primary programs that
    frequently purchase transportation services or at times provide
    transportation services to program clients. As the report notes, although
    transportation activities vary significantly among the 12 HHS programs,
    many of these programs are required “to reflect the principles of
    devolution. This means they operate with minimal Federal guidance on
    transportation issues, including planning requirements, program review,
    priority setting, service provision, and oversight.” Recognizing the
    challenge of modifying the planning processes within the differing
    program cultures, the report presents various options for obtaining more
    coordinated planning, such as policy statements in support of coordinated
    planning efforts and technical assistance on coordinated planning
    practices and strategies.

    Second, in order to receive stakeholders’ input at an early stage in the
    development of the planning guidelines, the Council convened an advisory
    panel workshop on July 1, 1998. The advisory panel included
    representatives from transit authorities, health care representatives, and

    11
     Recommended Framework for Developing State and Local Human Services Transportation Planning
    Guidance, Ecosometrics, Inc. (Sept. 22, 1998).



    Page 14                                        GAO/RCED-00-1 Transportation Coordination
    B-281617




    representatives from state and local governments. Key points expressed by
    the stakeholders at this meeting included the following:

•   More coordination in the planning process would increase the
    cost-effectiveness of human services transportation efforts. Planning is
    critical to starting, improving, or expanding the coordination of services.
    Coordinated planning should promote the free flow of information
    necessary to design more responsive transportation systems.
•   Coordination is difficult, and it is a lot of work. Many people need to be
    convinced that it is worth the effort. Most agencies do not have the basic
    facts and figures needed to analyze their own transportation services,
    particularly with respect to fully allocated costs. A data-intensive
    approach yields many benefits.
•   Public transit services for human services agencies’ programs and their
    clients may decline without a commitment to coordinate planning and
    resources. Growing elderly populations accentuate the need for additional
    services.
•   Financial and other incentives are needed to support transportation
    coordination efforts, and these incentives could include added
    consideration during grant reviews, special recognition through the
    Coordinating Council, and departmental recognition efforts.

    Third, DOT’s Volpe Center conducted an effort in support of the
    development of the joint planning guidelines. On the basis of a list of
    selected states and urban and rural areas believed to have experience in
    coordinating transportation services, staff of the Volpe Center conducted
    telephone interviews with representatives from the candidate areas to
    gather information on the history and background of transportation
    coordination efforts in their areas. Thereafter, Volpe staff conducted a
    second round of interviews focusing their efforts on developing 15 case
    studies of transportation coordination. The case studies were used to
    examine broad coordination strategies, such as the joint identification of
    clients’ needs, shared planning resources, and the establishment of
    cost-sharing arrangements, that can be used as part of a process for
    coordinating transportation services of human services and transit
    agencies.

    For instance, the Volpe Center study notes that the joint identification of
    clients’ needs can contribute to a coordinated approach to transportation
    service delivery in a number of ways. When the needs of each agency’s
    clients are regarded collectively, the participants are then able to take the
    first step in scoping the size and breadth of the coordinated system. The



    Page 15                                GAO/RCED-00-1 Transportation Coordination
B-281617




clients’ needs will include the type of transportation needed, the origins
and destinations of trips, and the timing and frequency of required trips.
Once participating agencies have this information, they will be able to
adjust existing paratransit services or create new services as needed while
achieving efficiencies through the comingling of clientele or coordinated
dispatching of services. The study cited the Mass Transportation Authority
(MTA) in Flint, Michigan, as an example of achieving efficiencies through a
comingled clientele. MTA provides public transportation for the Flint
School District (except for special education) and comingles school
children with the general public at a considerable cost savings to the
district. Formerly, it cost the district $660 per student for transportation
on an annual basis. Now, MTA provides that service at $264 per student.

Following the consultant’s and the Volpe Center’s reports, HHS and FTA
officials planned to have their staff develop and distribute draft guidance
through a multistep comment process. The status of the guidelines is
addressed at periodic Council meetings along with comments about the
need to bring this effort to closure. For instance, the FTA Deputy
Administrator noted at an April 1998 Coordinating Council meeting that
HHS and FTA have been working on a number of transportation
coordination issues over the years, including the joint planning guidelines,
and that these efforts need to be brought to closure. However, the
development of the guidelines stalled, and, in the spring of 1999, HHS and
DOT officials decided to have a contractor assist them in developing an
initial draft of the guidelines.

