U.S. OFFICE OF PERSONNEL MANAGEMENT
OFFICE OF THE INSPECTOR GENERAL
OFFICE OF AUDITS
Final Audit Report
Subject:
BLUECROSS BLUESHIELD OF MINNESOTA
EAGAN, MINNESOTA
Report No. lA-IO-78-10-002
Date: March 30, 2010
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UNITED STATES OFFICE OF PERSONNEL MANAGEMENT
Washington, DC 20415
Office of the
Inspector General
AUDIT REPORT
Federal Employees Health Benefits Program
Service Benefit Plan Contract CS 1039
BlueCross BlueShield Association
Plan Code 10
BlueCross BlueShield of Minnesota
Plan Codes 2201720
Eagan, Minnesota
REPORT NO. lA-10-78-1O-002 DATE: March 30, 2010
;;;IPgL-
Michael R. Esser
Assistant Inspector General
for Audits
www.opm.gov www.usajobs.goY
UNITED STATES OFFICE OF PERSONNEL MANAGEMENT
Washington, DC 20415
Office of the
Inspector General
EXECUTIVE SUMMARY
Federal Employees Health Benefits Program
Service Benefit Plan Contract CS 1039
BlueCross BlueShield Association
Plan Code 10
BlueCross BlueShield of Minnesota
Plan Codes 2201720
Eagan, Minnesota
REPORT NO. lA-1O-78-10-002 DATE: March 30, 2010
This final audit report on the Federal Employees Health Benefits Program (FEHBP) operations
at BlueCross BlueShield of Minnesota (Plan), in Eagan, Minnesota, questions $33,482 in health
benefit charges and lost investment income (LII). The BlueCross BlueShield Association agreed
(A) with this questioned amount.
Our limited scope audit was conducted in accordance with Government Auditing Standards. The
audit covered claim payments from January 1,2006 through June 30, 2009, as well as
miscellaneous payments and credits from 2004 through 2008 as reported in the Annual
Accounting Statements.' In addition, we reviewed the Plan's cash management practices related
to FEHBP funds for contract years 2004 through 2008. Due to errors identified during our
review of fraud recoveries, we expanded our audit scope to also include fraud recoveries in 2009.
Questioned items are summarized as follows:
I For claim payments, we only performed a system review of claims paid from January 1, 2008 through June 30, 2009,
and reviewed a listing of debarred providers to determine if any claims were inappropriately paid to these providers
from January 1,2006 through June 30, 2009.
www.opm.gov www.usajobs.gov
HEALTH BENEFIT CHARGES
Claim Payments
The audit disclosed no findings pertaining to claim payments. Overall, we concluded that the
claims in our system review and debarred provider samples were paid in accordance with the
FEHBP contract, the Service Benefit Plan brochure, the Plan's provider agreements, and/or the
Association's Federal Employee Program administrative manual.
Miscellaneous Payments and Credits
• ProviderSettlements fA) $24,734
The Plan overcharged the FEHBP for two provider settlements paid in 2007. As a result, the
FEHBP is due $24,734, consisting of $21,932 for provider settlement overcharges and
$2,802 for LII.
• Fraud Recoveries and Health Benefit Refunds (A) $8,748
The Plan did not return six fraud recoveries and three health benefit refunds to the FEHBP.
As a result, the FEHBP is due $8,748, consisting of$8,153 for recoveries and refunds not
returned and $595 for LII.
CASH MANAGEMENT
Overall, we concluded that the Plan handled FEHBP funds in accordance with Contract CS 1039
and applicable laws and regulations, except for the audit findings pertaining to cash management
notedin the "Miscellaneous Payments and Credits" section.
11
CONTENTS
PAGE
EXECUTIVE SUMMARY ~ , .i
I. INTRODUCTION AND BACKGROUND 1
II. OBJECTIVES, SCOPE, AND METHODOLOGy 3
III. AUDIT FINDINGS AND RECOMMENDATIONS 6
A. HEALTIl BENEFIT CHARGES 6
1. Claim Payments 6
2. Miscellaneous Payments and Credits ; 6
a. Provider Settlements 6
b. Fraud Recoveries and Health Benefit Refunds 7
B. CASH MANAGEMENT 9
IV. MAJOR CONTRIBUTORS TO THIS REPORT 10
V. SCHEDULE A - HEALTH BENEFIT CHARGES AND AMOUNTS QUESTIONED
APPENDIX (BlueCross BlueShield Association reply, dated February 22, 2010, to
the draft audit report)
I. INTRODUCTION AND BACKGROUND
INTRODUCTION
This final audit report details' the findings, conclusions, and recommendations resulting from our
limited scope audit of the Federal Employees Health Benefits Program (FEHBP) operations at
BlueCross BlueShield of Minnesota (Plan). The Plan is located in Eagan, Minnesota.
