oversight

Audit of Pension and Post-Retirement Benefit Costs for a Sample of BlueCross and BlueShield Plans

Published by the Office of Personnel Management, Office of Inspector General on 2015-11-16.

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

        U.S. OFFICE OF PERSONNEL MANAGEMENT
           OFFICE OF THE INSPECTOR GENERAL
                    OFFICE OF AUDITS




                  Final Audit Report
                            AUDIT OF
              PENSION AND POST-RETIREMENT BENEFIT
              COSTS FOR A SAMPLE OF BLUECROSS AND
                       BLUESHIELD PLANS

                                            Report Number 1A-99-00-14-068
                                                   November 16, 2015

                                                             -- CAUTION --
This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may
contain proprietary data that is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of
Information Act and made available to the public on the OIG webpage (http://www.opm.gov/our-inspector-general), caution needs to be exercised
before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy.
             EXECUTIVE SUMMARY 

        Audit of Pension and Post-Retirement Benefit Costs for a Sample of BlueCross and BlueShield Plans


Report No. 1A-99-00-14-068                                                                      November 16, 2015


Why did we conduct the audit?             What did we find?

We conducted this limited scope audit     We questioned $115,126 in pension and post-retirement benefit
to obtain reasonable assurance that       costs that were overcharged to the FEHBP for 2011 through 2013.
the BlueCross and BlueShield              The BCBS Association and/or BCBS plans agreed with the
(BCBS) plans are complying with the       questioned amounts. Lost investment income (LII) on these
provisions of the Federal Employees       questioned charges amounts to $4,040, which is calculated from
Health Benefits Act and regulations       January 1, 2012 through September 30, 2015.
pertaining to pension and post-
retirement benefit costs that are         Our audit results are summarized as follows:
included, by reference, in the Federal
Employees Health Benefits Program         	 Pension Costs – Our audit determined that two BCBS plans in
(FEHBP) contract. Specifically, the          our sample overcharged the FEHBP $10,399 for pension costs
objective of our audit was to                from 2011 through 2013. These pension cost overcharges
determine whether the 24 BCBS plans          consisted of $8,771 by Triple-S, Inc. and $1,628 by BCBS of
in our sample charged pension and            Vermont.
post-retirement benefit costs to the
FEHBP in accordance with the terms        	 Post-Retirement Benefit Costs – Our audit also determined that
of the contract and applicable               BCBS of Delaware overcharged the FEHBP $104,727 for post-
regulations.                                 retirement benefit costs from 2011 through 2013.

What did we audit?                        	 Lost Investment Income on Audit Findings – As a result of our
                                             audit findings presented in this audit report, the FEHBP is due
Our focused audit covered pension            LII of $4,040, calculated from January 1, 2012 through
and post-retirement benefit costs that       September 30, 2015.
were charged to the FEHBP from
2011 through 2013 for a sample of 24
BCBS plans.




_______________________
Michael R. Esser
Assistant Inspector General
for Audits
                                                        i
                    ABBREVIATIONS

Association   BlueCross BlueShield Association
BCBS          BlueCross BlueShield or BlueCross and BlueShield
CFR           Code of Federal Regulations
FAR           Federal Acquisition Regulations
FEHB          Federal Employees Health Benefits
FEHBAR        Federal Employees Health Benefits Acquisition Regulations
FEHBP         Federal Employees Health Benefits Program
FEP           Federal Employee Program
LII           Lost Investment Income
OIG           Office of the Inspector General
OPM           U.S. Office of Personnel Management
PRB           Post-Retirement Benefit




                                    ii
IV. MAJOR CONTRIBUTORS TO THIS REPORT
          TABLE OF CONTENTS

                                                                                                                               Page
          EXECUTIVE SUMMARY ........................................................................................... i 


          ABBREVIATIONS ...................................................................................................... ii 


  I.	     BACKGROUND ...........................................................................................................1 


  II.	    OBJECTIVE, SCOPE, AND METHODOLOGY .........................................................3 


  III.	   AUDIT FINDINGS AND RECOMMENDATIONS ....................................................5 


          A. Pension Costs ...........................................................................................................5 


          B. Post-Retirement Benefit Costs .................................................................................7 


          C. Lost Investment Income on Audit Findings.............................................................8 


  IV.	    MAJOR CONTRIBUTORS TO THIS REPORT........................................................10 


          APPENDIX (BlueCross BlueShield Association’s Draft Report Response, dated 

          July 27, 2015) 


          REPORT FRAUD, WASTE, AND MISMANAGEMENT

IV. MAJOR CONTRIBUTORS
            I. BACKGROUND
                       TO THIS REPORT
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 a
sample of 24 BlueCross and BlueShield (BCBS) plans, pertaining to pension and post-retirement
benefit costs.