A first draft of the guidelines was prepared on July 30, 1999. The draft
provides introductory information about coordination and how interest in
coordination has developed over time. The draft also contains a checklist
of general steps needed for a coordinated planning process, such as the
need to understand and document the transportation needs and resources
of the local area and involve the local community in the planning process.
Other material excerpted from the reports to the Council from the Volpe
Center and Ecosometrics, Inc., consists of background information on
primary HHS programs providing transportation services and FTA programs,
a discussion of planning requirements, and actual case studies of how
coordinated planning has led to more cost-effective transportation
services in different communities. However, it remains unclear how these
guidelines, as drafted, will fulfill their intended purpose, which is to assist
state and local officials in achieving specific coordination objectives,
including, but not limited to, (1) the joint identification of clients’
transportation needs and the appropriate mix of transportation services to



Page 16                                 GAO/RCED-00-1 Transportation Coordination
                        B-281617




                        meet those needs, (2) the expanded use of public transit to deliver human
                        services transportation, and (3) cost-sharing arrangements for program
                        clients transported by paratransit systems based on a uniform accounting
                        system.

                        The guidelines will likely become more responsive to these objectives as
                        they become fully developed and refined after reviews and revisions by
                        various HHS and FTA program officials and outside parties via the Council’s
                        new Internet site. After comments are received and considered by HHS and
                        FTA, the guidelines will be issued. HHS officials estimate that the guidelines
                        will be issued by the end of 1999.


TEA-21 Encourages       In addition to directing HHS and DOT to develop joint guidelines on
Transportation          transportation coordination during the appropriation process, TEA-21 has
Coordination Planning   several provisions supporting coordinated transportation planning. For
                        instance, one provision directs DOT to encourage transportation
                        coordination through the metropolitan planning process. In response to
                        TEA-21’s planning provisions, DOT officials plan to issue a revised planning
                        regulation. According to DOT, the transportation community provided
                        extensive input on planning and environmental issues during a TEA-21
                        outreach effort conducted by DOT’s Office of the Secretary during 1998. In
                        order to focus and continue discussion by partners and stakeholders, the
                        Federal Highway Administration and FTA prepared a paper entitled
                        “TEA-21 Planning and Environmental Provisions: Options for
                        Discussion.” The document presents issues and implementation options
                        relative to the planning and environmental provisions of TEA-21. However,
                        the document does not address the TEA-21 provision that directs the
                        Secretary of Transportation to encourage each metropolitan planning
                        organization to coordinate, to the maximum extent practicable, the design
                        and delivery of transportation services within the metropolitan planning
                        area. According to FTA planning officials, this provision was not initially
                        included in the options for the discussion paper because the legislative
                        provision referred to encouraging rather than requiring coordination.
                        These officials noted, however, that the revised planning regulation is
                        expected to address the coordination issue. As of August 1999, the
                        planning regulation was still under development, but FTA officials expect
                        to issue the notice of proposed rulemaking by the end of 1999.

                        Furthermore, FTA officials note that a coordinated planning environment
                        may be advanced through other TEA-21 provisions and federal
                        transportation coordination efforts. For instance, a TEA-21 provision



                        Page 17                                 GAO/RCED-00-1 Transportation Coordination
                             B-281617




                             provides that to the extent feasible, governmental agencies and nonprofit
                             organizations that receive assistance from government sources other than
                             DOT for nonemergency transportation services shall coordinate the design
                             and delivery of transportation services and be included in the planning for
                             those services. Another TEA-21 transportation coordination provision
                             relates to job access and reverse commute grants and requires each
                             application for funds to reflect coordination with and the approval of
                             affected transit grant recipients. As an FTA official noted, advancing
                             transportation coordination efforts becomes easier when a new program,
                             such as job access and reverse commute grants, provides additional funds
                             and links the receipt of the funds to the concept of transportation
                             coordination.