The audit was performed by the Office of Personnel Management's (OPM) Office of the Inspector
General (OIG), as established by the Inspector General Act of 1978, as amended.
BACKGROUND
The FEHBP was established by the Federal Employees Health Benefits (FEHB) Act (Public Law
86-382), enacted on September 28, 1959. The FEHBP was created to provide health insurance
benefits for federal employees, annuitants, and dependents. OPM's Retirement and Benefits
Office has overall responsibility for administration of the FEHBP. The provisions of the FEHB
Act are implemented by OPM through regulations, which are codified in Title 5, Chapter 1, Part
890 of the Code of Federal Regulations (CFR). Health insurance coverage is made available
through contracts with various health insurance carriers.
The BlueCross BlueShield Association (Association), on behalf of participating BlueCross and
BlueShield plans, has entered into a Government-wide Service Benefit Plan contract (CS 1039)
with OPM to provide a health benefit plan authorized by the FEHB Act. The Association
delegates authority to participating local BlueCross and BlueShield plans throughout the United
States to process the health benefit claims of its federal subscribers. The Plan is one of
approximately 63 local BlueCross and BlueShield plans participating in the FEHBP.
The Association has established a Federal Employee Program (FEp I ) Director's Office in
Washington, D.C. to provide centralized management for the Service Benefit Plan. The FEP
Director's Office coordinates the administration of the contract with the Association, member
BlueCross and BlueShield plans, and OPM.
The Association has also established an FEP Operations Center. The activities of the FEP
Operations Center are performed by CareFirst BlueCross BlueShield, located in Washington,
D.C. These activities include acting as fiscal intermediary between the Association and member
plans, verifying subscriber eligibility, approving or disapproving the reimbursement oflocal plan
payments ofFEHBP claims (using computerized system edits), maintaining a history file of all
FEHBP claims, and maintaining an accounting of all program funds.
I Throughout this report, when we refer to "FEP" we are referring to the Service Benefit Plan lines of business at the
Plan. When we refer to the "FEHBP" we are referring to the program that provides health benefits to federal
employees.
1
Compliance with laws and regulations applicable to the FEHBP is the responsibility of the
Association and Plan management. Also, management of the Plan is responsible for establishing
and maintaining a system of internal controls.
All findings from our prior audit of the Plan (Report No. lA-10-78-05-005, dated September 15,
2006) for contract years 1999 through 2003 were satisfactorily resolved, except for a finding
related to claim payment errors, which is in the process of being resolved.
The results of this audit were provided to the Plan in written audit inquiries; were discussed with
Plan and/or Association officials throughout the audit and at an exit conference; and were
presented in detail in a draft report, dated January 22, 2010. The Association's comments
offered in response to the draft report were considered in preparing our final report and are
included as an Appendix to this report.
2
II. OBJECTIVES, SCOPE, AND METHODOLOGY
OBJECTIVES
The objectives of our audit were to determine whether the Plan charged costs to the FEHBP and
provided services to FEHBP members in accordance with the terms of the contract. Specifically,
our objectives were as follows:
Health Benefit Charges
• To determine whether the Plan complied with contract provisions relative to benefit
payments.
• To determine whether miscellaneous payments charged to the FEHBP were in
compliance with the terms of the contract.
• To determine whether credits and miscellaneous income relating to FEHBP benefit
payments were returned promptly to the FEHBP.
Cash Management
• To determine whether the Plan handled FEHBP funds in accordance with applicable
laws and regulations concerning cash management in the FEHBP.
SCOPE
We conducted our limited scope performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform the audit to
obtain sufficient and appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.
We reviewed the BlueCross and BlueShield FEHBP Annual Accounting Statements as they
pertain to Plan codes 220 and 720 for contract years 2004 through 2008. During the period, the
Plan paid approximately $1.1 billion in health benefit charges (See Schedule A).