The audit was performed by the U.S. Office of Personnel Management’s (OPM) Office of the
Inspector General (OIG), as established by the Inspector General Act of 1978, as amended.

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 Healthcare and Insurance
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 BCBS 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 BCBS plans throughout the United States to process the health benefit claims
of its federal subscribers. There are 36 BCBS companies participating in the FEHBP. These 36
companies include 64 local BCBS plans.

The Association has established a Federal Employee Program (FEP1) 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
BCBS 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 Owings Mills,
Maryland and Washington, D.C. These activities include acting as intermediary for claims
processing between the Association and local BCBS plans, processing and maintaining
subscriber eligibility, adjudicating member claims on behalf of BCBS plans, approving or
disapproving the reimbursement of local plan payments of FEHBP claims (using computerized
system edits), maintaining a history file of all FEHBP claims, and maintaining claims payment
data and related financial data in support of the Association’s accounting of all program funds.
1
  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                                 Report No. 1A-99-00-14-068
Compliance with laws and regulations applicable to the FEHBP is the responsibility of the
management for the Association and each BCBS plan. Also, working in partnership with the
Association, management of each BCBS plan is responsible for establishing and maintaining a
system of internal controls.

This is our first focused audit of pension and post-retirement benefit costs for these 24 BCBS
plans. The results of this audit were discussed with the Association and BCBS plan officials
throughout the audit and at an exit conference on May 26, 2015. 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. Also, additional documentation provided by the
Association and BCBS plans on various dates through September 21, 2015 was considered in
preparing our final report.




                                               2                           Report No. 1A-99-00-14-068
    II. OBJECTIVE, SCOPE, AND METHODOLOGY

OBJECTIVE

The objective of this audit was to determine whether the 24 BCBS plans in our sample charged
pension and post-retirement benefit costs to the FEHBP in accordance with the terms of the
contract and applicable regulations.

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 objective. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objective.

The audit covered pension and post-retirement benefit costs from 2011 through 2013 for a
sample of 24 BCBS plans (from a universe of 64 BCBS plans). 2 Our sample included all BCBS
plans with FEHBP charges of$350 million or less in contract year 2013 (except for several
BCBS plans that are part of multi-plan companies, such as Anthem Inc. and Regence). For
contract years 2011 through 2013, these 24 BCBS plans charged approximately $21.7 million
and $5.5 million to the FEHBP for pension and post-retirement benefit costs, respectively.
Specifically, we reviewed pension and post-retirement benefit costs to determine ifthese 24
BCBS plans charged these costs to the FEHBP in accordance with the contract and applicable
regulations. The results of our reviews for the sample of24 BCBS plans were not projected to
the universe of all BCBS plans.

We did not consider each BCBS plan's internal control structure in planning and conducting our
auditing procedures. Our audit approach consisted mainly of substantive tests of transactions
and not tests of controls. Therefore, we do not express an opinion on each BCBS plan's system
of internal controls taken as a whole.

We conducted tests to determine whether the BCBS plans in our sample 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),
2
 Our sample consisted of the following BCBS plans: BCBS of Arkansas, Highmark BCBS of Delaware, BCBS of
Hawaii, BCBS ofldaho, Wellmark BCBS (Iowa/South Dakota), BCBS of Kansas, BCBS ofLouisiana, BCBS of
Michigan, BCBS of Mississippi, BCBS of South Carolina, BCBS of Kansas City, BCBS of Montana, BCBS of
Nebraska, BCBS of Western New York, Excellus BCBS (New York), BCBS ofNorth Dakota, Capital BlueCross
(Pennsylvania), Independence BlueCross (Pennsylvania), BlueCross ofNortheastern Pennsylvania, Triple-S, Inc. of
Puerto Rico, BCBS of Rhode Island, BCBS of Vermont, Mountain State BCBS (West Virginia), and BCBS of
Wyoming.


                                                       3                              Report No. 1A-99-00-14-068
and the laws and regulations governing the FEHBP as they specifically relate to pension and
post-retirement benefit costs. The results of our tests indicate that, with respect to the items
tested, the BCBS plans did not fully comply with the provisions ofthe contract and applicable
regulations relative to pension and post-retirement benefit costs. 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 BCBS plans 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 PEP Director's Office and the BCBS plans. Due to time constraints, we did not verify the
reliability of the data generated by the various information systems involved. However, while
utilizing the computer-generated data during our audit, nothing came to our attention to cause us
to doubt its reliability. We believe that the data was sufficient to achieve our audit objective.