                             In addition, the Coordinating Council sent a memorandum to HHS’ and
                             FTA’s regional offices on August 20, 1999, directing them to develop
                             regional action plans that include plans to promote transportation
                             coordination guidelines. Regional Working Groups were instrumental in
                             the Coordinating Council’s early efforts to identify statutory, regulatory,
                             and programmatic barriers to the coordination of transportation services.
                             However, according to Coordinating Council members, only some regional
                             groups continue to address transportation coordination, but the hope is
                             that the recent memorandum will stimulate activity by all 10 Regional
                             Working Groups.


Proposed Strategic Plan to   The Coordinating Council was established in 1986 to improve the
Strengthen the               efficiency and effectiveness of specialized and human services
Coordinating Council Still   transportation by coordinating related programs at the federal level
                             wherever possible and promoting the maximum feasible coordination at
Not Finalized                the state and local levels. HHS and DOT agreed to work in concert to
                             promote the purpose of the Council through five goals and six related
                             objectives. A Council goal, for example, is to achieve the most
                             cost-effective use of federal, state and local resources for specialized and
                             human services transportation, and one of the objectives is to remove
                             barriers that adversely affect the coordination of transportation services.

                             In 1995, HHS and FTA officials began efforts to strengthen the future work of
                             the Council by providing it with a draft strategic plan- -a blueprint- -for
                             advancing transportation coordination. The draft strategic plan list goals
                             and objectives, as well as specific tasks intended to make the goals and
                             objectives a reality. A draft of the Council’s strategic plan shows that its
                             efforts would be significantly expanded to 6 goals, 27 objectives, and 30



                             Page 18                                GAO/RCED-00-1 Transportation Coordination
              B-281617




              related tasks- -an ambitious undertaking, particularly since there is no
              prioritization of the goals, objectives, or tasks. One proposed goal is to
              achieve the most cost-effective use of federal, state, and local resources
              for transportation. Accompanying objectives for this goal include
              (1) maximizing opportunities for coordinating transportation program
              resources at federal, state, and local levels; (2) reducing the duplication of
              services; (3) identifying and encouraging cost-effective transportation
              services, and; (4) developing rapid response capabilities for implementing
              new technologies for transportation and/or access to community services.

              Several of the proposed tasks in the strategic plan relate to barriers. For
              instance, one proposed task is to identify regulatory barriers to
              coordination. Another proposed task would highlight the work of the
              Council through an annual report on efforts to reduce barriers,
              disseminate transportation coordination information, and note special
              projects. An additional proposed task would be to have action plans and
              annual updates submitted from each member agency to the Council.

              HHS’ and FTA’s attention to the development of this strategic plan has been
              sporadic, and there is no set date for finalizing the strategic plan. Although
              the need to issue this plan in the near future was noted at a June 1996
              Council meeting, the strategic plan for the Council continues to languish in
              a draft state, thus it is unclear when proposed tasks would be undertaken.
              Furthermore, given the difficulties the Council has experienced in bringing
              issues to closure, the scope of the strategic plan- –6 goals, 27 objectives,
              and 30 tasks- -could prove to be an overwhelming agenda, particularly
              given the lack of any prioritization within the strategic plan.


              Transportation coordination has the potential for realizing more efficient
Conclusions   and cost-effective transportation services. While the Coordinating Council
              has a long record of supporting transportation coordination initiatives, the
              Council’s efforts have been erratic and slow to produce results. A draft
              strategic plan for the Coordinating Council has a number of good ideas for
              moving the Council forward, such as an annual report for the Council,
              which, at a minimum, should include a report on barriers, dissemination
              efforts, and special projects. However, the draft strategic plan for the
              Council entails 6 goals, 27 objectives, and 30 tasks, which is a broad and
              perhaps overwhelming agenda, given the Council’s past level of
              performance and the lack of any prioritization within the strategic plan.
              Furthermore, the strategic plan could continue to languish in draft, since
              there is no set issuance date.



              Page 19                                 GAO/RCED-00-1 Transportation Coordination
                  B-281617




                  Congressional committees have repeatedly directed HHS and DOT to
                  develop guidelines to enhance transportation coordination through state
                  and local planning since 1996; these guidelines remain under development
                  and now have a tentative issuance date set for the end of 1999. Also under
                  development is a revised planning regulation that is expected to reflect a
                  TEA-21 provision directing that DOT encourage each metropolitan planning
                  organization to coordinate, to the maximum extent practicable, the design
                  and delivery of transportation services within the metropolitan planning
                  area. However, since both of these efforts remain works-in-progress, it is
                  unclear how, if at all, they will reinforce each other.