Specifically, we reviewed approximately $9 million in claim payments made from January 1,
2006 through June 30, 2009. In addition, we reviewed miscellaneous payments and credits,
such as refunds and subrogation recoveries, and cash management for 2004 through 2008. Due
to errors identified during our review of fraud recoveries, we expanded our audit scope to also
include all fraud recoveries in 2009.
2 For claim payments, we only performed a system review of claims paid from January 1,2008 through June 30, 2009,
and reviewed a listing of debarred providers to determine if any claims were inappropriately paid to these providers
from January 1,2006 through June 30, 2009.
3
In planning and conducting our audit, we obtained an understanding of the Plan's internal control
structure to help determine the nature, timing, and extent of our auditing procedures. This was
determined to be the most effective approach to select areas of audit. For those areas selected,
we primarily relied on substantive tests of transactions and not tests of controls. Based on our
testing, we did not identify any significant matters involving the Plan's internal control structure
and its operation. However, since our audit would not necessarily disclose all significant matters
in the internal control structure, we do not express an opinion on the Plan's system of internal
controls taken as a whole.
We also conducted tests to determine whether the Plan had complied with the contract, the
applicable procurement regulations (i.e., Federal Acquisition Regulations (FAR) and Federal
Employees Health Benefits Acquisition Regulations (FEHBAR), as appropriate), and the laws
and regulations governing the FEHBP. The results of our tests indicate that, with respect to the
items tested, the Plan did not comply with all provisions of the contract and federal procurement
regulations. Exceptions noted in the areas reviewed are set forth in detail in the "Audit Findings
and Recommendations" section of this audit report. With respect to the.items not tested, nothing
came to our attention that caused us to believe that the Plan had not complied, in all material
respects, with those provisions.
In conducting our audit, we relied to varying degrees on computer-generated data provided by
the FEP Director's Office, the FEP Operations Center and the Plan. Due to. time constraints, we
did not verify the reliability ofthe data generated by the various information systems involved.
However, while utilizing the computer-generated data during our audit testing, nothing came to
our attention to cause us to doubt its reliability. We believe that the data was sufficient to
achieve our audit objectives.
The audit was performed at the Plan's office in Eagan, Minnesota from October 12 through
October 23, 2009. Audit fieldwork was also performed at our office in Cranberry Township,
Pennsylvania.
METHODOLOGY
We obtained an understanding of the internal controls over the Plan's claims processing and
financial systems by inquiry of Plan officials.
To test the Plan's compliance with the FEHBP health benefit provisions, we selected and
reviewed a judgmental sample of 85 claims (referred to as our system review) that were paid
during the period January 1,2008 through June 30, 2009. 3 In addition, we reviewed all debarred
providers in Minnesota for the purpose of determining if any claims were inappropriately paid to
3 For this period, we identified 2,622,517 claim lines, totaling $388,210,529 in payments, using a standard criteria
based on our experience. From this universe, we selected and reviewed a judgmental sample of 85 claims
(representing 1,308 claim lines) totaling $9,185,382 in payments. We selected our sample from an OIG-generated
"Place of Service Report" (SAS application) that stratified the claims by place of service (POS), such as provider's
office and payment category, such as $50 to $99.99. We judgmentally determined the number of sample items to
select from each POS stratum based on the stratum's total claim dollars paid.
4
these providers. We used the FEHBP contract, the Service Benefit Plan brochure, the Plan's
provider agreements, and the Association's FEP administrative manual to determine the
allowability of benefit payments, The results of these samples were not projected to the universe
. ofc1aims.
We interviewed Plan personnel and reviewed the Plan's policies, procedures, and accounting
records during our audit of miscellaneous payments and credits. For contract years 2004 through
2008, we also judgmentally selected and reviewed 56 high dollar health benefit refunds, totaling
$3,867,317 (from a universe of 8,531 refunds, totaling $10,337,994); 10 high dollar special plan
invoices, totaling $4,350,884 in net payments (from a universe of 110 special plan invoices,
totaling $7,700,165 in net payments); 19 provider settlements, totaling $1,321,823 in net
payments (from a universe of 4,034 provider settlements, totaling $5,214,826 in net payments);
and 8 fraud cases, totaling $8,087 in recoveries (from a universe of 12 fraud cases, totaling
$17,333 in recoveries), to determine if refunds and recoveries were promptly returned to the
FEHBP andif miscellaneous payments were properly charged to the FEHBP.4 In addition, we
expanded our testing of fraud recoveries to also include two recoveries, totaling $5,341, from
2009. The results of these samples were not projected to the universe of miscellaneous payments
and credits.