The audit was performed at our offices in Washington, D.C. and Jacksonville, Florida from
January 15,2015 through May 26,2015.

METHODOLOGY

We reviewed the BCBS plans' policies, procedures, calculations, and/or accounting records
during our audit of pension and post-retirement benefit costs. We used the FEHBP contract, the
FAR, and the FEHBAR to determine the allowability, allocability, and reasonableness ofthe
plans' charges to the FEHBP for pension and post-retirement benefit costs.




                                                 4                           Report No. 1A-99-00-14-068
III. AUDIT FINDINGS AND RECOMMENDATIONS 


A. Pension Costs                                                                             $10,399

   Our audit determined that .2. of the 24 BCBS plans in our sample overcharged the FEHBP
   $10,399 for pension costs from 2011 through 2013. These pension cost overcharges
   consisted of $8,771 by Triple-S, Inc. and $1 ,628 by BCBS of Vermont.

   Contract CS 103 9, Part III, section 3 .2 (b )(1) 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 31.205-6(j)(l) states, "Pension plans are normally segregated into two types of
   plans: defined-benefit and defined-contribution pension plans. The contractor shall measure,
   assign, and allocate the costs of all defined-benefit pension plans and the costs of all defined­
   contribution pension plans in compliance with 48 CFR 9904.412 (Cost Accounting Standard
   for Composition and Measurement of Pension Cost) and 48 CFR 9904.413 (Adjustment and
   Allocation of Pension Cost). Pension costs are allowable subject to the referenced standards
   and the cost limitations and exclusions set forth in paragraph (j)(1)(i) ... of this subsection."
   Paragraph (j)(1 )(i) of this subsection states, "Except for nonqualified pension plans using the
   pay-as-you-go cost method, to be allowable in the current year, the contractor shall fund
   pension costs by the time set for filing of the Federal income tax return or any extension.
   Pension costs assigned to the current year, but not funded by the tax return time, are not
   allowable in any subsequent year. For nonqualified pension plans using the pay-as-you-go
   method, to be allowable in the current year, the contractor shall allocate pension costs in the
   cost accounting period that the pension costs are assigned. "

   FAR limits the amount of pension cost that may be charged to a government contract to the
   amount of any cash contribution to the pension fund trustee, or the amount of expense
   calculated in accordance with Cost Accounting Standard (CAS) 412 and 413, whichever is
   lower.

   For the period 2011 through 2013 , we reviewed the pension costs that were charged to the
   FEHBP for a sample of24 BCBS plans to determine ifthe pension costs were properly
   charged to the FEHBP in accordance with the contract and applicable regulations . Based on
   our review of these BCBS plans ' pension costs and supporting documentation, we
   determined that two ofthe BCBS plans (Triple-S, Inc. and BCBS of Vermont) did not
   properly charge pension costs to the FEHBP in accordance with the contract and applicable
   regulations.




                                              5                                Report No. 1A-99-00-14-068
The following schedule summarizes the questioned pension costs for these two BCBS plans:

                                                                              Total
           Plan                2011             2012          2013          Questioned
 Triple-S, Inc.                 ($3 ,307)       ($1 ,640)      $13 ,718           $8,771
 BCBS of Vermont                   (802)             329         2,101             1,628
          Total                 ($4,109)        ($1 ,311)      $15 ,819         $10,399

For Triple-S, Inc. , we determined that the plan overcharged the FEHBP $8,771 (net) for
pension costs from 2011 through 2013 . Specifically, the plan did not make the applicable
out-of-system adjustments for pension costs in 2011 through 2013 . This resulted in pension
cost undercharges of$3,307 and $1 ,640 to the FEHBP in 2011 and 2012, respectively, and a
pension cost overcharge of $13 ,718 to the FEHBP in 2013.

For BCBS of Vermont, we determined that the plan overcharged the FEHBP $1 ,628 (net) for
pension costs from 2011 through 2013. In 2011 , the plan made an out-of-system adjustment
for pension costs but inadvertently removed too much of the costs, resulting in an
undercharge of$802 to the FEHBP. In 2012 and 2013 , the plan made out-of-system
adjustments for pension costs but removed amounts that were less than what the plan actually
should have, resulting in overcharges of$329 and $2,101 to the FEHBP in 2012 and 2013 ,
respectively.