                  While efforts are under way to have the 10 Regional Working Groups
                  develop action plans, HHS and FTA are not instructing these Regional
                  Working Groups to assess barriers to transportation coordination. In
                  addition, no similar action agenda exists for the Coordinating Council.
                  However, the Coordinating Council recently developed its own Internet
                  site, which has the potential to be a powerful communication tool,
                  providing information on a host of coordination issues including barriers
                  to coordination. The utility of the site for resolving barriers, however, is
                  limited by two design weaknesses. First, as of August 1999, the Council’s
                  Internet site had not yet been linked to the main HHS or FTA Internet sites,
                  although it can be accessed directly when the specific Internet address is
                  known (www.ccamweb.org). Second, while the site is designed to enable
                  users to search on key words, our tests indicated that this design
                  component was not working.


                  In order to improve transportation coordination through better planning
Recommendations   and enhanced accountability, we recommend that the Secretary of Health
                  and Human Services and the Secretary of Transportation (1) require the
                  Coordinating Council to issue a prioritized strategic plan by a specific
                  date, (2) charge the Coordinating Council with developing an action plan
                  with specific responsibilities, and (3) require an annual report from the
                  Council on its major initiatives and accomplishments. As part of these
                  planning efforts, the agencies should also (1) make sure that
                  transportation coordination planning efforts under development reinforce
                  one another, (2) direct the Regional Working Groups to assess barriers to
                  transportation coordination, and (3) make information on coordination
                  barriers and strategies for overcoming the barriers readily available
                  through the Council’s Internet site.




                  Page 20                                GAO/RCED-00-1 Transportation Coordination
                  B-281617




                  We provided DOT and HHS with a draft of this report for their review and
Agency Comments   comment. DOT generally agreed with the draft report that measures could
                  be taken to expedite some of the Coordinating Council’s actions and
                  sharpen its strategic planning and management processes. DOT, however,
                  stated that the draft report did not sufficiently recognize the Council’s
                  accomplishments or the progress that has been made to improve
                  transportation coordination. We recognize that progress has been made
                  and conclude that the Council has a long record of supporting
                  transportation coordination initiatives. But we also conclude that the
                  Council’s efforts have been erratic. Furthermore, many of the examples of
                  the Council’s accomplishments in improving transportation coordination
                  cited by DOT were already recognized in our draft report. We agree with
                  DOT that regional meetings may have led to improved coordination efforts
                  in some states and have incorporated information in our draft report to
                  reflect this point. Moreover, we expanded our discussion on the Transit
                  Resource Center and its funding sources as a result of DOT’s comments.
                  The complete text of DOT’s comments appears in appendix I.

                  HHS  generally agreed with the report’s recommendations. However, HHS
                  stated that the draft report presented a narrow interpretation of the work
                  of the Coordinating Council and noted that the draft report failed to
                  recognize HHS establishment of the Community Transportation Assistance
                  Project, which it considers to be the backbone of HHS’ technical assistance
                  efforts on transportation issues. While the draft report recognized the
                  Transit Resource Center, which receives funding through the Community
                  Transportation Assistance Project, we have added a more detailed
                  reference to the Community Transportation Assistance Project. HHS also
                  commented that our draft report did not recognize the significance of the
                  transportation planning guidelines under development. Our draft report
                  traced the history of the development of these joint guidelines. On the
                  basis of this first draft of the guidelines, we believe that the way that they
                  will fulfill their intended purpose is unclear. However, we note that the
                  responsiveness of the guidelines to their intended purpose will likely be
                  strengthened as they become fully developed and refined after reviews
                  and revisions by various HHS and FTA program officials and outside parties.
                  The complete text of HHS’ comments appears in appendix II. Furthermore,
                  HHS made additional technical clarifications, which were incorporated into
                  the draft report, as appropriate.