We also reviewed the Plan's cash management to determine whether the Plan handled FEHBP
funds in accordance with Contract CS 1039 and applicable laws and regulations.
4See the audit findings for "Provider Settlements" (A2.a) and "Fraud Recoveries and Health Benefit Refunds" (A2.b)
on pages 6 through 9 for specific details of our sample selection methodologies.
5
III. AUDIT FINDINGS AND RECOMMENDATIONS
A. HEALTH BENEFIT CHARGES
1. Claim Payments
The audit disclosed no findings pertaining to claim payments. Overall, we concluded that
the claims in our system review and debarred provider samples were paid in accordance
with the FEHBP contract, the Service Benefit Plan brochure, the Plan's provider
agreements, and/or the Association's Federal Employee Program administrative manual.
2. Miscellaneous Payments and Credits
a. Provider Settlements $24,734
The Plan overcharged the FEHBP for two provider settlements paid in 2007. As a
result, the FEHBP is due $24,734, consisting of $21 ,932 for provider settlement
overcharges and $2,802 for lost investment income (LII).
Contract CS 1039, Part III, section 3.2 (b)(l) states, "The Carrier may charge a cost to
the contract for a contract term if the cost is actual, allowable, allocable, and
reasonable."
48 CFR 52.232-17(a) states, "all amounts that become payable by the Contractor ...
shall bear simple interest from the date due ... The interest rate shall be the interest
rate established by the Secretary of the Treasury as provided in Section 611 of the
Contract Disputes Act of 1978 (Public Law 95-563); which is applicable to the period
in which the amount becomes due, as provided in paragraph (e) of this clause, and
. then at the rate applicable for each six-month period as fixed by the Secretary until
the amount is paid."
For the period 2004 through 2007, there were 4,034 provider settlements totaling
$5,214,826 in net charges to the FEHBP. From this universe, we selected and
reviewed a judgmental sample of 18 provider settlements, totaling $666,772 in net
charges, for the purpose of determining whether the Plan properly charged or timely
returned these settlements to the FEHBP. From each year, we selected settlements
based on the following methodology: highest dollar corporate settlement credit,
highest dollar corporate settlement charge, highest dollar FEP settlement credit,
highest dollar FEP settlement charge, and highest FEP allocation rate. If the same
provider settlement was selected under more than one of these methodologies, then
we only counted that settlement as one sample item. Also, there were no provider
settlement payments and/or recoveries in 2008.
6
In one instance, we determined that the Plan did not correctly allocate a provider
settlement charge to FEP. Due to a clerical error made on the Plan's settlement
allocation spreadsheet, the Plan incorrectly allocated 19.44 percent to FEP instead of
4.4 percent, resulting in an overcharge of $11,249 to the FEHBP. As a result, we
reviewed additional provider settlement allocations to determine whether there were
similar errors. We found one additional settlement error, again due to a clerical error,
where the Plan incorrectly allocated 22.98 percent to FEP instead of3.74 percent,
resulting in an overcharge of $10,683 to the FEHBP.
In total, the FEHBP is due $24,734, consisting of $21,932 for two provider settlement
overcharges and $2,802 for LII on these overcharges. We calculated LII on the
questioned provider settlement overcharges through the dates (October 21, 2009 and
November 5, 2009) when the Plan deposited the funds into the FEP investment
account.
Association's Response:
The Association agrees with this finding. The Association states that the Plan
returned the questioned amount of $24,734 to the FEHBP on January 14,2010. In
addition, the Association states, "The error was due to a clerical error and to reduce
the risk of this occurring again, the Plan now uses MS Access instead of an Excel
Spreadsheet to allocate and track provider settlements."
Recommendation 1
We verified that the Plan deposited a total of $21,932 into the FEP investment
account on October 21,2009 and November 5, 2009 for these provider settlement
overcharges. Therefore, we recommend that the contracting officer verify that the
Plan returned these funds to the FEHBP letter of credit account (LOCA).