Association's Response:

Regarding Triple-S, Inc. , the Association states that the plan agrees that out-of-system
adjustments were not made for pension costs in 2011 through 2013 , resulting in undercharges
to the FEHBP in 20 11 and 2012 and an overcharge in 2013 .

For BCBS of Vermont, the Association states that the plan agrees with the questioned
charges.

OIG Comment:

Subsequent to the draft report, we revised the questioned charges for Triple-S, Inc. In an
email (dated August 20, 20 15), the Association informed us that Triple-S, Inc. agrees with
the revised questioned charges of$8,771 (net).




                                            6                             Report No . 1A-99-00-14-068
   Recommendation 1

   We recommend that the contracting officer disallow $10,399 (net) for pension costs that were
   overcharged to the FEHBP from 2011 through 2013 ($8 ,771 by Triple-S, Inc. and $1,628 by
   BCBS ofVermont).

B. Post-Retirement Benefit Costs                                                           $104,727

   Our audit determined that BCBS of Delaware overcharged the FEHBP $104,727 for 

   post-retirement benefit (PRB) costs from 2011 through 2013. 


   As previously cited from Contract CS 1039, costs charged to the FEHBP must be actual,
   allowable, allocable and reasonable.

   48 CFR 31.205-6(o) states, "(1) PRB covers all benefits, other than cash benefits and life
   insurance benefits paid by pension plans, provided to employees, their beneficiaries, and
   covered dependents during the period following the employees' retirement. Benefits
   encompassed include, but are not limited to, postretirement health care; life insurance
   provided outside a pension plan; and other welfare benefits such as tuition assistance, day
   care, legal services, and housing subsidies provided after retirement. (2) To be allowable,
   PRB costs shall be incurred pursuant to law, employer-employee agreement, or an
   established policy of the contractor, and shall comply with paragraphs (o)(2)(i), (ii), or (iii) of
   this subsection."

                             For the period 2011 through 2013, we reviewed the PRB costs that
    BCBS of Delaware
                             were charged to the FEHBP for a sample of 24 BCBS plans. Based
     overcharged the
                             on our review, we determined that BCBS of Delaware did not
     FEHBP $104,727
                             charge PRB costs to the FEHBP in accordance with the terms ofthe
      for PRB costs.
                             contract and applicable regulations.

   BCBS ofDelaware used the cash (or pay-as-you-go) method and charged $221,470 to the
   FEHBP for PRB costs from 2011 through 2013. We reviewed the Delaware plan's
   calculations of the PRB costs charged to the FEHBP and determined if these costs were
   calculated in accordance with 48 CFR 31.205-6(o). We determined that the plan did not
   allocate PRB costs on an actual payment basis during the audit scope. Specifically, each year
   the plan allocated a percentage of the corporate payments in the cost system to FEP, without
   adjusting the corporate payments to reflect the actual PRB payments incurred. As a result,
   the FEHBP was overcharged $104,727 for PRB costs from 2011 through 2013 (i.e., $31,921
   in 2011, $15,265 in 2012, and $57,541 in 2013).




                                                  7                            Report No. 1A-99-00-14-068
   Association's Response:

   The Association states that BCBS of Delaware agrees with the questioned charges.

   Recommendation 2

   We recommend that the contracting officer disallow $104,727 for PRB costs that were
   overcharged to the FEHBP by BCBS of Delaware from 2011 through 2013.

C. Lost Investment Income on Audit Findings                                                 $4,040

   As a result of the audit findings presented in this report, the FEHBP is due LII of $4,040
   from January 1, 2012 through September 30,2015.

   FAR 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."

   We calculated investment income that would have been earned using the semiannual rates
   specified by the Secretary of the Treasury. Our calculations show that the FEHBP is due LII
   of$4,040 from January 1, 2012 through September 30,2015 on the questioned pension and
   PRB costs that were overcharged to the FEHBP for contract years 2011 through 20 13.

   The following table summarizes the questioned LII amount that is due by each BCBS plan:

                   Plan                     LII Amount Due
    BCBS of Delaware                                   $3,478
    Triple-S, Inc.                                        507
    BCBS of Vermont                                        55
                   Total                               $4,040

   OIG Comment:

   The draft audit report did not include an audit finding for LII. Therefore, the Association did
   not address this item in its reply.




                                                 8                            Report No. 1A-99-00-14-068
Recommendation 3

We recommend that the contracting officer direct the applicable BCBS plans to credit $4,040
(plus interest accruing after September 30, 20 15) to the Special Reserve for LII on audit
findings.