                  To review the benefits and incentives to human services transportation
Scope and         coordination, we analyzed state, regional, and local best practices in
Methodology

                  Page 21                                GAO/RCED-00-1 Transportation Coordination
B-281617




human services transportation for the benefits realized and the incentives
that have fostered coordinated transportation. We discussed the benefits
and the incentives with HHS and FTA officials participating in the Joint
Coordinating Council and with consultants for the Council, and we
reviewed federal research directories and reports, including reports at the
National Transit Resource Center—a national transportation
clearinghouse. To review the efforts that HHS and FTA have taken to identify
and address barriers to coordination, we tracked barriers identified
through surveys and state outreach meetings, HHS and FTA regional input
and Coordinating Council meetings, and the federal response to barriers or
perceived barriers identified through these sources. We discussed the
barriers or perceived barriers with HHS and FTA officials participating in the
Coordinating Council and with consultants for the Council, and we
reviewed transportation coordination reports. To identify HHS’ and DOT’s
actions to facilitate planning processes that enhance transportation
coordination efforts, we focused on HHS’ and FTA’s efforts to develop
coordinated guidelines. We reviewed their primary efforts—reports and
meetings —expected to contribute to the development of the guidelines
and monitored the progress of the guidelines through discussions with HHS
and FTA officials and attendance at Coordinating Council meetings. We
also considered provisions in TEA-21 that would reinforce planning efforts
aimed at transportation coordination and discussed these issued with FTA
officials.

We performed our review from September 1998 through August 1999 in
accordance with generally accepted government auditing standards.


We are sending copies of this report to the appropriate congressional
committees; the Honorable Donna E. Shalala, Secretary of Health and
Human Services; the Honorable Rodney E. Slater, Secretary of
Transportation; and other interested parties. We will also make copies
available to others on request.




Page 22                                GAO/RCED-00-1 Transportation Coordination
B-281617




Please call me at (202) 512-3650 if you have any questions. Major
contributors to this report were Yvonne Pufahl and Ron Stouffer.




Phyllis F. Scheinberg
Associate Director,
Transportation Issues




Page 23                               GAO/RCED-00-1 Transportation Coordination
Appendix I

Comments From the Department of
Transportation




             Page 24       GAO/RCED-00-1 Transportation Coordination
Appendix I
Comments From the Department of
Transportation




Page 25                           GAO/RCED-00-1 Transportation Coordination
Appendix I
Comments From the Department of
Transportation




Page 26                           GAO/RCED-00-1 Transportation Coordination
Appendix II

Comments From the Department of Health
and Human Services




              Page 27      GAO/RCED-00-1 Transportation Coordination
Appendix II
Comments From the Department of Health
and Human Services




Page 28                                  GAO/RCED-00-1 Transportation Coordination
Appendix II
Comments From the Department of Health
and Human Services




Page 29                                  GAO/RCED-00-1 Transportation Coordination
           Appendix II
           Comments From the Department of Health
           and Human Services




(348124)   Page 30                                  GAO/RCED-00-1 Transportation Coordination
Ordering Information

The first copy of each GAO report and testimony is free.
Additional copies are $2 each. Orders should be sent to the
following address, accompanied by a check or money order
made out to the Superintendent of Documents, when
necessary. VISA and MasterCard credit cards are accepted, also.
Orders for 100 or more copies to be mailed to a single address
are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office
P.O. Box 37050
Washington, DC 20013

or visit:

Room 1100
700 4th St. NW (corner of 4th and G Sts. NW)
U.S. General Accounting Office
Washington, DC

Orders may also be placed by calling (202) 512-6000
or by using fax number (202) 512-6061, or TDD (202) 512-2537.

Each day, GAO issues a list of newly available reports and
testimony. To receive facsimile copies of the daily list or any
list from the past 30 days, please call (202) 512-6000 using a
touchtone phone. A recorded menu will provide information on
how to obtain these lists.

For information on how to access GAO reports on the INTERNET,
send an e-mail message with "info" in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web Home Page at:

http://www.gao.gov




PRINTED ON    RECYCLED PAPER
United States                       Bulk Rate
General Accounting Office      Postage & Fees Paid
Washington, D.C. 20548-0001           GAO
                                 Permit No. G100
Official Business
Penalty for Private Use $300

Address Correction Requested