Recommendation 2
We recommend that the contracting officer verify that the Plan credited the FEHBP
$2,802 for LII on the provider settlement overcharges.
b. Fraud Recoveries and Health Benefit Refunds $8,748
The Plan did not return six fraud recoveries and three health benefit refunds to the
FEHBP. As a result, the FEHBP is due $8,748, consisting of $8,153 for recoveries
and refunds not returned and $595 for LII.
Contract CS 1039, Part II, Section 2.3 (i) states, "All health benefit refunds and
recoveries, including erroneous payment recoveries, must be deposited into the
working capital or investment account within 30 days and returned to or accounted
for in the FEHBP letter of credit account within 60 days after receipt by the Carrier."
7
48 CFR 52.232-17(a) states, "all amounts that become payable by the Contractor ...
shall bear simple interest from the date due ... The interest rate shall be the interest
rate established by the Secretary of the Treasury as provided in Section 611 of the
Contract Disputes Act of 1978 (Public Law 95-563), which is applicable to the period
in which the amount becomes due, as provided in paragraph (e) of this clause, and
then at the rate applicable for each six-month period as fixed by the Secretary until
the amount is paid."
Fraud Recoveries
For the period 2004 through 2008, there were 12 fraud recoveries totaling $17,333.
From this universe, we selected and reviewed a judgmental sample of eight fraud
recoveries, totaling $8,087, for the purpose of determining if the Plan returned these
recoveries to the FEHBP in a timely manner. Our sample included four recoveries
that were judgmentally selected and four recoveries that, according to the Plan, were
not returned to the FEHBP.
Based on our review, we determined that the Plan did not return four fraud recoveries,
totaling $2,001, to the FEHBP. The Plan stated that these recoveries were not
returned to the FEHBP due to a lack of communication between the Plan's
departments after implementing the Association's "Fraud Information Management
System" in 2005.
As a follow-up step, we requested the Plan to review all 2009 FEP fraud recoveries to
determine if there were similar problems. The Plan reported two fraud recoveries,
totaling $5,341, during this period. Based on our review of the Plan's documentation,
we determined that the Plan did not return these two recoveries to the FEHBP.
<~ "
. In total, the Plan did not return six fraud recoveries, totaling $7,342, to the FEHBP.
We determined that the FEHBP is also due $497 for LII on these recoveries. We
calculated LII on these questioned recoveries through the date (December 29,2009)
when the Plan deposited the funds into the FEP investment account.
Health Benefit Refunds
For the period 2004 through 2008, there were 8,531 health benefit refunds (including
subrogation recoveries) totaling $10,337,994. From this universe, we selected and
reviewed a judgmental sample of 56 refunds, totaling $3,867,317, for the purpose of
determining if the Plan returned refunds to the FEHBP in a timely manner. From
each year in the audit scope, we selected all refunds greater than $20,000.
Based on our review, we determined that the Plan did not return three health benefit
refunds, totaling $811, to the FEHBP. Specifically, two refunds were not deposited
into the FEP investment account and adjusted through the LOCA, and one refund was
not adjusted through the LOCA. For the two refunds that were not deposited into the
FEP investment account, we determined that the FEHBP is also due $98 for LII on
8
these refunds. We calculated LII on these refunds through the date (December 4,
2009) when the Plan deposited the funds into the FEP investment account.
Association's Response:
The Association agrees with this finding. The Association states that the Plan
returned the questioned amount of$8,748 to the FEHBP on January 14,2010. In
addition, the Association states, "The Plan's process has been revised to ensure timely
. return ofFEHBP's portion of collected fraud recoveries and health benefit refunds to
the Program."
Recommendation 3
We verified that the Plan deposited a total of $8,153 into the FEP investment account
on various dates in December 2009 for the questioned fraud recoveries and health
benefit refunds. Therefore, we recommend that the contracting officer verify that the
Plan returned these funds to the LOCA.
Recommendation 4
We recommend that the contracting officer verify that the Plan credited the FEHBP
$595 for LII on the questioned fraud recoveries and health benefit refunds.