                                            9                          Report No. 1A-99-00-14-068
 IV. MAJOR CONTRIBUTORS TO THIS REPORT 


Experience-Rated Audits Group

               , Lead Auditor

               , Auditor

          , Auditor



                  , Chief

              , Senior Team Leader




                                     10   Report No. 1A-99-00-14-068
                                                                     .,
                                                                     BlueCross BlueShield
                                                                                           APPENDIX



                                                                     Association
                                                                     An Association of Independent
July 27, 2015                                                        Blue Cross and Blue Shield Plans

                         , Group Chief 	                             Federal Employee Program
Experience-Rated Audits Group                                        1310 G Street, N.W.
                                                                     Washington, D.C. 20005
Office of the Inspector General                                      202.942.1000
U.S. Office of Personnel Management                                  Fax 202.942.1125
1900 E Street, Room 6400
Washington , DC 20415-11000

Reference: 	              OPM DRAFT AUDIT REPORT
                          Audit of Pension and Postretirement Costs
                          For a Sample of Blue Cross Blue Shield Plans Audit
                          Audit Report Number 1A-99-00-14-068

Dear                  :

This is the Blue Cross and Blue Shield Association's response to the above referenced U.S. 

Office of Personnel Management (OPM) Draft Audit Report covering the Federal Employees' 

Health Benefits Program (FEHBP) Pension and Postretirement Benefit costs for a sample of 

Blue Cross Blue Shield Plans. 


Our comments concerning the findings in the report are as follows:

Pension Costs 	                                                                          $2,853,379


Deleted by the Office ofthe Inspector General- Not Relevant to the Final 

Report 





                                                                     Report No. lA-99-00-14-068
July 27 , 2015
Page 2 of 4

Deleted by the Office ofthe Inspector General- Not Relevant to the Final
Report




Triple-S, Inc.                                                                       $7,467

The Plan agrees that the plan did not make out-of-system adjustments for pension costs in
2011 through 2013, which resulted in an undercharge of $3,307 and $1 ,640 in 2011 and 2012,
respectively and an overcharge of $13,718 in 2013 to the FEHBP for a net overcharge of
$7,467 .

Blue Cross Blue Shield of Vermont                                                     $1,628

The Plan agrees that the plan overcharged the FEHBP $1 ,628 (net) in pension expenses
from 2011 through 2013. In 2011 , the plan made an out-of-system adjustment but
removed an amount more than what the plan should have, resulting in an undercharge of
$802 to the FEHBP. In 2012 and 2013, the plan made out-of-system adjustments but
removed an amount less than what the plan should have, resulting in overcharges of
$329 and $2,101 in 2012 and 2013, respectively .


                                                                Report No. l A-99-00-14-068
July 27, 2015
Page 3 of 4


Post-Retirement Benefit Costs                                                   $320,151


Deleted by the Office ofthe Inspector General- Not Relevant to the Final
Report

BCBS of Delaware                                                                $104,727

The Plan agrees that the Plan may have overcharged the FEHBP $104 ,727 in post-retirement
expenses from 2011 through 2013.


Deleted by the Office ofthe Inspector General- Not Relevant to the Final
Report




                                                              Report No. lA-99-00-14-068
                        

July 27 , 2015 

Page 4 of 4 


We appreciate the opportunity to provide our response to this Draft Audit Report and request
that our comments be included in their entirety as an amendment to the Final Audit Report.

Sincerely,




                    

Managing Director, Program Assurance 


Attachment




                                                                  Report No. lA-99-00-14-068
                                       Report Fraud, Waste, and 

                                           Mismanagement 

                                                  Fraud, waste, and mismanagement in
                                               Government concerns everyone: Office of
                                                   the Inspector General staff, agency
                                                employees, and the general public. We
                                              actively solicit allegations of any inefficient
                                                    and wasteful practices, fraud, and
                                               mismanagement related to OPM programs
                                              and operations. You can report allegations
                                                          to us in several ways:


                     By Internet: 	               http: //www. opm. govI our-inspector-general/hotline-to­
                                                  report-fraud-waste-or-abuse


                         By Phone: 	              Toll Free Number:                              (877) 499-7295
                                                  Washington Metro Area:                         (202) 606-2423


                           By Mail:               Office of the Inspector General
                                                  U.S. Office ofPersonnel Management
                                                  1900 E Street, NW
                                                  Room 6400
                                                  Washington, DC 20415-1100




                                                             --CAUTION-­
This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may
contain proprietary data that is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of
Information Act and made available to the public on the OIG webpage (http:llwww.opmgov/our-inspector-generaf), caution needs to be exercised
before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy.

                                                                                                                Report No. 1A-99-00-14-068