B. CASH MANAGEMENT
Overall, we concluded that the Planhandled FEHBP funds in accordance with Contract CS
1039 and applicable laws and regulations, except for the audit findings pertaining to cash
management noted in the "Miscellaneous Payments and Credits" section.
9
IV. MAJOR CONTRIBUTORS TO THIS REPORT
Experience-Rated Audits Group
Auditor-In-Charge
Auditor
Auditor
Auditor
Chief
Senior Team Leader
10
V. SCHEDULE A
BLUECROSS BLUESHIELD OF MINNESOTA
EAGAN, MINNESOTA
HEALTH BENEFIT CHARGES AND AMOUNTS QUESTIONED
HEALTH BENEFIT CHARGES 2004 2005 2006 2007 2008 Total
A. HEALTH BENEFIT CHARGES
PLAN CODE 220/720* $172,945,156 $190,497,897 $212,906,910 $239,670,991 $268,831,675 $1,084,852,629
MISCELLANEOUS PAYMENTS AND CREDITS 120,013 765,079 38,642 4,002,861 2,774,044 7,700,639
-,
TOTAL HEALTH BENEFIT CHARGES I $173 065,169 $191 262,976 . $212 945 552 $243 673,852 $271,605.719 $1,092 553 268 II
AMOUNTS QUESTIONED 2004 2005 2006 2007 2008 2009 Total
A. HEALTH BENEFIT CHARGES
1. CLAIM PAYMENTS $0 $0 $0 $0 $0 $0 $0
2. MISCELLANEOUS PAYMENTS AND CREDITS
a. PROVIDER SETTLEMENTS** 0 0 0 22,681 1,083 970 24,734
b. FRAUD RECOVERIES AND HEALTH BENEFIT REFUNDS* * 0 282 2,281 479 126 5,580 8,748
B. CASH MANAGEMENT 0 0 0 0 0 0 0
TOTAL AMOUNTS QUESTIONED I $0 $282 $2,281 $23,160 $1209 $6550 $33,482 ~
* We only reviewed claim payments from January 1,2006 through June 30,2009.
** This audit finding also includes lost investment income.
••
APPENDIX
BlueCross BlueShield
Association
An Association of Independent
Blue Cross and Blue Shield Plans
February 22,2010
Group Chief Federal Employee Program
Experience-Rated Audits Group 1510 G Street, N.W.
Office of the Inspector General Washington, D.C. 20005
202.942.1000
U.S. Office of Personnel Management Fax 202.942.1125
1900 E Street, Room 6400
Washington, DC 20415-1100
Reference: OPM DRAFT AUDIT REPORT
MINNESOTA BLUE CROSS BLUE SHIELD
Audit Report Number 1A-10-54-07-02
(Dated and received January 22, 2010)
Dear
This is our response to the above referenced U.S. Office of Personnel
Management (OPM) Draft Audit Report covering the Federal Employees' Health
Benefits Program (FEHBP) operations for Minnesota BlueCross BlueShield. Our
comments concerning the findings in the report are as follows:
AI 2a. Provider Settlements $24,734
We do not contest this finding. The error was due to a clerical error and to reduce
the risk of this occurring again, the Plan now uses MS Access instead of an
Excel Spreadsheet to allocate and track provider settlements.
The Plan returned $24,734 to the Program, consisting of $21,932 for two provider
settlement overcharges and $2,802 for Lost Investment Income (L1I) via wire
transfer on January 14, 2010.
A12b. Fraud Recoveries and Health Benefit Refunds $8,748
We do not contest this finding. The error was due to a process gap between
Plan departments. The Plan's process has been revised to ensure timely return
of FEHBP's portion of collected fraud recoveries and health benefit refunds to the
Program.
The Plan returned $8,748 to the Program, consisting of $8,153 for recoveries and
refunds not previously returned and $595 for Lost Investment Income (L1I) via
wire transfer on January 14, 2010.
aPM Draft Audit Response
February 22,2010
Page 2 of 2
We appreciate the opportunity to provide our response to each of the findings
and request that our comments be included in their entirety as part of the Final
Audit Report.
Executive Director
Program Integrity
cc:
Audit of Blue Cross BlueShield of Minnesota, Eagan, Minnesota
Published by the Office of Personnel Management, Office of Inspector General on 2010-03-30.
Below is a raw (and likely hideous) rendition of the original report. (PDF)